Terms of Service

1. About Indium OS and what it is not

Indium OS provides compliance software and outsourced customer due diligence (CDD) supportto Australian real estate agencies and their staff (the "Platform"). These Terms are a legal agreement between you (the agency, its principal, and authorised users) and Indium OS.

Indium OS is not:

• a law firm, and does not provide legal advice or legal services;
• a provider of financial, taxation, or investment advice;
• a reporting entity acting on your behalf before AUSTRAC; or
• a substitute for your own independent legal or compliance judgement.

Obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006(Cth) (the "AML/CTF Act") are imposed by law and administered by AUSTRAC. Any description of those obligations on the Platform is our understanding of the regime and is not legal advice. You should obtain your own independent legal advice.

2. The reporting entity remains responsible

Where your agency is a reporting entity under the AML/CTF Act, your agency remains solely liable for, and is the decision-maker on, its own compliance obligations. This includes enrolment and registration with AUSTRAC, adoption of an AML/CTF program, risk assessment, ongoing customer due diligence, record-keeping, and any reporting to AUSTRAC.

Indium OS prepares and evidences compliance workflows and supporting material. Indium OS does not make regulatory decisions for you and does not lodge, submit, or file reports (including suspicious matter reports or threshold transaction reports) to AUSTRAC on your behalf. Preparation of a draft report within the Platform does not discharge your reporting obligation; lodgement and the decision to lodge remain with your agency.

3. Acceptable use

You agree that you will not, and will not permit any user to:

• use the Platform for any unlawful purpose or to facilitate money laundering, terrorism financing, or sanctions evasion;
• upload identity documents or personal information without a lawful basis and appropriate consent;
• share login credentials, or attempt to bypass role-gating, access controls, or audit logging;
• reverse engineer, scrape, or attempt to extract source code or underlying data other than your own records; or
• misrepresent the outcome of a verification, or alter or fabricate evidence held on the Platform.

4. Intellectual property

Indium OS and its licensors own all intellectual property rights in the Platform, including its software, workflows, templates, and branding. You are granted a non-exclusive, non-transferable licence to use the Platform during your subscription for your own compliance operations. You retain ownership of the data and documents you upload; you grant Indium OS the rights necessary to host, process, and retain that data to provide the service and to meet record-keeping obligations.

5. Fees and payment

All fees below are in Australian dollars, are inclusive of GST, and are collected through our third-party payment provider.

5.1 CDD verification fee

A customer due diligence fee of $69 is payable per verified party at the end of the intake / CDD flow. This fee applies to both the vendor CDD and the buyer CDD pathway and is payable by the vendor and the buyer respectively. The fee and a tick-box acknowledgement are disclosed at the start of each flow before the fee is incurred.

5.2 Credit system

Where an agent facilitates a shared or reliance record (see 5.3), the agent's share of the fee accrues as credit. The agent chooses how their credit is applied:

• Personal — credit accrues toward a cash-out via our payment provider, prompted only once a threshold of $200 is reached; or
• Agency benefits — credit is applied to discounted resubmissions, feature unlocks, or trials for the agency.

5.3 Shared CDD record

A shared CDD record (reliance on due diligence already performed) carries a fee of $69, split $39 to Indium OS / $30 to the contributing agent. A shared record is only available after the original vendor and buyer CDD pathways are both complete and paid.

5.4 Resubmissions

In-progress edits to a submission are free. Where a submission is materially incomplete and must be fully re-verified, a full re-verification fee of $69 per entity applies. Fixing genuine errors or omissions in an existing submission is not charged again.

6. Limitation of liability

To the maximum extent permitted by law, and subject to any rights you have under the Australian Consumer Law that cannot be excluded, Indium OS is not liable for indirect, consequential, or economic loss, and its total aggregate liability arising out of or in connection with the Platform is limited to the fees paid by you to Indium OS in the twelve (12) months preceding the event giving rise to the claim. Nothing in these Terms limits liability that cannot be limited by law.

Because your agency remains the reporting entity and decision-maker, Indium OS is not liable for regulatory penalties, findings, or losses arising from your compliance decisions, your failure to lodge a report, or the accuracy of information you supply.

7. Termination

Either party may terminate on written notice in accordance with the subscription arrangement. We may suspend or terminate access for breach of these Terms, non-payment, or unlawful use. On termination, your right to use the Platform ends, but records subject to statutory retention will continue to be retained for the period required by the AML/CTF Act (see our Privacy Policy).

8. Governing law

These Terms are governed by the laws of the State of Victoria, Australia , and the parties submit to the non-exclusive jurisdiction of the courts of Victoria.

This document must be read together with our Privacy Policy and Legal Disclaimer. See our compliance overview for how the workflow operates.