Legal notices

Terms and conditions

Last updated: 21 ottobre 2026

1. 1. Who provides the Service
2. 2. Who the Service is for
3. 3. What the Service is, and what it is not
4. 4. Organisation, users and credentials
5. 5. Credit, prices and payment
6. 6. Delivery of documents
7. 7. Report Titolare Effettivo Estero
8. 8. The free trial
9. 9. Permitted use
10. 10. Personal data in the documents
11. 11. Intellectual property
12. 12. Liability
13. 13. Availability of the Service and API
14. 14. Suspension and termination
15. 15. Changes to these terms
16. 16. Governing law and jurisdiction
17. 17. Contact details
18. 18. The assistant
19. 19. Specific approval

1. Who provides the Service

Complify is a registered trademark of Esquad S.r.l., with registered office at Via Pedro Alvares Cabral 6, 87036 Rende (CS), tax code and VAT number 10229340962, entered in the Economic and Administrative Index (REA) under number CS-250237, share capital 10.000,00 € (hereinafter “the Provider”). The commercial information activity is carried out within the scope of the prefectural authorisation provided for by Article 134 of the Italian Consolidated Public Security Act (T.U.L.P.S.).

These terms govern access to the Complify portal and the purchase and use of the information services offered on it (hereinafter “the Service”).

2. Who the Service is for

The Service is reserved for businesses, professionals and entities acting in the course of their business or professional activity. It is not offered to consumers and is not intended for personal purposes or purposes unrelated to the user's professional activity. The provisions of the Italian Consumer Code on contracts concluded with consumers, including the right of withdrawal, therefore do not apply.

Anyone who activates the Service declares that they act on behalf of an organisation and that they have the authority to bind it to these terms.

3. What the Service is, and what it is not

The Service provides commercial information on businesses and individuals drawn from official and public sources — including the business register, filed financial statements, the land registry, the registers of protests and prejudicial acts, and international sanctions lists — processed and collected into documents that state the source and the date to which each item of data refers, or processed manually by the Provider's staff, as in the case of the “Report Titolare Effettivo Estero” (Article 7).

Risk assessments are evaluations produced with declared rules and with artificial intelligence tools, accompanied by their reasoning. They are a tool in support of the customer's decisions: they are not legal, financial or tax advice, they do not guarantee anyone's solvency, and they do not replace the customer's own assessments or the customer-due-diligence obligations to which the customer is subject by law. They do not constitute an assessment of the creditworthiness of consumers.

4. Organisation, users and credentials

The Service is activated for an organisation, which may have several users. Credentials are personal and may not be shared. The Customer is responsible for the use of the Service by its users, keeps the credentials with due care, and promptly notifies the Provider of any unauthorised use or suspected compromise. The Provider may suspend a user account where it has reason to believe that the credentials have been compromised or used in a non-compliant manner.

5. Credit, prices and payment

The Service is paid for on a pay-as-you-go basis, with the organisation's prepaid credit. The price of each product is shown in the portal before purchase and includes VAT; at the time of purchase the amount is deducted from the credit. There are no subscription fees, minimum usage commitments or tacit renewals.

Credit does not expire and is not refundable. Automatic reversals are an exception: when a purchased product cannot be delivered for reasons that do not depend on the customer, including where a manually fulfilled request closes with a negative outcome (Article 7), the relevant amount is returned to the organisation's credit, as indicated by the portal.

In the event of definitive termination of the Service at the Provider's initiative, any credit that was purchased and not used will be refunded.

Tax documents are issued by the Provider on the basis of the organisation's billing details. Any special conditions agreed in writing with the customer prevail over these terms.

6. Delivery of documents

Subject to Article 7, documents are delivered in the portal, as a rule within a few minutes of purchase, depending on the availability and response times of the sources, and remain in the organisation's archive, where all its authorised users can re-read them without any new charge. Some information may arrive from the sources at a later time: in that case the document says so and supplements itself as soon as the information becomes available, at no further cost.

Each document is fixed at the date of the data it contains and states that date. A later update is a new purchase, or is provided by monitoring where the customer has activated it.

7. Report Titolare Effettivo Estero

The “Report Titolare Effettivo Estero” (foreign beneficial owner report, the “BO Report”) is a document prepared by the Provider through the manual work of its staff. On the basis of the data supplied by the Customer and the sources consulted, it reconstructs the ownership chain of the company indicated and proposes the persons who are its beneficial owners pursuant to Article 20 of Legislative Decree no. 231/2007 or the applicable foreign rules.

The identification of beneficial owners is a reasoned proposal, referring to the fulfilment date shown in the document and based on the data accessible on that date. The BO Report is not an attestation, a certification or a legal opinion, and it does not replace the Customer's own checks and assessments or the customer-due-diligence obligations incumbent on the Customer by law, for which the Customer remains solely responsible. Where the registers of a jurisdiction are not public, are not accessible or are not up to date, the BO Report says so and applies, where provided for, the residual criterion.

The Customer indicates the name, address and country of the company and is responsible for their accuracy and for their referring to the company that it intends to verify. The BO Report concerns the company identified by the data supplied: the Provider is not liable for errors arising from inaccurate or incomplete data, or from homonyms that the data supplied do not allow to be resolved.

The BO Report is not delivered within the times stated in Article 6. The Provider delivers it within five working days of the request, excluding Saturdays, Sundays and Italian national public holidays. The term is indicative and failure to meet it does not give rise to any right to compensation. Delivery is notified in the portal and, for users who have not disabled communications, by email.

The fee is charged at the time of the request. If the Provider is unable to determine a beneficial owner or to locate the company indicated, the request closes with the outcome “not fulfilled”, no fee is due, and the amount is automatically credited back to the organisation's credit, stating the reason. The Customer may not cancel a request that has already been submitted.

The BO Report is fixed at the fulfilment date. An update is a new request and a new purchase.

The BO Report contains personal data of natural persons, drawn from public sources. Articles 9 and 10 apply; the Customer uses such data for customer-due-diligence obligations and for the professional purposes declared.

8. The free trial

The Provider may activate, at its discretion, a free trial with a limited number of positions and a dedicated free credit. Trial credit is not convertible or refundable, and is valid only for the purposes of the trial. The trial entails no commitment for the customer: at its end the Provider writes once only to ask whether to continue.

9. Permitted use

The customer uses the information for its own lawful purposes connected with its business, such as the assessment of customers, suppliers and counterparties, credit management, fraud prevention and compliance with legal obligations.

The Customer is responsible for the lawfulness of the requests made and of the use of the information obtained and, where it concerns natural persons, for compliance with the applicable personal data protection legislation.

It is not permitted to:

• resell, assign, publish or make available to third parties the documents or their content, except to the extent necessary for the customer's purposes;
• extract data systematically or in an automated manner outside the interfaces provided, including the APIs;
• use the information for unlawful or discriminatory purposes, or in any case purposes unrelated to the professional purposes declared;
• use the service for the assessment of the creditworthiness of consumers;
• attempt to circumvent the portal's security measures or to access data, accounts or organisations other than those for which the user is authorised.

10. Personal data in the documents

The documents may contain personal data of natural persons, drawn from public sources.

The Provider processes personal data in the context of the collection, processing and supply of commercial information as an independent controller, in accordance with the applicable legislation and the relevant privacy notices.

The Customer, when it acquires and uses for its own purposes the data contained in the documents, acts as an independent controller of the related processing and is responsible for their use in compliance with the applicable legislation.

The evidence is extracted by automated means from freely accessible web sources concerning natural persons, including so-called “bad news”, and is supplied for the assessment of the counterparty (for example for customer due diligence). The Customer must on no account use it for different purposes, does not rely on it as the sole basis for decisions concerning the person and, before making use of it, verifies its content against the source indicated. The Customer also may not share it with anyone and for any reason, save for legal obligations, and assumes all civil and criminal liability for its use.

The processing of the data of users and visitors by the Provider is described in the privacy notice.

11. Intellectual property

The portal, the layout of the documents, the texts, the assessments and the Complify trademark belong to the Provider. The customer receives a non-exclusive, non-transferable licence to use the documents purchased, for the purposes of point 9. Data from public sources remain subject to the rules of the respective sources.

Systematic reproduction or extraction of the content aimed at creating or feeding competing databases or services is prohibited.

12. Liability

The information is reported on the basis of the data available from the relevant sources at the date shown in the document. The Provider takes care over the correctness of the processing but is not liable for errors, omissions, delays or failures to update attributable to the sources, nor for the incompleteness or inaccuracy of information that depends on foreign registers that are not public, not accessible or not up to date.

The decisions taken by the Customer on the basis of the information received remain its own responsibility and competence.

Except in cases of wilful misconduct or gross negligence, the Provider's liability towards the customer, for any cause, is limited to the amounts paid by the customer for the Service in the twelve months preceding the event that gave rise to it.

To the extent permitted by law, the Provider is not liable for indirect or consequential damages, loss of profit or loss of business opportunities.

13. Availability of the Service and API

The Provider does whatever is reasonably possible for the Service to be continuously available, but does not guarantee it: maintenance work, updates or unavailability of the sources may suspend it for the time necessary. The Provider may modify or supplement the content of the products, while preserving their function.

API access takes place with one key per organisation, which the customer keeps as a credential and which the Provider may revoke in the event of non-compliant use.

14. Suspension and termination

The customer may stop using the Service at any time, without notice and at no cost: there is no contract to terminate. The Provider may suspend or terminate access to the Service in the event of breach of these terms, unlawful or abusive use, security risks, compromise of credentials, or where this is necessary to comply with legal obligations or requests from the authorities. Where possible, and taking into account the seriousness of the breach, the Provider informs the Customer and allows it to remedy the breach before definitive termination.

What is provided in point 5 on residual credit remains unaffected.

15. Changes to these terms

The Provider may update these terms by publishing them on this page with the date of the update. The changes apply to purchases made after publication; significant changes are also communicated by email to the administrators of the organisations.

16. Governing law and jurisdiction

These terms are governed by Italian law. For any dispute relating to the Service, the Court of Cosenza has exclusive jurisdiction.

17. Contact details

For any communication: Esquad S.r.l., Via Pedro Alvares Cabral 6, 87036 Rende (CS), email assistenza.clienti@complify.it, telephone 800 689874, certified email (PEC) esquad@legalmail.it.

18. The assistant

18.1. If the Customer has activated it, the Service includes “BIAI”, an automated artificial intelligence system (the “Assistant”) that answers questions about the use of the Service and about the subjects (businesses and individuals) present in the Customer's archive, by reading the data and documents to which the user already has access.

18.2. The Assistant does not decide, does not modify the archive and does not provide professional, legal, financial or credit opinions; it makes purchases only in the cases and within the limits of Article 18.6. Its answers report the assessments stored in the documents, at the date indicated, and do not replace the Customer's own assessments and customer-due-diligence obligations, for which the Customer remains solely responsible. The Customer verifies the content against the document before making use of it; the Assistant may be wrong.

18.3. The Assistant answers only on topics relating to the Service and to the Customer's archive. It is prohibited to use it for purposes other than those of Article 9, to circumvent legal obligations, or to obtain information on persons unconnected with a due-diligence file (istruttoria). Non-compliant requests are refused and reported to the Provider, which may suspend access to the Assistant.

18.4. Conversations are recorded and kept for twelve months, as described in the privacy notice. The Customer informs its users and does not enter unnecessary personal data in the chat.

18.5. The Assistant may be unavailable or limited in daily use. At any time the user may ask to speak with a member of the customer support team, within the service hours. The Provider may modify or suspend the Assistant without this constituting a breach.

18.6. Purchases on behalf of the user. If the function is activated, at the Customer's request, for the team to which the user belongs, and the user gives the Assistant a mandate from the Assistant's panel, the Assistant may search for subjects (businesses and individuals) in the databases that can be consulted through the Service and purchase, in the name and on behalf of the Customer, the products in the Customer's price list, including the update of a document already purchased. Each purchase: (a) is prepared by the Assistant and shown to the user with the product, the subject, its identification code and the price; (b) is executed only after the user's express confirmation in the same conversation, and a message that the Service does not recognise as a confirmation counts as a refusal; (c) falls within the daily threshold stated in the mandate, within the daily limits on searches and purchases set for the team, and within the available credit. A confirmed purchase is charged to the Customer as if the user had made it directly through the Service, under the terms of Article 5. The Customer is responsible for the request to activate the function and for the mandates given by its users. The user may revoke the mandate at any time from the Assistant's panel. The Provider records mandates, orders, confirmations and outcomes, and makes them available to the Customer on request.

19. Specific approval

For the purposes of Articles 1341 and 1342 of the Italian Civil Code, the Customer specifically approves the following clauses: Article 7 (Report Titolare Effettivo Estero); Article 10 (Personal data in the documents); Article 12 (Liability); Article 14 (Suspension and termination); Article 16 (Governing law and jurisdiction); Article 18 (The assistant).