Data Use and Licensing Terms

Version date: 23 September 2026

These Data Use and Licensing Terms apply to business customers only.

This version applies where it is incorporated into an Agreement or takes effect under the change provisions of an existing Agreement.

1. Purpose

These Data Use and Licensing Terms govern the Customer's use of Hackford Data supplied through the Hackford platform, exports, APIs, reports, bespoke datasets and related services.

They form part of the Agreement between Hackford Data Ltd, trading as Hackford, and the Customer.

2. Definitions

In these Data Use and Licensing Terms:

"Acquired Data" means Hackford Data lawfully exported or otherwise recorded by, or delivered to, the Customer within the access, export, API and other entitlements of an Order for paid Services. It excludes data supplied solely for a trial or evaluation unless that data is expressly included in a subsequent Order for paid Services.

"Affiliate" means an entity that directly or indirectly controls, is controlled by, or is under common control with a party.

"Agreement" means, as applicable, the Order, the Master Subscription Terms, these Data Use and Licensing Terms, the DPA, and any other document expressly incorporated into the Order.

"Customer", "you" or "your" means the customer entity identified in the Order.

"FCA Extract Data" means information made available through the Services that is sourced from the FCA Financial Services Register Extract Service, including selected records and fields from that source.

"Hackford Data" means data, records, search results, classifications, profiles, matches, relationship data, derived data, enrichment, exports, API responses, reports and other outputs made available by or through the Services. Hackford Data includes regulatory and third-party source information made available through the Services and Hackford's proprietary enrichment of that information.

"Master Subscription Terms" means Hackford's master subscription terms forming part of the Agreement.

"Order" means an order form, online order, statement of work or other ordering document accepted by both parties that describes the purchased package, users, fees, term, renewal, entitlements and other commercial terms.

Other capitalised terms have the meanings given in the Master Subscription Terms unless the context requires otherwise.

3. Licence

Subject to the Customer paying applicable fees and complying with the Agreement, Hackford grants the Customer a limited, non-exclusive, non-transferable and non-sublicensable licence to use Hackford Data for the Customer's internal business purposes within the scope of the Order and subject to the source restrictions in clause 9. The licence applies during the Subscription Term or agreed project term and continues for Acquired Data as set out in clause 12.

The Customer's Affiliates or wider group companies may use Hackford Data only if the Order expressly permits group access. Where group access is permitted, the Customer is responsible for use of Hackford Data by those Affiliates and group companies.

4. Professional-Services and Client Work

Where the Customer uses Hackford Data in connection with work for its clients, the following restrictions apply in addition to clause 9:

• the Customer remains responsible for its own use of Hackford Data;
• the Customer does not provide, disclose or make Hackford Data available to its clients, including selected records, extracts or Hackford Data embedded in reports, presentations or other materials;
• the Customer does not give its clients access to the Hackford platform, database, API or exports;
• the Customer's advice, analysis and conclusions provided to clients must not reproduce or disclose Hackford Data;
• Hackford Data is not presented as legal, regulatory, financial or other professional advice from Hackford.

5. Customer Materials

As between the parties, the Customer owns its own original materials. The Customer does not acquire ownership of Hackford Data embedded in or used to create those materials. Any embedded Hackford Data remains subject to these terms.

Client-facing materials must comply with clause 4 and must not reproduce or disclose Hackford Data.

6. Restrictions

The Customer must not:

• provide, disclose or make Hackford Data available to its clients, including selected records, extracts or Hackford Data embedded in customer-created materials;
• resell, sublicense, distribute or otherwise commercialise raw Hackford Data;
• provide any third party with general access to the platform, API, database, exports or substantial parts of Hackford Data;
• publish substantial datasets, bulk exports or raw record-level extracts publicly;
• use substantial quantities of Hackford Data, bulk exports, replicated datasets or Hackford's non-public classifications or methods to create or maintain a data product that materially substitutes for the Hackford service;
• systematically extract, download or replicate Hackford Data beyond agreed export, API or usage limits;
• scrape the platform or use unauthorised automated access;
• share credentials, API keys or named-user accounts;
• circumvent export limits, API restrictions, rate limits, paywalls, access controls or usage controls;
• use Hackford Data for indiscriminate bulk marketing, harassment, nuisance communications or irrelevant outreach;
• use Hackford Data as the sole basis for employment, credit, regulatory, disciplinary, licensing, access-to-services or other materially adverse decisions about any person or organisation;
• imply endorsement, approval or sponsorship by the FCA, SEC, any other regulator, public authority or third-party source;
• knowingly use inaccurate Hackford Data after receiving a correction or update from Hackford or another reliable source.

The source restrictions in clause 9 apply in addition to these restrictions.

7. AI Use

The Customer must not upload bulk Hackford Data, bulk exports or replicated Hackford datasets to public or shared AI services.

The Customer must not use Hackford Data to train, fine-tune or otherwise improve a general-purpose AI model.

Use of AI services remains subject to the other restrictions in these terms, including clauses 6, 8, 9 and 11.

8. Personal Data and Direct Marketing

Business-contact data can remain personal data where an individual is identifiable, even where the data relates to that individual's professional role.

For Hackford-supplied personal data, Hackford and the Customer act as independent controllers for their respective processing. They are not joint controllers. Hackford does not act as the Customer's processor merely because the Customer accesses or exports Hackford Data.

The Customer is responsible for its own lawful basis, transparency information, direct-marketing rules, communications, security and retention. In particular, the Customer must:

• use professional contact information only for relevant professional purposes;
• identify itself clearly in outreach;
• provide straightforward contact details and an easy opt-out;
• respect objections and opt-outs;
• maintain and screen against an appropriate suppression list;
• distinguish between companies, corporate subscribers, individual subscribers, sole traders, partnerships and other recipient types where different direct-marketing rules apply;
• where the Customer cannot determine whether a recipient is a corporate subscriber or an individual subscriber, apply the stricter individual-subscriber rules;
• cooperate reasonably with Hackford on material corrections, objections, suppression requests and rights requests relating to Hackford-supplied personal data.

The Customer must not transfer personal data contained in FCA Extract Data outside the United Kingdom or European Economic Area without appropriate protections under applicable data-protection law.

Privacy queries for Hackford should be sent to Daniel Robinson as Privacy Contact at dan.robinson@hackforddata.com.

9. Source and Regulator Restrictions

The Customer must use FCA Extract Data as an information resource only. The Customer must not distribute, publish or sell FCA Extract Data to any third party, or otherwise use FCA Extract Data to create another product or service.

The Customer must not use FCA Extract Data to advertise or promote products or services in ways that could imply FCA endorsement or are likely to mislead others, or use FCA Extract Data in ways that are knowingly or potentially libellous or slanderous of individuals, companies or organisations.

Where Hackford Data includes FCA Financial Services Register or related FCA Register Extract data, the Customer must not:

• reproduce FCA logos;
• use Hackford Data or FCA-derived data in advertising or promotion in a way that implies FCA endorsement;
• use the data in a knowingly misleading, libellous or slanderous way;
• make representations for or on behalf of the FCA;
• disseminate complete or near-complete copies of the FCA Financial Services Register or a substantial subset of it.

The restrictions on FCA Extract Data apply regardless of the quantity used and whether another product or service would compete with Hackford. An entitlement to access, export or use Hackford Data does not override these restrictions.

Where Hackford expressly notifies the Customer of source restrictions applying to other regulators, public authorities, registers, public sources or third-party sources, the Customer must comply with those notified restrictions.

10. Accuracy, Freshness and Use of Data

Hackford Data is provided as an information resource. It may include official-source data, public-source data, third-party data, derived classifications, matching, enrichment and Hackford analysis. Source data may be delayed, incomplete, changed by the source, or interpreted differently depending on context.

The Customer should consider source dates, confidence indicators, caveats and context supplied with Hackford Data. Hackford Data should not be treated as legal, regulatory, financial, employment, credit or professional advice.

Where Hackford notifies the Customer of a material correction, deletion, objection or source caveat, the Customer must take reasonable steps to apply it to relevant copies, CRM records, reports and client materials under its control.

Where Hackford notifies the Customer that the FCA requires replacement, retrieval or deletion of FCA Extract Data because of an error in the source extract, the Customer must cooperate with Hackford and take the steps necessary to give effect to that requirement for affected copies under its control. The Customer must also cooperate with Hackford in the recall and return of affected FCA Extract Data following a personal data breach that is required to be notified to the supervisory authority under applicable data-protection law. The Customer must promptly notify Hackford of such a breach involving FCA Extract Data under its control and provide reasonable assistance and relevant information for the investigation and response.

11. Confidentiality

Public-source facts are not themselves confidential merely because they are included in Hackford Data.

Non-public exports, compilations, classifications, reports, access credentials, API responses, licensed datasets, pricing, documentation, non-public platform materials and Hackford's non-public methods are Hackford Confidential Information.

The Customer must restrict access to Hackford Confidential Information to authorised users and personnel who need access for permitted purposes. The Customer remains responsible for use of Hackford Data by its users, employees, contractors, advisers and Affiliates who receive Hackford Data for a permitted purpose.

The confidentiality obligations relating to confidential FCA Extract Data and confidential product materials incorporating that data continue for as long as the relevant information remains confidential. The Customer must not rely on a confidentiality exception to make a disclosure prohibited by clause 9.

12. Suspension, Termination and Continued Data Rights

12.1 Service access

Expiry or termination of an Order, including non-renewal or cancellation, ends access to the Platform and the right to further exports, deliveries and updates under that Order. Completion of a one-off delivery does not itself end the licence to the agreed delivered data.

12.2 Acquired Data

The licence in clause 3 continues for Acquired Data after the service period ends, subject to payment of the fees due for that data or the period in which it was acquired and continued compliance with the Agreement. Its purpose and scope do not expand after the service period ends. If the Order expressly specifies a duration for use of Acquired Data, that duration applies; a subscription or delivery period alone is not a data-licence expiry date.

The source restrictions, confidentiality, data-protection and correction, replacement, retrieval, recall, return and deletion obligations continue to apply to Acquired Data and all copies of it. Its format or location does not extend the licence or override those obligations.

12.3 Suspension or termination of data rights

Hackford may terminate the licence to affected Acquired Data by written notice if the Customer commits a material breach relating to that data, including failure to pay undisputed fees due for that data or the period in which it was acquired. Where the breach can be remedied, termination may take effect only if it remains unremedied 10 Business Days after written notice requiring remedy. Failure to comply with an obligation does not by itself terminate the licence to Acquired Data; suspension or termination of that licence by Hackford is governed by this clause.

Hackford may suspend affected data rights where reasonably necessary to contain material misuse or a security risk involving that data. Hackford may also suspend or terminate affected data rights to the extent necessary to comply with Applicable Law or binding source restrictions, including where a loss or limitation of Hackford's source rights prevents the Customer's continued use.

Hackford must identify the affected data, the reason, the required action and its timing in the notice, and limit the action to the scope reasonably necessary. Prior notice must be given where reasonably practicable. Suspension or action necessary to comply with Applicable Law or binding source restrictions may take immediate effect where necessary. This does not shorten the remedy period for termination under the first paragraph of this clause 12.3. Suspended rights must be restored when the reason for suspension is resolved, unless those rights have validly ended.

12.4 Return and deletion

When the licence to any Hackford Data expires or is terminated, the Customer must stop using that data and delete copies under its control as soon as reasonably practicable and within 30 days. This includes data not covered by the continuing licence in clause 12.2 when the service period ends. The Customer must comply with any earlier applicable correction, replacement, retrieval, recall, return or deletion requirement under clause 10, Applicable Law or binding source restrictions notified under clause 12.3. A suspension alone does not require deletion unless a separate applicable requirement calls for it.

These requirements apply to affected Hackford Data within the Customer's systems and materials, including archives and backups. They do not require deletion of the Customer's own content or information lawfully obtained independently of Hackford. Where Applicable Law requires retention of affected Hackford Data, the Customer must retain only the information required, for no longer than required, restrict access and processing to that legal requirement, and delete it when the requirement ends.

The obligations concerning source restrictions, privacy, confidentiality and correction, replacement, retrieval, recall, return and deletion survive expiry or termination for as long as the Customer holds affected data.