Terms of Service

Terms of Service of NoCFO Oy

15 December 2025

These General Terms of Service (“Agreement” or “Terms”) govern the use of the financial management SaaS service (“Service”) provided by NoCFO Oy (“NoCFO”, Business ID 3149769-7). By using the Service, the Customer agrees to comply with these Terms and to act in accordance with applicable law and good practice. The Terms are accepted upon logging into the Service.

1. Scope of Application

This Agreement applies to the provision of the Service to the Customer. The Agreement enters into force when the Customer begins using the Service. These Terms apply to all features and use of the Service unless otherwise expressly agreed in writing between the parties.

2. Definitions

Customer: The individual or legal entity using the Service.
Service: The accounting and financial management SaaS service developed and maintained by NoCFO.
Company Account: The Customer’s account created upon onboarding to the Service.
User: A person authorized by the Customer to use the Service.
Parties: NoCFO and the Customer.
DPA: The data processing agreement attached to this Agreement.

3. NoCFO’s Rights and Obligations

NoCFO is responsible for providing the Service in accordance with these Terms and may use subcontractors where necessary. NoCFO has the right to modify the content and features of the Service without prior notice and to continuously develop the Service, including making technical or functional changes.

The Service may be subject to interruptions or changes due to development or maintenance. NoCFO shall not be liable for damages caused to the Customer as a result thereof but will, where reasonably possible, notify the Customer of significant service interruptions in advance.

NoCFO may restrict or suspend the Customer’s access to the Service if the Customer endangers the Service’s operation, security, technical reliability, lawful use, or development, or materially breaches its contractual obligations, including failure to pay fees, or otherwise intentionally or unintentionally compromises the Service.

In connection with the use of the Service, NoCFO’s experts may provide guidance on using the Service and on financial management matters. The Customer is solely responsible for any actions taken based on such guidance, whether within or outside the Service. NoCFO does not guarantee the accuracy of any guidance or advice.

NoCFO has the right to process data stored in the Service, including receipts, vouchers, invoices, bank statements, banking transactions, customer registers, and other financial data, for the purposes of analyzing, developing, automating, and improving the quality of the Service.

Such processing is based on this Agreement, NoCFO’s legitimate interest in developing and maintaining the Service, and the DPA, which governs all processing of personal data on behalf of the Customer.

NoCFO may discontinue the Service by notifying the Customer at least three (3) months in advance.

4. Customer’s Rights and Obligations

The Customer has the right to use the Service in accordance with these Terms. The Customer shall familiarize itself with the Terms prior to using the Service and ensure that use complies with applicable law and good practice.

The Customer is responsible for:

  • The accuracy and timeliness of all data entered into the Service
  • Managing and securing user access rights
  • All actions taken using the Company Account credentials
  • The functionality and security of its own devices and network connections

With respect to personal data stored in the Service, the Customer acts as the data controller and NoCFO as the data processor. Processing is governed by the DPA. The Customer is responsible for ensuring that all stored content complies with applicable law and does not infringe third-party rights.

The Customer shall notify NoCFO without undue delay of any errors detected in the Service.

The Customer may use third-party services integrated into or offered through the Service, such as payment services, e-invoicing services, or external APIs. By using such services, the Customer accepts the applicable third-party terms and is responsible for complying with them. NoCFO is not responsible for the content, operation, or availability of third-party services.

5. Pricing and Payment Terms

Current prices and payment methods are available on NoCFO’s website. NoCFO may amend pricing without separate consent. Fees are charged in advance or in arrears depending on the selected service plan. The minimum monthly billing amount is EUR 10; lower amounts are invoiced quarterly.

All prices are subject to applicable value-added tax (VAT). Late payment interest is charged in accordance with the Finnish Interest Act. Invoice payment terms are fourteen (14) days from the invoice date.

NoCFO does not provide refunds for partial billing periods, unused service time, or retroactive cancellations unless mandatory law requires otherwise.

Third-party payment service providers may be used for payment processing.

6. Intellectual Property Rights

All intellectual property rights related to the Service and all associated materials, software, interfaces, databases, templates, documentation, and content belong exclusively to NoCFO or its licensors. No rights are transferred to the Customer other than a limited right to use the Service in accordance with these Terms.

The Customer may not copy, modify, reproduce, sell, rent, sublicense, transfer, publish, translate, reverse engineer, decompile, or otherwise attempt to derive the source code of the Service, except where expressly permitted by mandatory law.

7. Confidentiality

Confidential Information means all information marked as confidential or which should reasonably be understood as confidential due to its nature or circumstances. This includes, without limitation, information relating to software, products, services, technology, or the Customer, as well as other proprietary or sensitive information.

Each Party shall keep Confidential Information received under this Agreement confidential and shall not disclose it to third parties or use it for purposes other than those permitted under this Agreement without prior written consent from the other Party.

Each Party shall ensure that its employees and representatives comply with this confidentiality obligation.

Unless otherwise agreed, all Confidential Information remains the property of the original owner.

Confidential Information does not include information that was lawfully in the recipient’s possession prior to acceptance of this Agreement, is publicly available, or was lawfully obtained from a third party without confidentiality obligations.

This confidentiality obligation does not restrict NoCFO’s right to process Customer data stored in the Service to the extent permitted by this Agreement and the DPA for providing, maintaining, analyzing, developing, and automating the Service.

8. Liability and Limitation of Liability

NoCFO is not liable for damages caused by third-party services or by the Customer’s own actions. The Service is provided “as is.” NoCFO is not liable for indirect or consequential damages, including loss of profit, incorrect information, or data loss, unless mandatory law provides otherwise.

NoCFO’s total liability is limited to an amount equal to three (3) months of service fees paid by the Customer, excluding VAT.

9. Term and Termination

This Agreement is valid until further notice. The notice period for termination is one (1) month, and fees are charged until the end of the notice period. After termination, Customer data stored in the Service will be deleted after three (3) months unless retention is required by law.

10. Governing Law and Disputes

This Agreement is governed by the laws of Finland. Any disputes shall be resolved in the competent courts of Finland.

11. Force Majeure

Force majeure means an event beyond a Party’s reasonable control that prevents or materially hinders performance and could not reasonably have been foreseen or avoided. Such events include, but are not limited to, war, natural disasters, fire, pandemics, large-scale network, telecommunications, or power outages, government orders, or similar exceptional events.

If NoCFO is prevented from performing its obligations due to force majeure, it shall be released from liability for the duration of the event. NoCFO shall notify the Customer of the force majeure event and its estimated duration as soon as reasonably possible.

If the force majeure event continues for more than three (3) months, the Customer may terminate the Agreement with immediate effect by written notice.

12. Personal Data Processing and Data Protection

Each Party shall comply with applicable data protection laws. NoCFO acts as a data controller for its own customer and user data in accordance with its privacy notice available on its website.

The Customer acts as the data controller for personal data stored in the Service, and NoCFO acts as the data processor. Processing is governed by the DPA, which defines the Parties’ rights and obligations.

NoCFO may process personal data stored by the Customer in accordance with this Agreement and the DPA for providing, maintaining, analyzing, developing, and automating the Service. NoCFO does not process personal data for marketing purposes without the data subject’s explicit consent.

13. Amendments

NoCFO may amend these Terms by notifying the Customer via the Service or its website. Continued use of the Service after the effective date constitutes acceptance. If the Customer does not accept the changes, either Party may terminate the Agreement.

14. Limitation Period for Claims

Any claims arising from this Agreement must be brought within six (6) months from the date on which the grounds for the claim arose.

15. Assignment

The Customer may not assign this Agreement without NoCFO’s prior written consent. NoCFO may assign the Agreement to a third party.

Appendix 1: Data Processing Agreement (DPA)

This appendix forms part of the General Terms of Service of NoCFO and governs the processing of personal data between the Customer (data controller) and NoCFO Oy (data processor).

1. Subject Matter and Nature of Processing

NoCFO processes personal data on behalf of the Customer for providing, maintaining, developing, analyzing, and automating the Service. Processing includes technical handling of financial documents and data stored in the Service.

2. Categories of Personal Data

Processed data may include:

  • Names, contact details, and addresses of the Customer’s customers, employees, partners, or other data subjects
  • Billing, bank account, and payment information
  • Receipts, vouchers, bank statements, transaction data, and other financial materials
  • Any other data entered into the Service

The Customer is responsible for ensuring lawful collection and transfer of the data.

3. Processor Obligations

NoCFO shall process personal data:

  • In accordance with applicable data protection laws
  • Solely in accordance with this Agreement and this appendix
  • Only in accordance with the Customer’s documented instructions

NoCFO ensures that persons processing personal data are bound by confidentiality obligations.

NoCFO shall not grant authorities access to data without a lawful order.

NoCFO shall notify the Customer without undue delay of personal data breaches.

Upon request, NoCFO shall provide reasonable information regarding the Service’s security measures. The Customer has no right to conduct physical audits without NoCFO’s prior written consent.

4. Processing for Service Development

NoCFO may process Customer data, including financial materials, to analyze, develop, automate, and improve the Service. This may include technical analysis, classification, modeling, machine learning training, error detection, and performance optimization.

Such processing does not include marketing use or disclosure to third parties beyond what is necessary to provide the Service.

5. Subprocessors and Data Transfers

NoCFO may use authorized subprocessors. Data may be transferred outside the EU/EEA where necessary, provided appropriate safeguards are in place (e.g. standard contractual clauses or the EU–US Data Privacy Framework).

6. Controller Obligations

The Customer is responsible for ensuring lawful processing, data accuracy, fulfillment of information obligations, and regulatory notifications.

7. Data Security

NoCFO implements appropriate technical and organizational security measures, which are regularly reviewed.

8. Data Deletion or Return

Customer data is deleted three (3) months after termination unless longer retention is required by law. The Customer is responsible for retaining legally required records.

This appendix remains in force for the duration of the Agreement.

Appendix 2 – Payment Functionality and Third-Party Payment Services

This appendix applies solely to payment functionality within the Service and prevails in case of conflict.

1. Nature of the Payment Functionality

NoCFO provides a technical solution enabling the Customer to initiate payments via licensed third-party payment service providers. NoCFO is not a payment service provider, payment institution, or subject to AML reporting obligations and does not hold or process funds.

2. Third Parties and Payment Execution

Payments are executed under agreements between the Customer and its bank or payment service provider. NoCFO is not responsible for payment execution, delays, failures, or third-party services. The Customer must verify payment status with its bank.

2.1 Salt Edge

Payment initiation may be provided via Salt Edge Limited and its licensed payment institution partner. NoCFO is not responsible for their services or availability.

2.2 Holvi Integration

Payments may also be initiated from a Holvi account via integration with Holvi Payment Services Oy. Payments are governed by the agreement between Holvi and the account holder. NoCFO acts solely as a technical intermediary.

All payments initiated via NoCFO are deemed initiated by the Holvi account holder. The account holder is fully responsible for user access rights and all payments made thereunder.

3. Payment Data, Consent, and Irrevocability

The Customer is responsible for the accuracy and legality of payment data. Payments are initiated only after explicit consent and acceptance of third-party terms (e.g. Salt Edge). Payments cannot be cancelled via NoCFO once approved.

4. AML and Compliance

The Customer is responsible for compliance with AML and related obligations. NoCFO does not perform customer identification, transaction monitoring, or AML reporting.

NoCFO may suspend payment functionality if misuse or legal non-compliance is suspected or required by a third-party provider.

5. Limitation of Liability

NoCFO is not liable for indirect damages. Total liability related to payment functionality is limited to service fees paid to NoCFO during the preceding three (3) months, unless mandatory law requires otherwise.

6. Suspension of the Service

NoCFO may suspend payment functionality without compensation if third-party services are unavailable, regulation changes, security risks arise, or continuation is not reasonably possible.

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