Valnivo Professional

Terms of use for Valnivo Professional

Valnivo Professional · v2 · last updated 2026-09-30 · about this product · the consumer app's own notice

Who you are dealing with

Valnivo Professional is operated from Luxembourg by Valnivo Labs. Valnivo Labs is a trade name, not a registered company. The name of the person responsible is given on request — write to privacy@valnivo.eu — and is given without condition for a formal data-protection request or a complaint to a supervisory authority, so no right of yours depends on it being printed here.

This is weaker than the law wants, and it is said plainly rather than hidden. Art. 13(1)(a) GDPR and the Luxembourg e-commerce law of 14 August 2000 both expect the controller to be named. The same is true of the consumer app's notice, and the real fix in both cases is a legal entity rather than better wording.

No lawyer has reviewed these documents. That is stated because a firm deciding whether to rely on them is entitled to know it.

What is in force today

Valnivo Professional is an early-stage service and there is no charge for it. No price is quoted anywhere, nothing is invoiced, and no payment method is taken — so any clause below about fees describes an arrangement that does not yet exist. If that changes it changes by agreement, in a new version, and never by a figure appearing on a screen.

The processing agreement is the exception, and it is in force. An art. 28 agreement attaches to processing and not to payment: the moment a firm puts a client's figures into this service there has to be one, whether or not anybody is being charged. It is accepted when a firm claims its account, and that acceptance is what executes it.

The terms

1. What this is. A calculation service for organisations. You enter clients in the application, or send cases to the API — figures, a currency, a country and your own reference — and receive projections of where those figures lead under the assumptions you supply. It is arithmetic performed on your instructions. It is not advice, not a forecast, not a suitability assessment, and not a statement about what any person can afford, should do, or is likely to experience.

2. Who may accept these terms. An organisation, through somebody authorised to bind it. Not its users: a person given a seat accepts nothing on their own account and has no contract with us. An individual planning their own money is not the customer for this and should use the consumer app under its own terms, which is free.

3. What you warrant, and what each warranty is doing. These are the clauses that carry the regulatory argument, so each says why it is here:

• (a) Any advice is yours. You warrant that any advice, recommendation or assessment you give the people you plan for is your own, given under your own responsibility, and that you hold whatever authorisation, registration or professional licence your jurisdiction requires for it. We are a tool you use; we are not a participant in what you tell your client.
• (b) You are the controller. You warrant that the figures are lawfully collected under your own basis, and that you have given the people concerned the information art. 14 GDPR requires — including that a third-party tool is used. They never meet us, so that duty can only be yours.
• (c) You will not put identity in a case. No name, e-mail, telephone number, address, date of birth, account number or national identifier, including inside your own reference field. The service refuses the named fields at the boundary; the reference is free text and only you can keep it clean. A blocklist is a floor, not a proof, and this clause is the rest of the measure.
• (d) You will not present a projection as something it is not. The sentence that travels with every figure — an illustration built on the assumptions in the request, not a forecast, not advice — stays with the figure when you put it in front of a client. It may not be removed, overlaid or placed so that it reads as our assessment of that person.
• (e) You will not use the service to hold anybody's identity. The API answers and forgets. The application stores the clients you enter, sealed, with your own reference beside each in the clear — so a client file, a name or any other identifying detail put into a reference, or anywhere else the service would carry it, is a breach of this clause.

4. What we will never do, whatever a contract says. These are not negotiable per customer, because they are what keeps the service outside the perimeter of financial regulation for every customer at once:

• Never say what a person can afford, can borrow, or should do.
• Never name, rank or compare a fund, account, provider or policy.
• Never connect to a bank or fetch anyone's accounts or balances (the one proposal there has ever been was assessed, and it is not approved).
• Never take a referral fee, commission or other consideration for sending anybody anywhere.

A request for any of these is refused rather than priced.

5. The figures. Every projection is an illustration built on the assumptions in your request. Rates of return, inflation and horizons are yours, not ours; the arithmetic is published and testable, and you are expected to satisfy yourself that it suits your purpose before you rely on it. The same calculation runs in the demonstration on the product page, so nothing is hidden.

6. Data protection. The data processing agreement governs any processing of personal data and prevails over these terms wherever the two could be read differently. In outline: for the figures you send, you are the controller and we are your processor; for your own account — your organisation, your contacts, your keys and your usage — we are the controller, and our privacy notice for this product says what that means.

7. Keys and access. A key is issued to an organisation, never to a person, is checked before any arithmetic runs, and is revocable by either of us. We store a hash of it and never the key, so a leak of our records is not a leak of your key. Keeping a key secret, and telling us promptly when it is not, is yours.

8. Where a client's figures are sealed, and what that costs you. A client you enter in the application is stored sealed. The key that opens it is held by your organisation and wrapped for each of your members allowed to open it, and we hold no copy and no escrow. The consequence is yours and is stated rather than buried: if no member of your organisation holds a key, the data is unrecoverable, by you and by us.

9. Availability. No service level, no uptime commitment, and no promise that any endpoint stays at its address. The product is in early access; while it is, it may change or be withdrawn. When a service level exists it will be a schedule to this agreement with numbers in it, and until then the absence is stated rather than implied.

10. Liability. Not yet written. This clause is a placeholder, to be drafted with a lawyer, and it is marked here rather than filled with wording nobody has reviewed. Between businesses Luxembourg law permits far more limitation than the consumer terms may claim, which is precisely why this clause must not be written by the party it would favour. Intent, gross negligence and personal injury are excludable nowhere. Note also that a firm relying on a projection to advise a client is relying on its own assumptions, which bears on what a limitation can fairly cover.

11. Term, suspension and exit. The agreement runs for the period stated in it and does not renew itself. We may suspend for a breach of clause 3 or 4, on notice and with a chance to put it right. At the end, and at any time before it: every client you hold is deletable on its own, not only in bulk, and a handover document can be written for any one of them, because your own client may ask you for exactly one of them and you have a month to answer. Your retention may be longer than ours would be — a regulated firm may have to keep records for five years — so the period is a term to agree with you, not a default we impose.

12. Price. There is no charge for it today. That is how things stand rather than a right these terms give you: it may change, and nothing here promises that it will not. Nothing is charged without an explicit purchase. When it is charged: a stated price, an invoice from the provider in clause 0, and VAT handled as reverse charge for EU business customers. This is B2B only; nothing here is offered to a consumer, which is the second reason the consumer terms are not the right instrument.

13. How this fits the white-label licence. The white-label licence licenses the widgets to be embedded on somebody's own site under their own name, and states that it and this document "should share one set of professional terms rather than growing two that drift". Settled here: they are one base and one schedule. Clauses 3(a), 3(d), 4, 5 and 10 above are the base and govern both — the advice boundary is a property of the product and not of the contract it arrived under. The white-label document keeps only what is specific to a licence: what is licensed, the mark, the term, and what happens when it lapses. Any change to the advice boundary is made here, once.

14. Law and forum. Luxembourg law. Forum to be settled with clause 10.

0. The provider. Valnivo Labs, based in Luxembourg. Valnivo Labs is a trade name, not a registered company. The name of the person responsible is given on request, and without condition for a formal data-protection request or a complaint to a supervisory authority, as the head of this document says. Every clause above depends on this line.

What these terms deliberately do not contain

• No indemnity from the customer to us. It would be normal in a B2B contract and it is left out until a lawyer says what it should say; an indemnity drafted by the party it protects is the clause a court reads hardest.
• No audit right for us over the customer. We have no interest in inspecting a firm's book, and a right to do so would sit oddly beside a design whose whole claim is that we cannot read it.
• No storage of results. The design refuses it by name, so there is no clause about retention of output — there is no output kept to retain.
• No sub-licensing, resale or white-labelling of this service. That is the other document.

What changed in this version

© 2026 Valnivo · offered from Luxembourg to firms in the European Economic Area. Enquiries: contact@valnivo.eu