Terms & Conditions

These Terms govern your use of flowsecure.eu and your engagement with FlowSecure. FlowSecure is based in the Republic of Estonia and operates under Estonian law. By using this website or engaging our services, you agree to these Terms.

Professional engagements are additionally governed by a bespoke engagement letter and a mutual non-disclosure agreement signed by both parties. Where those documents conflict with this page, those documents prevail for client matters.

1. Website Content

Content on flowsecure.eu is published for general information. It does not constitute legal, tax, financial, or investment advice. No advisor-client relationship is created by visiting the site, submitting an inquiry, or subscribing to any updates. You should not rely on the website in isolation to make structural, tax, or investment decisions.

2. Professional Engagement

We accept new engagements by application. A formal advisor-client relationship begins only once an engagement letter is signed by both parties and initial fees are settled. The engagement letter defines scope, deliverables, timelines, and fee arrangements specific to each client.

Pricing displayed on the website or in the shop is indicative of starting points and configurations. Final fees for bespoke engagements are documented in the engagement letter on the basis of scope, jurisdiction complexity, and service depth.

3. Shop Purchases

Products purchased directly through the shop are subject to the specific terms displayed at checkout. Where a product represents the commencement of a bespoke service (such as incorporation, banking introduction, or payment onboarding), the product purchase initiates that engagement and a corresponding engagement letter is issued following your order confirmation.

Prices are shown in EUR. Applicable VAT, where due under Estonian and EU rules, is calculated at checkout based on your country and VAT status.

4. Refunds and Withdrawal

Given the bespoke nature of our services and the immediate commencement of formation, banking, and regulatory filings upon order confirmation, once substantive work has begun the statutory consumer right of withdrawal under Estonian Law of Obligations Act § 53 may no longer apply. By placing an order, you expressly request that performance begin before the withdrawal period expires where applicable.

Refund requests for partially delivered engagements are handled case by case, with reference to the engagement letter and the costs already incurred on your behalf. Community membership fees are non-refundable once the private network has been accessed.

5. Client Responsibilities

You are responsible for providing complete, accurate, and truthful information during KYC, onboarding, and throughout the engagement. You confirm that any funds used and any business conducted within the structures we set up are lawful and compliant with applicable tax and reporting obligations in your jurisdictions of residence.

You agree to promptly provide any additional documentation reasonably required by incorporation agents, banks, payment providers, or other counter-parties to complete the engagement.

6. Scope Limitations

FlowSecure does not provide, facilitate, or knowingly participate in services that enable tax evasion, money laundering, terrorism financing, sanctions evasion, or any other illegal purpose. Every structure we design is intended to operate lawfully within every jurisdiction it touches. We reserve the right to decline any engagement, at our sole discretion, where purpose, source of funds, or client profile fall outside our scope.

7. KYC and AML Compliance

As an Estonian-operated advisory firm, we are bound by the Estonian Money Laundering and Terrorist Financing Prevention Act and the EU Anti-Money Laundering Directives. Engagements are conditional on successful completion of KYC and, where required, enhanced due diligence. We may decline or terminate engagements at any point where KYC findings raise concerns we cannot resolve.

8. Intellectual Property

The FlowSecure name, logo, website design, and all original content are owned by us. You may view and read the content for personal use; you may not reproduce, adapt, or commercially exploit any part of the site without written permission.

9. Liability

Website content is provided without warranty of any kind. To the maximum extent permitted by law, FlowSecure is not liable for any decision taken, loss suffered, or damage incurred solely on the basis of information published on the website.

For professional engagements, our liability is defined, capped, and allocated within the engagement letter. Nothing in these Terms limits liability for fraud, willful misconduct, or matters that cannot be limited under Estonian law.

10. Governing Law and Jurisdiction

These Terms, the use of flowsecure.eu, and any engagements arising from it are governed by the laws of the Republic of Estonia, without regard to conflict-of-laws rules. Any dispute that cannot be resolved amicably will be submitted to the exclusive jurisdiction of the competent Estonian courts, save that we reserve the right to bring proceedings in a client’s jurisdiction where necessary to enforce our rights.

11. Changes

We may amend these Terms from time to time. Changes take effect when posted on this page with an updated “last updated” date. Material changes affecting active clients will be communicated by email.

12. Community Membership, Educational Content and Service Outcomes

The FlowSecure Intelligence Community, its discussions, publications, reports, updates, events, resources, courses, newsletters, and any other materials made available through the platform are provided solely for informational and educational purposes.

Nothing published, discussed, or shared within the Community constitutes legal advice, tax advice, financial advice, investment advice, accounting advice, or any other regulated professional advice. Members remain solely responsible for conducting their own due diligence and obtaining independent professional advice where appropriate before making any business, financial, tax, legal, banking, investment, or commercial decision.

Participation in the Community does not create an advisor-client relationship unless a separate written engagement letter has been executed between the parties.

FlowSecure makes reasonable efforts to ensure that information shared within the Community and during professional engagements is accurate, relevant, and valuable. However, we do not warrant or guarantee the accuracy, completeness, future validity, suitability, availability, approval, acceptance, or success of any information, strategy, structure, introduction, application, banking relationship, payment provider onboarding, company formation, residency process, regulatory application, or other service outcome.

Many outcomes depend on independent third parties, including but not limited to banks, payment providers, regulators, government authorities, incorporation agents, compliance departments, and other institutions beyond our control.

Unless otherwise required by mandatory applicable law, all Community memberships, subscriptions, consulting fees, onboarding fees, formation fees, advisory fees, implementation fees, and service payments are non-refundable once an order has been confirmed, payment has been received, and work, access, onboarding, preparation, research, introductions, or service delivery has commenced.

The inability to achieve a desired outcome, obtain approval from a third party, open an account, complete onboarding, receive licensing, secure a banking relationship, obtain residency, or achieve any other anticipated result shall not in itself entitle a client or member to a refund.

By purchasing any Community membership, advisory service, implementation service, or other offering provided by FlowSecure, you acknowledge that FlowSecure is engaged as a service provider and not as a guarantor of any specific result or outcome.

13. Affiliate marketing program

Participation

The Company may offer an Affiliate Marketing Program through which approved affiliates may promote the Company’s products and services in exchange for commissions on qualifying sales generated through their unique affiliate code or affiliate link.

Participation in the Affiliate Program is subject to approval by the Company. The Company reserves the right to approve, reject, suspend, or terminate any affiliate account at its sole discretion.

Affiliate Account Information

The affiliate is solely responsible for maintaining accurate, complete, and up-to-date information within their affiliate account, including but not limited to:

• Full legal name;
• Email address;
• Telephone number;
• Account holder name;
• Bank account details;
• IBAN number;
• Any other information requested by the Company.

The Company shall have no liability whatsoever for any payment delays, failed payments, rejected payments, returned payments, or payments sent to incorrect accounts resulting from inaccurate, outdated, incomplete, or incorrect information provided by the affiliate.

Responsibility for Bank Details

The affiliate is solely responsible for ensuring that their payout bank details are accurate at all times.

Payouts shall be made using the bank account information stored in the affiliate dashboard at the time the payment is processed.

If an affiliate changes bank accounts, closes an account, changes IBAN details, changes account holder information, or otherwise modifies their banking arrangements, the affiliate must update such information within their affiliate dashboard before the payout is processed.

The Company shall not be liable for any loss, delay, banking fees, intermediary bank charges, rejected transfers, returned payments, or misdirected payments caused by incorrect or outdated banking information provided by the affiliate.

Any costs incurred as a result of incorrect banking information may be deducted from future commissions or invoiced separately to the affiliate.

Commission Approval

Commissions are only earned on qualifying orders that have been successfully completed and accepted by the Company.

The Company reserves the right to withhold, reverse, adjust, cancel, or reject commissions arising from:

• Cancelled orders;
• Refunded orders;
• Fraudulent transactions;
• Chargebacks;
• Payment disputes;
• Duplicate transactions;
• Self-referrals;
• Abuse of the affiliate system;
• Violations of applicable law;
• Violations of these Terms and Conditions;
• Any transaction reasonably deemed invalid by the Company.

The Company’s records shall be considered final and conclusive regarding commission calculations.

No Guaranteed Earnings

The Company makes no guarantees regarding:

• Affiliate earnings;
• Number of sales;
• Conversion rates;
• Revenue generated;
• Future commission levels.

Participation in the Affiliate Program does not create any employment, partnership, agency, franchise, joint venture, or fiduciary relationship between the Company and the affiliate.

Payout Schedule

Commissions may be paid manually by the Company according to the payout schedule communicated through the affiliate dashboard or otherwise determined by the Company.

The Company reserves the right to delay any payout for compliance, verification, fraud prevention, banking, accounting, operational, legal, or technical reasons.

Payout dates are estimates only and do not constitute guaranteed payment dates.

Payment Processing Delays

Bank transfers may require several business days to arrive depending on:

• Banking institutions;
• Intermediary banks;
• Public holidays;
• Compliance reviews;
• Cross-border payment processing;
• Other factors outside the Company’s control.

The Company shall not be liable for delays caused by banks, payment institutions, payment processors, correspondent banks, government authorities, or other third parties involved in the payment process.

Taxes

Affiliates are solely responsible for determining, reporting, and paying any taxes, duties, social contributions, VAT obligations, income taxes, withholding taxes, or other governmental charges arising from commissions received.

The Company does not provide tax advice and accepts no responsibility for an affiliate’s tax obligations.

Prohibited Conduct

Affiliates may not:

• Misrepresent the Company;
• Make false or misleading statements;
• Engage in spam or unsolicited communications;
• Use deceptive marketing techniques;
• Infringe intellectual property rights;
• Violate applicable laws or regulations;
• Impersonate the Company or its employees;
• Use affiliate codes in a fraudulent manner;
• Attempt to manipulate commission calculations.

The Company may immediately terminate participation and cancel unpaid commissions in the event of such conduct.

Right to Modify or Terminate

The Company reserves the right to modify, suspend, discontinue, or terminate the Affiliate Program at any time without prior notice.

The Company may also modify commission structures, payout methods, eligibility requirements, qualification criteria, or program rules at its sole discretion.

Limitation of Liability

To the maximum extent permitted by law, the Company’s total liability arising from or relating to the Affiliate Program shall not exceed the total commissions actually earned and unpaid by the affiliate during the three (3) months preceding the event giving rise to the claim.

Under no circumstances shall the Company be liable for:

• Indirect damages;
• Consequential damages;
• Lost profits;
• Loss of business opportunities;
• Loss of anticipated revenue;
• Reputational damage;
• Banking losses;
• Tax liabilities;
• Third-party claims.

Final Authority

The Company shall have the final authority regarding:

• Affiliate approval;
• Commission calculations;
• Commission adjustments;
• Payout determinations;
• Program interpretation;
• Fraud determinations;
• Compliance reviews;
• Affiliate account status.

All decisions made by the Company regarding the Affiliate Program shall be final and binding.

14. Contact

Questions about these Terms: support@flowsecure.eu.