Terms & Conditions

Version 1.0 – September 2025

These Terms are published by us, Cleo AI Limited (referred to in these Terms as “us”, “we”, and “our”), a company registered in England and Wales under company number 09864205. Our registered office address is 3rd Floor, 1 Ashley Road, Altrincham, Cheshire, WA14 2DT, United Kingdom. You can reach us at team@meetcleo.com.

1.     What do these Terms cover and when will they apply?

These Terms govern the access to and use of our AI assistant which aims to make it easy for you to manage your money, we call our AI assistant “Cleo”.

They form the basis of a legal agreement between us and you when you sign up to use Cleo using the sign-up process available on our website (https://web.meetcleo.com/) (our “Site”) or when you otherwise use Cleo for the first time.

Please read these Terms carefully and let us know if you have any questions.

2.     Regulated financial services

To use Cleo, you need to give us access to certain information such as your bank account balance and transaction data (more on that below), when we access such data and information to provide you with our services we are providing an account information service for you, which is a regulated financial service.

We don’t receive any funds from you, and we cannot send any funds anywhere on your behalf. The terms relating to the bank account which you link to Cleo will be those provided to you by the provider of your bank account. We aren’t responsible for your bank account or any of the funds in it.

We are authorised and regulated by the UK’s Financial Conduct Authority (the “FCA”) as a registered account information services provider with firm reference number 806670.

3.     What is Cleo and how can you use it?

3.1.  What does Cleo do?

Cleo is a web-based application which uses artificial intelligence to analyse data and information you provide to it, together with Third-Party Information (as defined below) to respond to requests you make of it (using Cleo’s functionality) from time to time.

Cleo is programmed to enable you to get insight into your spending data and trends, with the intention that Cleo helps you with you planning your budgeting and saving goals. 

When using our free-of-charge version of Cleo, you will have access to the following features:

●        budgeting tools, and: Cleo allows you to set a monthly budget with category-specific spending limits. You can also view previous budgets and generate insights based on your spending to help monitor and manage your finances, and

●        account overview: Cleo lets you view the balance and transaction history of any accounts you have linked to the app, all in one place.

As Cleo is a mobile phone application, there are certain minimum requirements which the device you seek to use to access Cleo will need to meet. We will let you know what these requirements are before you try to download Cleo to your device but, as a minimum, your device will need to have an operating system of iOS version 15.1 or later, or android version 10 or later (“Minimum Device Requirements”).

Where you ask Cleo (using the functionality available in Cleo) to provide you with alerts relating to the saving goals or spending challenges you have set, we will make reasonable efforts to provide you with such alerts, but you acknowledge and agree that:

●        there are a number of factors which affect the timeliness of the alert being provided to you, such as the availability and the speed in which Cleo is given access to Third-Party Account Information (as defined below),

●        alerts will be provided based on the information provided to Cleo at the time that Cleo makes the alert available to you and therefore may not be up to date, and

●        Cleo relies on machine-based software which operates with a degree of autonomy, it uses input data to infer how to produce outputs (including alerts). Whilst we have tried to programme Cleo to be as accurate as possible, we cannot guarantee that alerts will accurately reflect your saving goals, spending challenges, or your then-current financial position due the nature of artificial intelligence technologies.

If you no longer wish to receive alerts, you can turn them off using Cleo’s functionality. You can re-enable alerts after you turn them off where permitted by the functionality of Cleo.

Additional features and functionality may be available in paid-for versions of Cleo, to access those features and functionality you will need to subscribe (under separate terms and conditions) to use those versions.

3.2.  Cleo does not provide financial advice

It is important that you note that we do not intend to provide you with any legal, tax, or financial advice through your use of Cleo. Cleo cannot provide you with direct investment advice (such as by recommending a particular investment strategy or investment). We are not a law firm, tax advisor, accountancy firm, broker, or financial planner.

We strongly encourage you to consider consulting a suitably authorised accountant or financial advisor before implementing any financial strategy or making any other financial decision.

3.3.  What can you use Cleo for?

You can only use Cleo in accordance with its functionality and for your own purposes i.e. not for any commercial purposes.

3.4.  Third party account information

When using Cleo, you may direct Cleo to retrieve your account transaction history, balance information, or other information maintained by one or more third parties with which you have relationships, maintain accounts or engage in financial transactions (“Third-Party Account Information”). 

We work with one or more third-party service providers to access Third-Party Account Information.  Cleo will use this information to provide you insights in accordance with its functionality, we will also use it for our own internal business purposes (after anonymising it) and to offer you other products and services that may be of interest to you.

We need your explicit consent to be able to obtain Third-Party Account Information on your behalf. By using Cleo, you therefore expressly authorise us to access Third-Party Account Information maintained by identified third parties, on your behalf as your agent, and you expressly authorise such third parties to disclose your information to us. 

When we access Third-Party Account Information, we will only do so for the purposes of fulfilling our obligations to you under these Terms. We will not request sensitive payment data relating to the accounts to which the Third-Party Account Information relates.

We might be required by law or regulation to present you with a security challenge before Cleo is able to access or process Third-Party Account Information. Where we do so, you acknowledge and agree that Cleo’s processing of any such Third-Party Account Information is dependent upon you successfully completing any such security challenge in the manner required by us or neither we or Cleo will be able to so process any such Third-Party Account Information and we shall not be liable to you for not doing so.

We will not review the Third-Party Account Information for accuracy, legality or non-infringement, we are not responsible for your Third-Party Account Information or products and services offered by or on third-party sites.

You acknowledge that any Third-Party Account Information that is displayed through Cleo will be the information we most recently accessed, and that this information may not reflect pending transactions or other recent activity.

3.5.  Is there anything you can’t do with Cleo?

You must not and must not permit or allow any other person to:

●        provide us with false, inaccurate, or misleading information,

●        use Cleo in breach of applicable law or regulations,

●        take any action that might impose an unreasonable or disproportionately large load on Cleo or our Site, such as by flooding our network with large amounts of traffic, exploiting any weaknesses in our network protocols, or targeting specific applications to disrupt our services,

●        use Cleo to infringe or misappropriate our, or any other persons’ rights (including intellectual property rights),

●        use Cleo to store, distribute or transmit any material through Cleo that is unlawful, harmful, threatening, defamatory, obscene, is harassing or racially or ethnically offensive, facilitates illegal activity, or promotes discrimination,

●        adapt, translate, arrange, or alter Cleo, reverse engineer, decompile or disassemble Cleo,

●        circumvent or avoid the use of any security device or process designed to protect against unauthorised or unlawful use of Cleo,

●        use Cleo for the benefit of any other person including for, or in connection with, the provision of services which consist in whole or part in the use of Cleo,

●        redistribute, retransmit, or disseminate Cleo, or

●        use Cleo otherwise than in accordance with these Terms.

3.6.  Changes to Cleo

As Cleo is a technology product, you acknowledge and agree that we will make continual improvements to Cleo and that features and functionality we make available to you may change from time to time. If you do not like any change we make to Cleo, you can stop using Cleo and can close your Cleo Account pursuant to clause 6 (Closing your Cleo Account) below.

3.7.  Our use of subcontractors

We rely on our partners and service providers to make Cleo available to you in accordance with these Terms. Where we do so, we will remain responsible and liable to you for the actions or omissions of any such service provider where we rely on them to perform our obligations to you under these Terms. Our Privacy Policy (see clause 11 (How we use your information) below) sets out further information on our partners and service providers who help us make Cleo available to you. For the avoidance of doubt, providers of Third-Party Account Information are not our subcontractors.

3.8.  How do you get help with using Cleo or your Cleo Account?

You can contact us for help by using the in-chat app using the functionality of Cleo, or at team@meetcleo.com.

4.     Getting started

4.1.  Registration

To use Cleo, you must first register to set up a Cleo account (a “Cleo Account”) with us by completing the account registration form available on our Site. You only need to register once. Registration is subject to approval by us in all cases, and we reserve the right, in our sole and absolute discretion, to decline any registration request, without giving a reason but we would usually do this if you don’t pass our eligibility criteria, our compliance checks, or we are prevented by applicable law or regulations from providing services to you.

If we approve your registration, you will receive a notification from us which we will send to the details you gave us in your account registration form confirming that your Cleo Account is active and that you are able to use Cleo subject to these Terms.

4.2.  Eligibility

To be eligible to use Cleo, and to set up a Cleo Account you must be:

●        a legal resident of the United Kingdom,

●        of legal age to form a binding agreement with us (18+), and

●        not prohibited by law or regulations from using Cleo.

It is your responsibility to ensure you satisfy all of the minimum eligibility criteria set out above before choosing to register with us.  By submitting an account registration form to create a Cleo Account with us, you confirm to us that you do meet all of the minimum eligibility criteria.

Please note that additional eligibility criteria may apply to certain services offered through our Site, which will be set out in the terms relating to those services and may be displayed on our Site. 

4.3.  Accuracy of Information

You agree to provide us with accurate, complete, and up-to-date contact information, which may include email address and mobile telephone number.  You are responsible for the information you provide to us and keeping such information up to date. 

You must promptly update your Cleo Account in the event of any changes to information you have provided. If you are having difficulty updating your information, you can email us at team@meetcleo.com to request support.

4.4.  Verification of Information

You authorise us to make (including through third party service providers) any inquiries we consider necessary to verify your identity and information you provide to us. 

This may include:

●        screening you against third-party databases or other sources,

●        requesting reports from service providers,

●        asking you to provide a form of government identification (e.g., driver’s license or passport) to check your name, place and date of birth, your address, nationality and any other information which we deem necessary under applicable laws, or

●        requiring you to take steps to confirm ownership of your email address. 

We reserve the right to terminate, suspend, or limit access to Cleo in the event we are unable to obtain or verify any of this information.

4.5.  Cleo Account security

You must take all reasonable precautions to keep the access credentials (such as your username and password) that you use to access your Cleo Account (your “Access Credentials”) confidential and secure at all times.

You must contact us immediately if you discover or suspect any unauthorised use of your Cleo Account, or error in the operation of your Access Credentials.  If you discover or suspect any unauthorised use of a payment or financial account linked to your Cleo Account, you should immediately notify the provider of that account.

We may, from time to time, with or without prior notice, temporarily suspend the operation of or access to Cleo, including by suspending access to your Cleo Account, if we believe there has been unauthorised access to your Cleo Account or we suspect it is being used for illicit or improper purposes.

If you or we suspect that your Cleo Account or your Access Credentials have been used by someone other than you or otherwise in breach of these Terms, you must cooperate with us, our agents, and any regulatory authority or law enforcement agency.

5.     Communications

You will receive disclosures, notices, statements, and any other communications about us and Cleo from us electronically (“Communications”) from time to time. You hereby consent to receive Communications electronically.  

You understand that, in order to view and retain copies of the Communications, you will need:

●          a mobile device that meets at least the Minimum Device Requirements;

●          a valid email address and sufficient storage space to save Communications on your device or the capability to print the Communications from the device on which you view them.

You agree that we have no obligation to provide you Communications in paper format, although we reserve the right to do so at any time.  You can request that specific electronic records be provided in writing by contacting team@meetcleo.com.

If we need to contact you about any actual or suspected fraud or security threats, we'll do this using the fastest and most secure way of contacting you (for example, we may try to send you a text message rather than calling you), using the most recent contact details we have for you which are stored in your Cleo Account (which may be updated by us if we receive information that they have changed or are incorrect).

It is important to note that we will never contact you to ask you for your bank account information, transaction details, or to ask you for any security information relating to your bank account, we will only ever access Third-Party Account Information directly from the provider of your account.

6.     Fees and charges

As you are signing up to our free-to-use version of Cleo, there will be no charge to you for your access to and use of Cleo pursuant to these Terms. As set out above, we may offer paid-for versions of Cleo from time to time but if you wish to use any such other version of Cleo you will need to enter into a separate agreement with us relating to such access and use. We will not make features or functionality of any paid-for version of Cleo available to our free tier users.

7.     Closing your Cleo Account

These Terms have no fixed duration and will continue until you or we close your Cleo Account in accordance with these Terms.

You can close your Cleo Account at any time for any reason, using Cleo’s functionality. If you are having difficulty closing your Cleo Account, you can contact us at team@meetcleo.com and we will close your Cleo Account for you within thirty (30) days after we receive your request (according to our records) and will let you know when we have done so.

We can close your Cleo Account by giving you at least fourteen (14) days’ written notice, but we may close your Cleo Account immediately by giving notice to you if:

●          you breach these Terms in a material way, or persistently breach them,

●          you give us false or misleading information,

●          steps are taken to make you bankrupt or make you the subject of any form of debt relief process,

●          we reasonably consider that by continuing to provide you with access to Cleo and to your Cleo Account we might:

o   breach applicable law, regulation, the requirements imposed on us by any governmental or regulatory body or any other obligation we may have, or

o   face action or sanctions from a governmental body, law enforcement agency, or regulator,

●          you become incapacitated or die,

●          you behave in a threatening or abusive way to our staff, or

●          we have reasonable grounds to believe that you are unable or unwilling to pay your debts when due.

8.     When can we suspend access to your Cleo Account?

We may suspend your right to access and use your Cleo Account (including your access to and use some or all of the features and functionality of Cleo) if:

●          you breach these Terms in a material way,

●          our access to Third-Party Account Information is withdrawn or suspended,

●          we reasonably believe that it is necessary or desirable to do so for legal, regulatory or security reasons, or to protect our business. This might happen, for example, if we believe that your Cleo Account has been compromised, or that someone else is making (or attempting to make) requests on your behalf,

●          you are subject to any sort of bankruptcy process, or

●          if we have other serious grounds or valid reasons for doing so including for example, legal or regulatory reasons or suspected misuse of our services or Cleo or suspected fraudulent or criminal activity.

We cannot be responsible for any losses you might suffer if we suspend or revoke your right to access or use of your Cleo Account pursuant to this clause 8 unless this has arisen as a result of our negligence.

We'll normally notify you before we suspend your Cleo Account or immediately afterwards and, where possible, we will provide you with the reasons for the suspension.

If your Cleo Account is suspended and the reason we suspended your Cleo Account no longer applies, we will normally allow you to carry on using your Cleo Account. You can tell us that this is the case and request reinstatement by contacting team@meetcleo.com. If we don’t agree that the reason for suspension no longer applies, or there are other reasons for your Cleo Account to remain suspended, we will normally tell you this in response to your request to reinstate your Cleo Account.

9.     What happens if your Cleo Account is closed?

When your Cleo Account is closed (either by us or you):

●          all rights granted to you under these Terms will immediately cease,

●          your right to access and use Cleo will end immediately,

●          we will stop accessing Third-Party Account Information relating to you,

●          we will delete any personal data relating to you which is in our possession or control in accordance with our Privacy Policy (see clause 11 (How we use your information) below), and

●          we will keep any data and information which we are required by applicable law, regulation, or the requirements of any regulator to keep.

Any closure of your Cleo Account shall be without prejudice to any rights that have accrued to either party.

10.  What we are not responsible for

We shall have no responsibility to you and shall not be liable to you for any failure to provide, or any delay in providing, or suspending your Cleo Account in accordance with these Terms to the extent that such failure, delay or suspension results from:

●          your failure to comply with your obligations under these Terms, or to provide us with accurate information or updates as reasonably required or requested by us,

●          you providing us with incorrect instructions, or

●          a pending investigation into any specific activity on your Cleo Account.

If we breach these Terms, we won't be liable to you for losses and costs caused by abnormal or unforeseeable events, that we cannot reasonably control and which would have been unavoidable despite all reasonable efforts to prevent the event happening.

11.  How we use your data and information

We will process any personal information relating to you which you provide to us or which we otherwise hold in accordance with our Privacy Policy which can be accessed on our Privacy Policy page.

For the purposes of the UK’s Payment Services Regulations 2017, you explicitly consent to us accessing, processing, and retaining any information you provide to us, for the purposes of providing account information services to you via the functionality in the Cleo App. This does not affect any rights and obligations you or we have under data protection legislation. You may withdraw this consent by telling us to close your account. If you do this, we'll stop using your data for this purpose but may continue to process your data for other purposes in accordance with these Terms and our Privacy Policy.

We will endeavour to keep data and information you provide or make available to us confidential, but you acknowledge and agree that we can disclose such data and information where we are required to do so by applicable law, regulations, or the requirements of any governmental authority or regulator (including the FCA).

You agree that we can also use data and information you provide to us or process using Cleo (including Third-Party Account Information) to:

●        aggregate that data and information relating to use of Cleo by other customers on an anonymised basis,

●        analyse use of Cleo and prepare documents and reports relating to the use of Cleo, and

●        disclose and otherwise exploit the documents and reports referred to above, but we will not do so in a way which discloses your identity,

this does not affect any rights and obligations you or we have under data protection legislation relating to personal information (please see our Privacy Policy for further information on how we use personal information you provide to us or process using Cleo).

12.  Ownership of Cleo and the Site

We or our licensors own Cleo and our Site, including any and all rights (including intellectual property rights), title, and interest in and to Cleo and our Site. 

We only grant you the right to use Cleo and your Cleo Account in accordance with these Terms, we do not give you any additional rights such that nothing in these Terms gives you any ownership rights in relation to Cleo or our Site. We and our licensors reserve all rights (including intellectual property rights), title, and interest in and to Cleo and the Site. 

13.  Changes to these Terms

We can change these Terms for any of the following reasons:

●        where the costs to us of providing access to Cleo to you change or we have a good reason to expect that they will change,

●        where the change is either good for you (including where we're making the change to improve the security of your account or we're making these Terms clearer or fairer) or neutral,

●        to reflect changes or developments in the technology or systems which we use, or

●        where we're making the change to reflect a change in law, regulation or industry codes of practice (including where we have a good reason to expect a change), or to reflect a decision by a court, regulator or the Financial Ombudsman Service (or equivalent).

If we make a change to these terms, we'll give you at least two months’ advance notice of the change, unless we are unable to for a good reason, for example if we are required to make the change quicker for legal or regulatory reasons or where the change is not to your disadvantage. In this case, we'll give you notice but we may make the change more quickly, including on the same day as the change is notified to you. We'll always give you details of when the change will take effect.

If you don't want to accept any change, then you can always end your agreement with us by telling us to close Cleo account (see clause 6 (Closing your Cleo Account) above). If you don't do this, we'll assume you've accepted the change.

14.  Language, governing law, and jurisdiction

These Terms and all communications between us concerning your use of Cleo will be in English.

These Terms shall be governed by and construed in accordance with English law unless you entered into an agreement with us in Scotland or Northern Ireland, in which case the law of that jurisdiction will apply.

You agree that any dispute concerning or relating to these Terms shall be subject to the exclusive jurisdiction of the courts of England and Wales, unless you reside in Scotland or Northern Ireland, in which case you or we may also bring a claim in those jurisdictions.

15.  General

These Terms are the entire understanding and agreement between you and us related to your access to and use of Cleo.  These Terms supersede any previous agreement between us and you relating to your access to and use of Cleo. 

We may (at our election) choose to delay enforcing or choose not to exercise rights under these Terms. If we do this, we do not waive our rights to exercise or enforce them on any other occasion.

You may not sell, assign or transfer your Cleo Account or your rights or obligations under these Terms, in whole or in part, to any other person without our prior, written consent. 

We may assign or transfer any or all of our rights or obligations under these Terms to another person. If we do so, we will provide you at least fourteen (14) days’ written notice of the proposed transfer or assignment. If you object to the assignment or transfer, you can close your Cleo Account in accordance with clause 6 (Closing your Cleo Account) above.

If any provision of these Terms is found to be invalid, unlawful, void, or unenforceable, the relevant provision shall be enforceable to the fullest extent possible, and the remaining provisions of these Terms shall remain in full force and effect.

16.  Contacting us and complaints

Please submit any questions you have about these Terms, or any complaint or concern in relation to Cleo or our Website by email to team@meetcleo.com in the first instance.

If you’re unhappy with the way we deal with any complaint you may have which relates to Cleo, you may be able to refer your complaint to the Financial Ombudsman Service by writing to Financial Ombudsman Service, Exchange Tower, London E14 9SR, calling 0800 023 4567 or 0300 123 9123 or by sending an email to complaint.info@financial-ombudsman.org.uk.

You can find out more about the Financial Ombudsman Service on their website at www.financial-ombudsman.org.uk.