Terms & Conditions

1. About HeadStart Docs and these Terms

1.1 These terms and conditions (Terms) govern your access to and use of the website operated by HeadStart Docs Pty Ltd (ABN 12 691 347 823) (HeadStart Docs, we, us, our) and your access, download and use of any compliance documents, courses, tools or other materials made available through this website (Site), whether provided at no charge or for a fee.

1.2 By accessing the Site, creating an account, downloading any materials or using any products, you agree to be bound by these Terms. If you do not agree, you must not use the Site or access our products.

1.3 We may update these Terms from time to time by publishing the updated version on the Site. Your continued use of the Site after changes take effect constitutes your acceptance of the updated Terms.

1.4 The Site may provide referrals to HeadStart Counsel (the trading name of Astris Law Pty Ltd), a related incorporated legal practice with the same director and beneficial owner as HeadStart Docs. The beneficial owner has a financial interest in both businesses (see section 6 for full disclosure). HeadStart Counsel is a separate corporate entity from HeadStart Docs. Any services provided by HeadStart Counsel are subject to separate engagement terms and are not governed by these Terms. You are free to engage any legal practitioner of your choice.

2. Nature of Products (No Legal Advice)

2.1 HeadStart Docs is a private digital publisher. We are not a law practice and we do not provide legal advice, legal services or representation. Use of the Site or access to any Product does not create a solicitor–client relationship between you and HeadStart Docs, or between you and any related law practice.

2.2 We publish and make available digital templates, checklists, tools, training materials and courses (Products), including (without limitation) AML / CTF program documents, compliance frameworks, CPD materials, implementation tools, software portals (such as the AML Portal) and verification or screening services (such as HeadStart Search and HeadStart Verify). Certain access, including portal access on our free tier and free tools and resources, is provided at no charge. Other Products and services, including AML/CTF program packs, CDD screening and verification, are provided for a fee.

2.3 All Products and content, including all website contents (Material) we provide as general information only. Our Products and Material are not legal advice, not tailored to your circumstances and not ready for use without professional review and customisation. They are not intended to be substitute and do not constitute taking legal advice specific to your circumstances.

2.4 While every care is taken in preparing Products, we make no representation that any Product is fit for your particular purpose. The content is not intended to be comprehensive nor to constitute professional advice.

2.5 You must obtain advice from a qualified legal practitioner in the relevant jurisdiction to implement and tailor any Product. You must not rely on any Product or Materials as a substitute for advice from a qualified legal practitioner.

2.6 Our Products are not suitable for DIY (do-it-yourself) use. They are designed to be reviewed, adapted and settled by a suitably qualified legal practitioner.

2.7 By accessing, downloading or using any Product, you acknowledge and agree that:

(a) you will engage a qualified legal practitioner to review, tailor and finalise the Product to your specific circumstances;

(b) you will not rely on any Product as if it were legal advice; and

(c) you will not implement any Product in your business or practice without appropriate legal review.

2.8 If you are a practising professional adviser (including a law practice, accountant, consultant or compliance provider), you are responsible for ensuring that any use of the Products in your work complies with applicable laws, professional obligations and these Terms.

2.9 We may use artificial intelligence (AI) assisted tools and processes in the research, drafting, development and production of our Products, Site content and Material, including (without limitation) AML/CTF compliance products, training materials and portal features. AI-assisted content is reviewed and curated by our team, but is not a substitute for independent legal advice. You acknowledge that the use of AI-assisted tools does not affect any other term or disclaimer in these Terms.

3. What we do and do not promise about our Products

3.1 What we do promise

When you access a Product from us we promise that:

(a) we will provide access to the digital products described on the Site for that Product (subject to our right to refuse or cancel access, including access by AML / compliance competitors); and

(b) those products will, in all material respects, correspond with the nature and intended use of the Product as described on the Site at the time of access.

3.2 Purpose and intended use of our Products

You acknowledge that:

(a) our Products are designed as general information and a starting point for you to develop AML / CTF compliance documentation with your lawyer and other advisers (as required);

(b) our Products are licensed on a generic basis and are not tailored to your specific business, structure, client base, risk profile or regulatory position;

(c) our Products require a lawyer to review and tailor your AML / CTF program and documents to your specific business circumstances before use;

(d) our Products are not a substitute for legal advice;

(e) our Products do not provide ongoing compliance, monitoring, implementation or review services;

(f) our Products do not provide you, your practice or your clients with AML / CTF compliance coverage – compliance is and remains your responsibility; and

(g) you have not provided us with information about your business or practice (including, for example, your staff numbers, governance documents, other partners you work with, or how you intend to implement your policies and procedures), and we do not take any such matters into account when making Products available.

3.3 What we do not promise (outcomes)

We do not promise or represent that, and you acknowledge that:

(a) any Product, by itself and without further tailoring and advice, is sufficient for your particular business, practice, client, matter, transaction or jurisdiction;

(b) use of a Product will, by itself, ensure that you, your practice or your clients comply with any particular law, regulation, rule, standard or regulator expectation;

(c) using a Product will result in any particular regulatory outcome, approval, audit result, supervision outcome or enforcement outcome;

(d) a Product will continue to be appropriate for you if your circumstances or relevant laws, rules or guidance change; or

(e) any Product is legally reviewed, legally drafted by a qualified legal professional or a substitute for legal advice, or that such advice is included (before, during or after purchase of the Product).

3.4 Your responsibility and reliance

You acknowledge and agree that:

(a) you are solely responsible for assessing whether a Product is appropriate for your intended use, including by obtaining advice from a qualified legal practitioner;

(b) you will not treat any statement on the Site, in marketing material or in a Product as a personal recommendation that the Product is suitable for your specific circumstances; and

(c) other than the limited promises in clause 3.1, you are not relying on our skill or judgment in deciding whether to acquire or use a Product for your particular purposes.

3.4A Software and automation tools

Where our Products include software or automation tools (including the AML Portal and any associated features):

(a) these are provided as tools to assist you in managing your compliance obligations;

(b) you are solely responsible for the configuration, data entry and correct operation of the software;

(c) the accuracy and effectiveness of any output depend entirely on your inputs and settings; and

(d) HeadStart Docs is not responsible for errors or omissions resulting from your configuration or use of these tools.

3.5 Products provided at no charge

3.5.1 Where a Product is provided genuinely at no charge (for example, free tools, free resources and portal access on our free tier), you acknowledge and agree that:

(a) the Product is provided on an "as is" and "as available" basis without any warranty or representation of any kind, express or implied, to the maximum extent permitted by law;

(b) you have paid no consideration for the Product and the Product is not supplied "in trade or commerce" for the purposes of the consumer guarantees under the Australian Consumer Law to the extent that it is provided genuinely at no charge;

(c) we make no representation or warranty that the Product is complete, accurate, current, error-free or fit for any particular purpose;

(d) you assume all risk associated with your use of the Product; and

(e) you will not use any Product provided at no charge without first obtaining independent legal advice from a qualified legal practitioner.

3.5.2 To the maximum extent permitted by law, we exclude all liability (including liability in contract, tort, negligence, under statute or otherwise) arising out of or in connection with any Product provided at no charge, including (without limitation) any loss, damage, cost or expense of any kind arising from your reliance on, use of or inability to use such Product.

3.6 Non-excludable rights

Nothing in this clause 3 limits any rights that may apply under the Australian Consumer Law in respect of Products supplied for consideration.

4. Licence and use of Products

4.1 Definitions for this clause

For the purposes of this clause 4:

(a) Product means any digital template, pack, course, toolkit, checklist or other material supplied by us via the Site.

(b) Retail Product means a Product designated as a retail product, licensed for use by a single business or practice.

(c) Commercial Licence Product means a Product designated as a commercial or partner product, licensed for use with multiple client entities.

(d) Client Entity means a third party client of yours for whom you provide services using a Product.

4.2 Ownership

(a) All intellectual property rights in the Products are owned by us or our licensors.

(b) You obtain no right, title or interest in any Product other than the Licence expressly granted in this clause 4.

4.3 Grant of Retail Licence

(a) Subject to compliance with these Terms (and, where applicable, payment of any fee), we grant you a limited, non exclusive, non transferable licence to use the Retail Product for the internal business purposes of a single business or practice entity (Retail Licence).

(b) Under a Retail Licence you may:

(i) download, store and copy the Retail Product within your organisation; and

(ii) adapt and customise the Retail Product for use in that organisation's own business or practice.

(c) Under a Retail Licence you must not:

(i) use the Retail Product to prepare documents or deliver services for more than one business or practice entity;

(ii) use the Retail Product as the primary basis for services to Client Entities (for example, as part of a consulting or outsourced compliance service); or

(iii) permit related entities, franchisees or group members to use the Retail Product, unless a separate Retail Licence has been purchased for each such entity.

4.3A Edition Eligibility

(a) The Standard Edition is a single-entity retail licence for:

(i) individual practitioners operating as a sole trader;

(ii) sole-director proprietary limited companies; or

(iii) multi-staff businesses with multiple principals, partners, directors or shareholders.

(b) If your business comprises multiple related entities (a reporting group or elective group under s 10A of the AML/CTF Act), you must purchase the Group Edition.

(c) Purchasing a Standard Edition when your business structure requires a Group Edition constitutes a material breach of these Terms and the Licence, entitling us to terminate the Licence and pursue remedies under clause 4.9.

4.4 Grant of Commercial Licence

(a) Where you purchase a Commercial Licence Product, and subject to payment of the applicable fee and compliance with these Terms, we grant you a limited, non exclusive, non transferable licence to use the Commercial Licence Product to provide services to a specified number or class of Client Entities (Commercial Licence).

(b) The scope of the Commercial Licence, including (as applicable):

(i) the maximum number of Client Entities;

(ii) the permitted sector(s) or jurisdiction(s);

(iii) any update rights or support inclusions; and

(iv) any reporting, branding or attribution requirements,

will be as described at the point of purchase or in any commercial licence or partner schedule agreed with you (Commercial Licence Terms).

(c) Under a Commercial Licence you may:

(i) use, adapt and implement the Commercial Licence Product as part of your professional services to permitted Client Entities; and

(ii) create customised versions of the Commercial Licence Product for those Client Entities, subject to the attribution and branding requirements in clause 4.6.

(d) Unless you have purchased a Commercial Licence Product and agreed Commercial Licence Terms with us, you are deemed to hold only a Retail Licence and must not use any Product with multiple Client Entities.

4.5 Licence conditions and restrictions (all Products)

You must not, without our prior written consent:

(a) resell, redistribute, publish, sub licence, white label or otherwise commercially exploit any Product as a stand alone product or toolkit, whether to Client Entities or any other third party;

(b) represent any Product as originating from you or remove, obscure or alter any copyright, trade mark or attribution notices on a Product;

(c) use a Product in any way that is misleading, unlawful, deceptive or inconsistent with these Terms;

(d) reverse engineer, decompile, disassemble or otherwise attempt to derive the underlying structure, methodologies or frameworks of any Product, except to the limited extent permitted by law; or

(e) use automated tools or systems to mass reproduce, scrape or harvest content from any Product or from the Site.

4.6 Branding, attribution and derivative works

(a) Unless we expressly agree in writing, all Products and any materials derived from them must retain:

(i) our copyright notice; and

(ii) any attribution or "powered by HeadStart Docs" wording specified at the time of purchase.

(b) You may create tailored documents and workflows based on a Product for your own business (Retail Licence) or for permitted Client Entities (Commercial Licence), but those tailored documents remain subject to the restrictions in this clause 4 and your licence terms.

(c) Creating tailored documents does not give you any ownership of the underlying frameworks or content contained in the original Product.

4.7 Term and termination of Licence

(a) Each Licence commences on the date of purchase of the relevant Product and continues until terminated in accordance with these Terms or any applicable Commercial Licence Terms.

(b) We may suspend or terminate a Licence immediately by written notice if:

(i) you materially breach these Terms or any Commercial Licence Terms; or

(ii) we reasonably believe you have misused or allowed unauthorised use of a Product.

(c) On termination of a Licence you must:

(i) cease all use of the relevant Product; and

(ii) delete or destroy all copies of the relevant Product in your possession or control, except to the extent you are required by law to retain records.

(d) Termination of a Licence does not affect any accrued rights or obligations as at the date of termination.

4.8 Audit and verification

(a) We may, on reasonable notice, request information and a written statement from you to verify that your use of any Product complies with these Terms and any Commercial Licence Terms, including the number and identity (by code or anonymised identifier) of Client Entities using a Commercial Licence Product.

(b) You must co-operate with any verification request and promptly provide the information we reasonably require.

(c) If an audit or verification reveals material unauthorised use, we may charge additional licence fees and/or suspend or terminate the relevant Licence, in addition to any other rights we may have.

4.9 Remedies and liquidated damages for breach of Licence

(a) You acknowledge that unauthorised use, copying, distribution or sublicensing of a Product is likely to cause loss to us that is difficult to quantify in advance.

(b) Without limiting any other rights or remedies, where we reasonably determine that you have used a Product with a Client Entity that is not authorised under your Licence (for example, a Client Entity that is not covered by a Retail Licence or exceeds the number permitted under a Commercial Licence), you must pay to us, as liquidated damages and not as a penalty, an amount of AUD $10,000 per unauthorised Client Entity per Product.

(c) Without limiting clause 4.9(b), where we reasonably determine that you have otherwise materially breached the Product Licence (for example, by reselling, redistributing, white labelling, publishing or sharing a Product contrary to clause 4.5), you must pay to us, as liquidated damages and not as a penalty, an amount of AUD $20,000 per breach.

(d) The parties agree that the amounts specified in clauses 4.9(b) and 4.9(c) are a genuine pre estimate, as at the date of these Terms, of the loss that we are likely to suffer as a result of the relevant breaches.

(e) Nothing in this clause 4.9 prevents us from seeking:

(i) injunctive or other equitable relief to prevent or restrain unauthorised use, copying or disclosure of any Product; or

(ii) damages or other relief for any loss not reasonably contemplated by the liquidated damages in clauses 4.9(b) and 4.9(c), where permitted by law.

(f) Payment of liquidated damages under this clause does not of itself grant you any additional Licence rights. We may require you to purchase an appropriate Licence, cease unauthorised use and/or delete copies of the relevant Products in addition to paying liquidated damages.

5. Intellectual Property

5.1 All intellectual property rights in the Site and in all Products and Material, including text, templates, checklists, diagrams, presentations, video content, audio recordings, course content and underlying frameworks (HeadStart Docs IP) are owned by us or our licensors.

5.2 Except as expressly permitted by an applicable Licence, you obtain no right, title or interest in any HeadStart Docs IP.

5.3 You must not, without our prior written consent:

(a) reproduce, duplicate, copy, adapt, translate, transmit, publish, upload, distribute or exploit any part of the Site or Site Materials for any commercial purpose;

(b) use automated systems or software (including data scraping, crawling or mining tools) to extract data or information from this Site for commercial use; or

(c) reverse engineer, decompile or disassemble any software or tool available on or through the Site.

5.4 If you provide feedback, suggestions or improvement ideas (Feedback), you grant us a perpetual, irrevocable, worldwide, royalty free licence to use, adapt and commercialise that Feedback without further notice or compensation to you.

5A. Copyright Protection and Enforcement

5A.1 All content on the Site and in our Products, including (without limitation) all text, graphics, logos, images, photographs, audio, video, software, code, documentation, course materials, templates, checklists, frameworks, tools and compilations of data (collectively, Protected Content), is protected by copyright under the Copyright Act 1968 (Cth) and applicable international copyright conventions and treaties.

5A.2 You must not, without our prior written consent:

(a) reproduce, duplicate, copy or store any Protected Content other than as expressly permitted by your Licence;

(b) distribute, publish, transmit, broadcast or make available any Protected Content to any third party;

(c) publicly display or perform any Protected Content;

(d) create derivative works based on any Protected Content; or

(e) otherwise exploit any Protected Content for any purpose not expressly authorised by these Terms or your Licence.

5A.3 You acknowledge that any breach of clause 5 or this clause 5A will cause significant and immediate loss to us that is difficult to quantify in advance. Without limiting any other rights or remedies available to us, you agree to pay to us, as liquidated damages and not as a penalty, the sum of AUD $50,000 for each breach of clause 5 or this clause 5A. The parties agree that this amount is a genuine pre-estimate, as at the date of these Terms, of the minimum loss that we are likely to suffer as a result of any such breach.

5A.4 Payment of liquidated damages under clause 5A.3 does not limit, waive or otherwise affect our right to:

(a) seek and obtain injunctive relief, including interlocutory and final injunctions, to prevent or restrain any breach or threatened breach of clause 5 or this clause 5A;

(b) seek and obtain any other equitable relief available at law or in equity;

(c) recover damages for any loss exceeding the liquidated amount specified in clause 5A.3, where permitted by law; or

(d) exercise any other right or remedy available to us under these Terms, at law or in equity.

5A.5 This clause 5A survives the expiry or termination of these Terms and any Licence granted under them.

6. Optional Lawyer Referral to Astris Law Pty Ltd

6.1 We may, at your request, provide referrals to Astris Law Pty Ltd trading as HeadStart Counsel (Astris Law) or to other law practices for legal review and customisation of our Products.

6.2 Astris Law is a Queensland law practice. Astris Law and HeadStart Docs are related entities with the same director, secretary and beneficial owner, and a close commercial relationship, but trading as separate corporate entities. HeadStart Docs owns the intellectual property in the Products and Material. Astris Law provides legal services under its own legal practice obligations.

6.3 Any legal work performed by Astris Law (or any other law practice to which you are referred) is a separate engagement between you and that law practice. It is subject to:

(a) confirmation of conflicts of interest before acting;

(b) their client onboarding requirements; and

(c) a separate costs agreement or client agreement with that law practice.

6.4 HeadStart Docs does not provide legal services, does not act as your solicitor, and does not assume responsibility for any advice provided by Astris Law or any other law practice. For the avoidance of doubt, no referral fees are exchanged between Astris Law and us, the ultimate beneficial owner of each entity has a financial interest in both businesses and will benefit directly or indirectly from the referral, through increased revenue resulting in increased dividends.

6.5 You are free to engage any legal practitioner of your choice. You are under no obligation to use Astris Law or any other law practice we may refer.

6.6 Any fees for legal services are payable to the law practice you engage. HeadStart Docs may receive service fees or other commercial benefits in connection with referrals, and such arrangements may be disclosed to you as required by law or professional obligations.

6.7 No contact with your legal practitioner

6.7.1 HeadStart Docs does not contact, communicate with, advise, direct or otherwise engage with your nominated legal practitioner or any legal practitioner acting on your behalf, whether identified at checkout, during portal configuration or at any other time.

6.7.2 Where you provide your legal practitioner's name or firm details during checkout or portal setup, that information is recorded solely for the purpose of identifying the reviewing practitioner on your account and maintaining an audit trail of your compliance setup. We do not use that information to contact your practitioner, share your account details with them, or facilitate any communication between us and them.

6.7.3 HeadStart Docs does not monitor, oversee or verify whether your legal practitioner has reviewed your program documents or portal configuration. The relationship between you and your legal practitioner is entirely your own. We are not a party to it, we do not supervise it, and we accept no responsibility for the scope, quality or outcome of any legal review you obtain.

6.7.4 We provide a Lawyer Brief and Configuration Schedule as part of your portal access. These materials are provided to you (not to your practitioner) as a convenience to help you explain the platform to your chosen adviser. You are responsible for delivering those materials to your practitioner if you choose to do so.

6.7.5 For the avoidance of doubt, no solicitor–client relationship, retainer, duty of care or professional obligation of any kind exists between HeadStart Docs (or any of its officers, employees or related entities in their capacity as officers or employees of HeadStart Docs) and your legal practitioner or between HeadStart Docs and you in respect of any legal services.

7. Website Use and Accounts

7.1 You must use the Site in accordance with these Terms and all applicable laws.

7.2 You must not use this site:

(a) for any unlawful purpose or in any way that may damage, disable or impair the Site;

(b) to send or procure the sending of unsolicited or unauthorised advertising, promotional material or spam;

(c) to transmit any data, or upload any material, that contains viruses, trojans, worms, logic bombs, spyware, adware or any other harmful programs or computer code.

(d) to infringe the rights (including intellectual property, privacy or confidentiality rights) of any person;

(e) to attempt to gain unauthorised access to any part of the Site or any related systems;

(f) to attack the Site via a denial-of-service attack or a distributed denial-of-service attack;

(g) to copy our Material and Products to compete with us, in breach of your Licence;

(h) to access, monitor or copy any material or information from the Site using any robot, spider, scraper or other automated means, or any manual process, for any purpose without our express written permission; or

(i) to benchmark, analyse or reverse engineer any part of the Site or AML Portal for the purpose of building or assisting in building a competing or substantially similar product or service.

7.3 If you create an account, you are responsible for:

(a) keeping your login and access details secure;

(b) all activities that occur under your account; and

(c) notifying us promptly of any unauthorised use or security breach.

7.4 We may suspend or cancel your access to the Site or to any Product if we reasonably suspect misuse, breach of these Terms or unlawful conduct.

7.5 We do not warrant that the Site will be secure or free from bugs or viruses and accept no liability for any damage that may result from the transmission of any bugs or viruses via the Site. You are responsible for ensuring that your devices, software and systems are appropriately configured and protected.

8. Pricing and Payment

8.1 Certain access, including portal access on our free tier and free tools and resources, is provided at no charge. Paid Products and services, including AML/CTF program packs, CDD screening and verification, are charged at the rates displayed on the Site.

8.2 All prices displayed on the Site are in Australian Dollars (AUD) and, unless otherwise stated, include GST.

8.3 Payment for paid services must be made by the methods specified on the Site. All transactions are subject to successful payment authorisation.

8.4 We use third-party payment processors. We are not responsible for payment processing errors or charges imposed by your bank or card issuer.

8.5 For commercial licences or partner arrangements, pricing and payment terms may be set out in a separate agreement.

9. Delivery, Access and Updates

9.1 Our Products are delivered digitally, either by download or by granting you access through an online portal or learning management system.

9.2 You are responsible for ensuring that your systems and devices are capable of accessing and using the Products in the formats provided.

9.3 Unless expressly stated otherwise, Products are made available for download or online access for a limited period. We do not guarantee perpetual access to any Product or digital file.

9.4 We may update or revise a Product from time to time. Unless otherwise specified at the time of purchase, your licence does not automatically entitle you to future versions or updates.

9.5 For commercial licence customers, update rights (if any) will be governed by the applicable commercial licence or partner agreement.

9.6 Documents are delivered via email after brief review (maximum 8 hours). We reserve the right to refuse retail licence sales to competitors.

10. Refunds, Credits and Issues with Products

10.1 Free Products and Paid Services

10.1.1 Where Products are provided genuinely at no charge, no refund applies as no payment has been made. Paid Products (including AML/CTF program packs) are subject to clause 10.1.2 and your non-excludable rights under the Australian Consumer Law.

10.1.2 Where you pay for services (including CDD screening, verification services and portal credit top-ups), all payments are final and we do not offer change of mind refunds. CDD credits are consumed upon use and cannot be reversed.

10.1.3 You are encouraged to obtain advice from your own lawyer before using any Product or service.

10.2 Rights That Cannot Be Excluded

10.2.1 Nothing in this clause 10 limits any rights or remedies you may have under the Australian Consumer Law or any other law that cannot lawfully be excluded or limited.

10.3 CDD Screening Charges

10.3.1 CDD screening charges are not refundable on a change-of-mind basis.

10.3.2 If you experience an issue with a CDD screening result (for example, an error or technical fault), you may request a review by contacting support@headstartdocs.com.au with details of the issue. We will review the matter and may, at our discretion, issue a credit or refund.

10.3.3 Nothing in this clause 10.3 limits any rights or remedies you may have under the Australian Consumer Law or any other law that cannot lawfully be excluded or limited.

10.4 Technical Issues (All Products)

10.4.1 If you experience a technical issue downloading, opening or accessing a Product (for example, incorrect link, corrupted file or access failure), you must notify us promptly with details and your order number.

10.4.2 We will take reasonable steps to resolve the issue, which may include reissuing download links, providing replacement files, or supplying the Product in an alternative format.

10.4.3 If we are unable to resolve a technical issue within our control within a reasonable time (e.g., 14 days), we may, at our discretion, issue a credit adjustment or refund the price paid for the affected service, less any non-refundable payment processing fees.

10.5 Commercial Licence Products

10.5.1 Subject to clause 10.2, we do not offer change of mind refunds or other voluntary refunds for Commercial Licence Products.

10.5.2 The only refunds we will ordinarily consider for Commercial Licence Products are:

(a) where we are unable to provide the Commercial Licence Product you purchased or a materially equivalent replacement (e.g., a Product with similar functionality and scope); or

(b) unresolved technical issues under clause 10.4.

10.5.3 If we provide a refund or credit for a Commercial Licence Product, you must immediately cease all use of the Product and confirm that you have deleted all copies from your systems, devices and storage locations, except to the extent you are legally required to retain records. In such circumstances, you agree that you and your agents will cease using the digital products, and will not seek to modify, resell or use such products in any way without our permission, and that doing so is a clear breach of licence terms.

10.6 Situations Not Eligible for Refund

10.6.1 Without limiting clause 10.1, the following do not of themselves qualify for a refund or credit:

(a) change of mind after purchase;

(b) purchasing the wrong Product or sector where the Product was correctly described on the Site;

(c) preferring a different drafting style or approach to the one used in the Product;

(d) deciding not to obtain legal advice after purchase;

(e) general dissatisfaction with a Product where no specific defect or technical issue has been identified; or

(f) refusal or failure to confirm deletion of all copies of the Product when requested as part of any refund or credit process.

10.6.2 The fact that our Products are not suitable for DIY use and must be tailored with legal and other professional advice is not a reason for a refund. This is a feature of our Products that we are transparent and upfront about; it is not a defect.

10.7 Other Issues

10.7.1 If you believe there has been a billing error, duplicate charge, or other unusual circumstance, you should contact us promptly with details. We may, in our absolute discretion, review such cases individually.

11. User Obligations

11.1 You are responsible for:

(a) ensuring that the information you provide to us is true, complete and accurate;

(b) using the Products only in accordance with these Terms and with any instructions, warnings or limitations described in the Product;

(c) obtaining independent legal advice before implementing any Product; and

(d) complying with all laws and professional obligations that apply to your use of the Products and the Site.

11.2 If you use the Products with or on behalf of your clients or customers, you must ensure that:

(a) your engagement terms with them clearly explain your role and responsibilities;

(b) you do not misrepresent any Product as originating from you, unless permitted under a written commercial licence; and

(c) you pass through all mandatory disclaimers and attributions we specify.

12. Warranties and Disclaimers

12.1 To the maximum extent permitted by law, we provide the Site and all Products on an "as is" and "as available" basis, without warranties of any kind.

12.2 Without limiting clause 12.1, we do not warrant that:

(a) any Product is complete, up to date or suitable for your particular circumstances;

(b) the Site or any Product will be uninterrupted, secure or error free; or

(c) any particular outcome will be achieved by using the Site or a Product.

12.3 You are solely responsible for:

(a) assessing whether a Product is appropriate for your needs; and

(b) obtaining legal advice on any Product before implementation.

13. Limitation of Liability

13.1 To the maximum extent permitted by law, we exclude all liability for any loss, damage, cost or expense of any kind (including consequential loss, loss of profits, loss of revenue, loss of data and business interruption) arising out of or in connection with:

(a) your use of, or inability to use, the Site or any Product;

(b) your reliance on any information or Materials contained on this Site;

(c) any errors or omissions in a Product or Material;

(d) your reliance on any Product without appropriate legal review;

(e) the cost of procurement of substitute products or services resulting from any products, services, data or information purchased or obtained through this Site;

(f) unauthorised access to or alteration of your transmissions, data or information contained on your systems or the Site.

13.2 Where a court determines that our liability cannot be excluded, our aggregate liability to you for all claims arising out of or in connection with the Site is limited to the amount actually paid by you (if any) in the 12 months preceding the claim. For Products provided at no charge, our aggregate liability is limited to AUD $1.

13.3 You indemnify us against all loss, damage, costs and expenses (including legal costs on a full indemnity basis) arising from:

(a) your breach of these Terms;

(b) your misuse of any Product; or

(c) any claim by a third party (including your clients) arising from your use of a Product or the Site.

14. Third Party Services and Links

14.1 This Site may contain hyperlinks or references to other websites owned or operated by third parties. These links are provided for your convenience only.

14.2 We have no control over, and accept no responsibility for, the content or availability of any third-party websites. Inclusion of a link does not imply any recommendation, endorsement or association.

14.3 We will not be responsible or liable, directly or indirectly, for any loss, cost, claim, damage, expense or fees (including legal fees) caused or alleged to be caused in connection with the use of, or reliance on, any content, goods or services available on such external websites.

15. Privacy

15.1 We handle personal information in accordance with our Privacy Policy, as updated from time to time and available on the Site.

15.2 By using the Site or purchasing Products, you consent to our collection, use and disclosure of personal information as described in our Privacy Policy.

16. Suspension and Termination

16.1 We may suspend or terminate your access to the Site, any account or any Product if:

(a) you materially breach these Terms;

(b) we reasonably suspect misuse, fraud or unlawful activity; or

(c) we are required to do so by law or a regulator.

16.2 Termination does not affect any rights or obligations that have accrued before the effective date of termination.

16.3 On termination, any Licence granted to you under these Terms will cease, and you must cease using, and delete, all copies of the relevant Products, except to the extent that continued retention is required by law.

17. Changes to Products and the Site

17.1 We may add, remove or modify Products, features or content on the Site at any time without prior notice.

17.2 We are not liable to you for any changes, suspension or discontinuance of any part of the Site or any Product.

18. Governing Law and Jurisdiction

18.1 These Terms are governed by the laws of Queensland, Australia.

18.2 You submit to the exclusive jurisdiction of the courts of Queensland, Australia and any courts that may hear appeals from those courts in respect of any proceedings arising out of or in connection with these Terms, the Site or any Product.

19. General

19.1 If any provision of these Terms is held to be invalid, illegal or unenforceable, that provision is severed, and the remaining Terms will continue in full force.

19.2 No waiver of any breach of these Terms is effective unless in writing and signed by us. A failure or delay to exercise a right, power or remedy does not operate as a waiver.

19.3 These Terms, together with any additional licence or product-specific terms agreed at the time of purchase and our Privacy Policy, constitute the entire agreement between you and us in relation to the Site and Products.

19.4 You must be over 18 to use this Site. It is a breach of these terms if you access this Site if under the age of 18. You and your client must be over the age of 18 to purchase a licence.

20. HeadStart Verify Technology Platform

20.1 Nature of HeadStart Verify Platform

20.1.1 HeadStart Verify is a digital identity collection technology platform provided within the AML Portal.

20.1.2 HeadStart Docs Pty Ltd provides technology infrastructure that enables reporting entities to collect and verify customer identity information. We are a technology provider, not a compliance service.

20.1.3 You (the reporting entity) perform all identity collection and verification using our tools. HeadStart Docs Pty Ltd does not collect or verify identity on your behalf.

20.1.4 HeadStart Docs Pty Ltd does not act as your agent under s 37 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act). We provide technology tools; you perform the CDD.

20.1.5 Your use of HeadStart Verify constitutes your performance of customer due diligence (CDD), not delegation to HeadStart Docs Pty Ltd.

20.1.6 HeadStart Docs Pty Ltd is not a reporting entity under the AML/CTF Act and has no AUSTRAC reporting obligations in respect of your customers.

20.2 Your Obligations as the Reporting Entity

20.2.1 You remain solely responsible for all AML/CTF compliance obligations. You are the collector and verifier of identity information.

20.2.2 You must review, assess and approve all identity information collected through HeadStart Verify. By signing or approving a VOI report, you are performing the verification, not HeadStart Docs Pty Ltd.

20.2.3 You must not rely on HeadStart Verify as a substitute for your own customer due diligence (CDD) procedures. The platform is a tool to assist your CDD, not a replacement for it.

20.2.4 HeadStart Docs Pty Ltd does not make any determination about identity verification outcomes. You make all verification decisions.

20.2.5 You are responsible for ensuring HeadStart Verify is appropriate for your risk-based approach and AML/CTF program.

20.3 No Guarantee of Compliance

20.3.1 Use of HeadStart Verify does not guarantee AML/CTF compliance. Compliance is your responsibility.

20.3.2 AI-assisted document extraction is provided as a tool only. You must verify all extracted data before relying on it.

20.3.3 HeadStart Docs Pty Ltd makes no representation about the accuracy of AI extraction or liveness detection. These are tools to assist your verification process.

20.3.4 You must maintain appropriate records and audit trails as required by the AML/CTF Act. This is your obligation, not ours.

20.4 Data Handling and Retention

20.4.1 Identity documents and personal information collected through HeadStart Verify are stored in accordance with our Privacy Policy and at your direction.

20.4.2 HeadStart Docs Pty Ltd retains identity data to provide the HeadStart Verify service and as instructed by you. We do not independently retain records for AML/CTF purposes.

20.4.3 You may direct deletion of identity data at any time, subject to your record-keeping obligations under the AML/CTF Act. The s 107 retention obligation (7 years) is your obligation as the reporting entity, not ours.

20.4.4 You acknowledge that the records created through HeadStart Verify are your records, hosted by HeadStart Docs Pty Ltd. You are responsible for ensuring compliance with your record-keeping obligations.

20.5 Third-Party Sharing (Future Feature)

20.5.1 HeadStart Verify may in future offer functionality allowing customers to share their verified identity package with third parties.

20.5.2 Any such sharing functionality will be customer-controlled and require explicit consent.

20.5.3 Third parties receiving shared identity data are responsible for their own CDD obligations.

20.5.4 This feature is not currently active.

21. Prohibited Conduct – Reverse Engineering and Technology Protection

21.1 Prohibited conduct

You must not, and must not permit any person acting on your behalf to, reverse engineer, decompile, disassemble or otherwise attempt to derive the source code, algorithms, data structures, workflows, configuration logic, screening rules, risk scoring methodologies, approval gate logic, automated decision-making processes or any other proprietary technology underlying or forming part of the Site, the AML Portal, Plug & Play Technology or any related software, tools or services provided by HeadStart Docs Pty Ltd, except to the limited extent expressly permitted by applicable law that cannot be excluded by agreement.

21.2 Specific prohibitions

Without limiting clause 21.1, you must not:

(a) monitor, intercept or analyse network traffic, API calls, data flows or communications between your browser or device and our servers;

(b) use browser developer tools, inspection tools, debugging tools, packet sniffers or similar to extract, observe, record or replicate any proprietary logic, configuration, workflow or process;

(c) create, commission, fund or assist in the creation of any product, service, platform or tool that is based on, derived from or informed by your observation, analysis, testing or use of our technology, workflows, features, user interface patterns or configuration systems;

(d) systematically access or use the Site, AML Portal or any related platform to map, document, catalogue, screenshot or reproduce its features, workflows, configuration options, screening logic or user interface patterns; or

(e) engage, instruct or permit any third party (including employees, contractors, consultants or agents) to perform any of the acts described in this clause 21 on your behalf or for your benefit.

21.3 Acknowledgements

You acknowledge and agree that:

(a) the technology, software, configuration logic, automated workflows, screening rules, risk scoring methodologies, approval gate logic and user interface design of the Site, the AML Portal and Plug & Play Technology constitute valuable trade secrets and confidential information of HeadStart Docs Pty Ltd;

(b) any breach of this clause 21 would cause irreparable harm to HeadStart Docs Pty Ltd that may not be adequately compensated by damages alone; and

(c) the prohibitions in this clause 21 are reasonable and necessary to protect the legitimate business interests of HeadStart Docs Pty Ltd.

21.4 Remedies

If you breach any provision of this clause 21:

(a) all licences granted to you under these Terms (including any Retail Licence, Commercial Licence or AML Portal subscription) will terminate immediately and automatically without notice;

(b) HeadStart Docs Pty Ltd is entitled to seek injunctive or other equitable relief from any court of competent jurisdiction without the requirement to prove actual loss or damage and without the requirement to post any bond or security;

(c) you will be liable to pay liquidated damages to HeadStart Docs Pty Ltd in the amount of $50,000 (AUD) for each breach of this clause 21, which amount you acknowledge represents a genuine pre-estimate of the minimum loss that HeadStart Docs Pty Ltd would suffer as a result of such breach; and

(d) you will indemnify HeadStart Docs Pty Ltd against, and must pay on demand, all legal costs and expenses (on a full indemnity basis) incurred by HeadStart Docs Pty Ltd in connection with any breach or suspected breach of this clause 21.

21.5 Survival

This clause 21 survives the termination or expiry of these Terms, any licence granted under these Terms and any subscription to the AML Portal or any other service.