Terms of Service

1. What ubo.swiss is

ubo.swiss is a regtech tool that helps Swiss fiduciaries identify ultimate beneficial owners (UBOs) of Swiss legal entities, supporting compliance with the Swiss Transparency Act (TJPG / LTPM, in force autumn 2026). The tool aggregates publicly-available commercial-register data (ZEFIX, cantonal HR), foreign public registers where applicable (e.g. Francerecherche-entreprises.api.gouv.fr), and screens identified persons against open sanctions lists.

2. What ubo.swiss is NOT

• Not a substitute for the fiduciary's own KYC obligations under the Swiss Anti-Money Laundering Act (AMLA / GwG / LBA-FINMA). You remain legally responsible for identifying the UBO of each client under LBA Art. 3 and for the completeness of any TJPG filing.
• Not a registry. Authoritative source-of-truth is the cantonal commercial register and, where applicable, the federal Transparenzregister (write-only for filers).
• Not legal advice. Output of the tool is an aid to compliance workflow, not a legal opinion.
• Not a certified data product. Outputs may contain extraction errors (OCR / LLM / parser limitations) — every filing must be verified against the source publications and the client's declaration before submission.

3. Acceptable use

• Use the tool only for legitimate compliance, KYC, AML, and regulatory filing purposes (LBA Art. 3, TJPG / LTPM, GwG).
• Do not scrape, redistribute, resell, or repackage the tool's outputs without a separate written licence.
• Do not use the tool to investigate natural persons for purposes unrelated to a documented compliance mandate. Personal data of registered persons (managers, partners) is protected by Swiss revDSG and EU GDPR even when sourced from public registers.
• Do not attempt to circumvent rate limits, authentication, or other technical safeguards.

4. No warranty

The service is provided as-is, without warranty of any kind, express or implied. We make no guarantee that data is complete, current, or fit for any particular purpose. In particular:

• ZEFIX exposes only a subset of commercial-register publications — pre-2018 founding acts are frequently missing. The tool surfaces this gap explicitly when detected.
• LLM-based extraction of French narrative-mutation publications may produce errors. Outputs marked "NOT FOR FILING WITHOUT VERIFICATION" require manual review.
• Sanctions screening is best-effort against open lists (SECO, OFAC, EU, UN, FINMA via OpenSanctions). It is not equivalent to a commercial sanctions feed and must not be relied upon as the sole basis for an AMLA-relevant decision.

5. Liability

To the maximum extent permitted by Swiss law, we exclude liability for indirect or consequential damages, regulatory fines, missed filings, or losses arising from reliance on the tool's output. The fiduciary remains the responsible party under TJPG / LTPM, LBA, and any applicable sector regulation. Maximum aggregate liability under any contract that may follow these draft terms is limited to fees paid during the 12 months preceding the claim.

6. Data protection

Processing of personal data is governed by our Privacy & data protection notice (Swiss revDSG + EU GDPR where applicable). Lawful basis for processing public-register personal data is legitimate interest (revDSG Art. 31 / GDPR Art. 6(1)(f)) tied to the fiduciary's own AMLA obligations.

7. Governing law & venue

These draft terms are governed by Swiss substantive law, excluding conflict-of-laws rules and the United Nations Convention on Contracts for the International Sale of Goods. Exclusive jurisdiction is at the registered seat of the service operator (to be confirmed in the final terms).

8. Changes

We may update these terms. Material changes will be notified via the lookup interface. Final commercial terms will replace this draft before any paid onboarding.

9. Contact

For legal questions about these terms: hello@uboswiss.ch.