Terms and Conditions of Service

1. Acceptance of the Terms and Conditions of Use

This app, Ciento (the "Service"), is a technology platform that enables you, the user, to manage personal finances through manual data entry, access financial insights, and utilize artificial intelligence features via our mobile application, website, and conversational interfaces (e.g., WhatsApp, Telegram).

These terms and conditions of use constitute a legal agreement and are entered into by and between you ("User," "you") and Ciento Labs Inc. ("Company," "we," "us," "our"), a company incorporated in Canada with its head office in Vancouver, British Columbia.

The following terms and conditions, together with any documents and/or additional terms they expressly incorporate by reference (collectively, these "Terms and Conditions"), govern your access to and use of the Service.

2. Eligibility and Age Restriction

The Service is strictly intended for individuals who have reached the age of majority in their jurisdiction of residence.

• Spain and the European Union: You represent and warrant that you are at least 18 years of age.
• British Columbia Residents: You represent and warrant that you are at least 19 years of age.
• Other Jurisdictions: You represent and warrant that you are of the legal age of majority under applicable law to form a binding contract with the Company.

If you do not meet these requirements, you must not access or use the Service. We reserve the right to terminate any account found to be used by a minor.

3. Modifications to the Terms and Conditions

We reserve the right to revise and update these Terms and Conditions.

• Standard Changes (15 Days Notice): For material changes that affect your rights or obligations (e.g., price increases, changes to data handling), we will provide you with at least fifteen (15) days' advance notice via email, a prominent notice in the App, or a chat notification.
• Urgent Updates (1 Day/Immediate): For changes required to address immediate security threats, legal compliance requirements, or the addition of new features that do not materially reduce your rights, we may provide notice of one (1) day or make the changes effective immediately upon posting.

Your continued use of the Service after such changes constitutes your acceptance of the new Terms. If you are a consumer in the EEA and you do not accept a material change, you may terminate your subscription before it takes effect, and we will refund any amount you have paid for a period after termination.

4. Service Description and Manual Data Entry

• 4.1 No Direct Bank Connections: You acknowledge that Ciento is a standalone financial management tool. We do not directly connect to, scrape, or access your bank accounts, investment accounts, or financial institution portals.
• 4.2 User Responsibility: All financial data (expenses, incomes, budgets, balances) is manually input by you or sent by you to our AI via chat. You are solely responsible for the accuracy, completeness, and currency of the data you provide. The Company is not responsible for any financial decisions made based on inaccurate data you have entered.

5. Beta Services and Pre-Release Features

• 5.1 Beta Access: We may designate certain parts of the Service as "Beta," "Early Access," or "Pre-Release" ("Beta Services"). You acknowledge that Beta Services are under development, may contain bugs or errors, and may be incomplete or subject to change without notice.
• 5.2 No Warranty for Beta: TO THE FULLEST EXTENT PERMITTED BY LAW, BETA SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND. WE SPECIFICALLY DISCLAIM ANY LIABILITY FOR DATA LOSS, SERVICE INTERRUPTIONS, OR INACCURATE AI RESPONSES OCCURRING DURING THE USE OF BETA SERVICES. This does not limit the statutory rights described in section 14.
• 5.3 Feedback: If you provide feedback regarding the Beta Services, you grant Ciento Labs Inc. a perpetual, irrevocable, royalty-free license to use such feedback for any purpose, including product improvement.

6. Your Use of the Service and Security

• 6.1 Account Security: You are responsible for maintaining the confidentiality of your account credentials and your WhatsApp/Telegram device access. You must exercise caution when accessing your account from a public or shared computer.
• 6.2 Prohibited Data: You must not send the following to the Service or to our AI, in any channel:
• Full credit card numbers (PANs)
• Bank account passwords or PINs
• CVV/CVC codes
• Government identification numbers (e.g., DNI, NIE, NIF, SIN, SSN)

We reserve the right to block or ban users who repeatedly transmit sensitive credentials via unencrypted chat channels.

7. Artificial Intelligence (AI) Disclaimer

Our Service utilizes artificial intelligence (including third-party models like Google Gemini) to process your queries and generate financial insights. By using the Service, you understand and agree that:

• No Financial Advice: The content generated by our AI is for informational and illustrative purposes only. It does not constitute financial, investment, tax, legal, or professional advice, and it is not a regulated financial advisory service in Spain or elsewhere in the EU.
• Potential for Error (Hallucinations): AI models can make mistakes ("hallucinations"). The AI may misinterpret your inputs or provide mathematically incorrect summaries. You should always verify important financial figures against your actual bank statements.
• No Reliance: You must obtain specific or professional advice from a qualified advisor before taking, or refraining from, any action on the basis of the content on our Service. The Company has no responsibility or liability whatsoever for any financial decisions you make based on AI-generated content.

8. Subscriptions, Prices, and Payments

• 8.1 Plans and Prices: Ciento offers a free plan and a paid Premium plan. Premium is 3,99 € per month or 39,99 € per year for users billed in euros, and CAD 5.99 per month or CAD 49.99 per year for users billed in Canadian dollars. Prices shown to consumers in Spain and the rest of the EU include VAT where applicable. The price applicable to you is the one displayed in the App Store or Google Play at the moment of purchase, in your local currency.
• 8.2 Billing: Subscriptions are sold and billed through the Apple App Store or Google Play under their terms and privacy policies. Where we offer payment on the web, we use a third-party processor such as Stripe. We never receive or store your payment card details.
• 8.3 Automatic Renewal: Your Subscription renews automatically for successive periods unless cancelled at least 24 hours before the end of the current period. You may cancel at any time in your Apple App Store or Google Play subscription settings. Cancellation stops the next renewal; it does not shorten the period you have already paid for.
• 8.4 Price Changes: We will give you at least fifteen (15) days' notice before a price increase takes effect for your subscription, and you may cancel before it applies.
• 8.5 Refunds: Outside the cases described in section 9 and any other rights granted by mandatory law, payments are non-refundable and there are no credits for partially used periods. Because purchases are processed by Apple and Google, refund requests are handled through their respective stores.

9. Right of Withdrawal for Consumers in the EU

If you are a consumer resident in the European Union, you have the right to withdraw from a purchase within fourteen (14) calendar days of the contract date, without giving any reason, under Directive 2011/83/EU and the Spanish consumer law that implements it (Royal Legislative Decree 1/2007).

• How to exercise it: Because subscriptions are sold by Apple and Google, the fastest route is a refund request in the store you purchased from. You may also notify us at product@cientolabs.com with a clear statement of your decision to withdraw, and we will assist you with the store process.
• Immediate access and loss of the right: Ciento Premium is digital content and a digital service supplied immediately. If you ask us to begin supply during the withdrawal period and acknowledge that you will lose your right of withdrawal once supply has begun, that right ends at that point, as permitted by Article 16(m) of Directive 2011/83/EU.
• Free plan: No withdrawal right applies to the free plan, because no payment is made.

10. Conditions of Use and Prohibited Acts

As a condition of your access and use of the Service, you agree that you may use the Service only for lawful purposes. You warrant and agree that your use of the Service shall not:

• Violate any applicable national, regional, local, or international law.
• Involve sending any material that is exploitive, obscene, harmful, threatening, abusive, or harassing.
• Impersonate the Company, a Company employee, another user, or any other person or entity.
• Restrict or inhibit anyone's use or enjoyment of the Service, or which, as determined by us, may harm the Company or users of the Service.
• Use any robot, spider, or other automatic device to access the Service for any purpose, including monitoring or copying any of the material on the Service.

11. Intellectual Property Rights

The Service and its entire contents, features, and functionality (including but not limited to all information, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof) are owned by the Company, its licensors, or other providers of such material and are protected by copyright, trademark, patent, trade secret, and other intellectual property or proprietary rights laws.

Trademarks: "Ciento", the Ciento logo, and our other marks are trademarks of Ciento Labs Inc. You may not use them without our prior written permission, and nothing in these Terms grants you a licence to do so. Third-party names and marks mentioned in the Service belong to their respective owners.

12. Disclaimer of Warranties

YOU UNDERSTAND AND AGREE THAT YOUR USE OF THE SERVICE, ITS CONTENT, AND ANY SERVICES OR ITEMS FOUND OR ATTAINED THROUGH THE SERVICE IS AT YOUR OWN RISK. THE SERVICE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT ANY WARRANTIES OR CONDITIONS OF ANY KIND, EITHER EXPRESS OR IMPLIED.

NEITHER THE COMPANY NOR ITS DIRECTORS MAKE ANY WARRANTY, REPRESENTATION, OR ENDORSEMENT WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, SUITABILITY, ACCURACY, CURRENCY, OR AVAILABILITY OF THE SERVICE OR ITS CONTENTS (INCLUDING AI-GENERATED CONTENT).

This section does not apply to the extent that it would exclude or limit rights that mandatory consumer law gives you. See section 14.

13. Limitation on Liability

EXCEPT WHERE SUCH EXCLUSIONS ARE PROHIBITED BY LAW, UNDER NO CIRCUMSTANCE WILL THE COMPANY OR ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, CONTRACTORS, LICENSORS, LICENSEES, SUPPLIERS, OR SUCCESSORS BE LIABLE FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE SERVICE, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT, OR OTHERWISE, EVEN IF FORESEEABLE.

Nothing in these Terms excludes or limits our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot lawfully be excluded or limited, including under Spanish and EU consumer law.

14. Consumer Rights in Spain and the EEA

If you are a consumer resident in Spain or elsewhere in the EEA:

• You keep all mandatory rights granted by the law of your country of residence, and nothing in these Terms removes or reduces them.
• Digital content and digital services supplied by us must conform to the contract as required by Directive (EU) 2019/770 and Royal Legislative Decree 1/2007. If they do not, you may require that they be brought into conformity, or obtain a price reduction or termination, in the cases and order provided by that law.
• You may address any complaint to us at product@cientolabs.com. We aim to reply within 30 days. You may also submit your complaint to the consumer authorities of your Autonomous Community or, where both parties agree, to the Spanish consumer arbitration system (Sistema Arbitral de Consumo).

15. Governing Law and Choice of Forum

The Service and these Terms and Conditions are governed by and construed in accordance with the laws of the Province of British Columbia and the federal laws of Canada applicable therein, without giving effect to any choice or conflict of law provision, and any action or proceeding will be instituted in the courts of Vancouver, British Columbia.

Exception for consumers in the EEA: If you are a consumer resident in the European Economic Area, this choice of law does not deprive you of the protection of the mandatory provisions of the law of your country of residence, and you may bring proceedings in the courts of the place where you are domiciled. Nothing in this section restricts your right to do so.

16. Language

These Terms are published in English and Spanish. The Spanish version is provided for users of the Spanish-language site; for consumers resident in Spain, the Spanish version prevails in the event of any discrepancy.

17. Privacy

By submitting your personal information and using our Service, you consent to the collection, use, reproduction, hosting, transmission, and disclosure of such information in compliance with our Privacy Policy.

18. Contact Information

This Service is operated by Ciento Labs Inc., Vancouver, BC, Canada. All feedback, comments, requests for technical support, and other communications relating to the Service should be directed to product@cientolabs.com.