Terms of Use

Please read these Terms carefully before creating an account, starting a trial, selecting a plan or using BravoLisa.

By accessing or using BravoLisa, you agree to these Terms.

1. Service, contract, eligibility and acceptance

1.1 Service

BravoLisa is an AI-assisted software service designed to help self-employed professionals in Luxembourg manage their business administration.

The purpose of BravoLisa is to support users in organising, processing and understanding business-related information, including income, expenses, receipts, invoices, client and supplier information, financial records, VAT-related information and other data relevant to bookkeeping, business administration and tax preparation.

BravoLisa may provide features such as:

• tracking income and expenses;
• uploading, storing and organising receipts, invoices, bank statements and other business records;
• issuing and managing invoices;
• extracting and structuring information from uploaded documents;
• categorising expenses and transactions;
• generating summaries, insights, forecasts and financial overviews;
• preparing or pre-filling tax-related information, forms or supporting documents;
• supporting VAT tracking and VAT return preparation, where applicable;
• exporting records and reports;
• providing AI-assisted explanations, suggestions and administrative support through Lisa, the AI assistant inside BravoLisa.

BravoLisa is intended to be used only for lawful professional or business purposes connected with the user’s self-employed activity.

1.2 Contracting party

Your contracting party is the person or the legal entity operating BravoLisa, as identified in the About Us section of our website or application. The operator may be a natural person acting in a professional capacity or a company.

The About Us section forms part of these Terms and identifies who is responsible for providing BravoLisa to you, including the operator’s name, legal form where applicable, registered or business address, registration and VAT details where they exist, and contact information.

In these Terms, “BravoLisa”, “we”, “us” or “our” means that contracting party.

If the operator of BravoLisa changes — for example if the activity is transferred from a natural person to a company — clause 8.6 applies.

1.3 Professional use only

BravoLisa is intended for professional users, in particular self-employed professionals in Luxembourg.

By creating an account or using BravoLisa, you confirm that you use the service for professional or business purposes and not as a consumer.

1.4 Eligibility

To use BravoLisa, you must:

• have legal capacity to enter into a binding agreement;
• be at least 18 years old;
• use BravoLisa for lawful professional or business purposes;
• provide accurate, complete and up-to-date information if requested by BravoLisa;
• accept these Terms and all other agreements, policies or notices required for the relevant service or plan.

If you use BravoLisa on behalf of another person, you confirm that you have authority to accept these Terms on their behalf.

1.5 Required agreements and notices

Your use of BravoLisa may be subject to additional terms, policies or notices for example:

• the Privacy Policy;
• the Cookie Notice;
• the AI Use Notice;
• the Data Processing Terms, which apply when you use BravoLisa to process personal data about third parties;
• the Plans page;
• the engagement letter for human accountant and/or tax services, where applicable;
• any order form, subscription confirmation or other document accepted by you in connection with a specific plan or service.

These documents form part of the contractual framework between you and BravoLisa where they apply to the service you use.

If you do not accept a required document, you may not be able to use the relevant service, feature or plan.

1.6 Additional checks and information

For certain services, especially the Care plan and any human accountant and/or tax service, we or the relevant professional accountant may request additional documents, information, identification details, KYC materials, explanations or confirmations.

We are not obliged to enter into or continue any agreement, engagement letter or service arrangement if:

• you do not provide the requested information;
• the information is incomplete, inaccurate or inconsistent;
• you do not pass KYC, AML, sanctions, professional or risk checks;
• the professional accountant cannot accept or continue the engagement;
• entering into or continuing the service would create legal, regulatory, professional, security, operational or reputational risk.

2. BravoLisa service and plans

2.1 What BravoLisa is

BravoLisa is an AI-assisted bookkeeping and business administration tool designed primarily for self-employed professionals in Luxembourg.

BravoLisa helps users organise business-related information, including expenses, invoices, receipts, financial tracking, bookkeeping data, tax-related information and business insights.

BravoLisa is a software service. Except where expressly agreed under a separate human accountant or tax engagement, BravoLisa does not provide tax, legal or accounting advice and does not replace your own review, judgement or professional advice.

2.2 Plans

BravoLisa may offer different plans, including Free, Smart and Care. During the beta-launch period, only the free beta software service is generally available unless we expressly agree otherwise with you.

The current features, limits, prices, billing periods and commercial conditions of each plan are described on the Plans page or inside the app.

The Plans page forms part of these Terms.

We do not include plan prices directly in these Terms because prices, features and commercial conditions may change over time.

2.3 Changes to plans and features

We may update our plans, features, limits, prices, user interface and functionality from time to time.

Where a price change affects an existing paid subscription, we will notify you in advance in accordance with these Terms.

2.4 Free plan

The Free plan allows you to use limited BravoLisa features without paying a subscription fee.

The Free plan may include limits on invoices, expenses, uploads, storage, exports, analytics, AI-assisted features or other functionality.

Current Free plan limits are described on the Plans page or inside the app.

We may change Free plan limits from time to time to keep the service sustainable.

2.5 Smart plan

The Smart plan is a paid subscription plan that gives access to additional software and AI-assisted features described on the Plans page.

Depending on the selected VAT regime and available features, Smart may include tools such as income and expense tracking, invoice management, AI-assisted insights, tax forecasts, pre-filled tax-related forms, VAT tracking, VAT return preparation and additional exports.

On Smart, BravoLisa may help prepare information and draft documents, but you remain responsible for reviewing, validating and submitting any forms, declarations, invoices or other documents.

BravoLisa does not submit tax declarations, VAT returns or other filings to Luxembourg public authorities on your behalf under the Smart plan.

2.6 Care plan and human accountant services

The Care plan includes Smart plan functionality and access to additional human accountant and/or tax services, as described on the Plans page.

The human accountant and tax services are provided by an individual professional accountant and are governed by a separate engagement letter.

The Care price is split into two components:

• the Smart plan tariff, which covers the software and AI-assisted services described under the Smart plan; and
• the remaining part, which covers the human accountant and/or tax services governed by the engagement letter.

Care is an annual subscription. It runs from 1 January to 31 December. Your first Care year may be a partial year, starting on the date your Care plan begins and running to 31 December of the same year, and is billed for the months it covers.

Care is subject to a minimum commitment of 12 months. Where your first Care year is a partial year, the minimum commitment ends on 31 December of the following year.

Care covers the declarations and periods falling within your Care subscription. Preparation of declarations, bookkeeping or supporting work relating to periods before your Care plan began is not included and is quoted separately.

Form 100 (the Luxembourg income tax return covering your full household income, including salary, rental income and capital gains) is not included in Care by default. We can prepare it on request, for a separate fee quoted case by case.

Care and any human accountant or tax services begin only after KYC, onboarding and acceptance of a separate engagement letter by the professional accountant. We or the professional accountant may request additional documents, information, identification details or confirmations before accepting or continuing the engagement.

If the engagement letter is not entered into, is terminated, or cannot continue for legal, professional, KYC or risk reasons, we may downgrade, suspend, modify or terminate the Care plan or the human services component, as applicable.

Unless expressly stated otherwise in the engagement letter, the use of Care does not mean that all information entered into BravoLisa or all AI-generated outputs have been reviewed, validated or approved by the professional accountant.

2.7 Beta period

BravoLisa is made available as a beta or early-access service before paid plans are launched.

During the beta-launch period, the BravoLisa software service is provided free of charge. Some plans, features or limits described in these Terms or on the Plans page may not yet be available; features may be added, changed or removed at short notice; and the service may be interrupted or contain errors more often than a fully released service. If you would like to discuss Care during beta, please contact us at hello [at] bravolisa [dot] lu. We may agree to provide Care separately, subject to KYC, onboarding and a separate engagement letter; no human accountant or tax service arises automatically from beta access.

The provisions of these Terms relating to fees, trials, billing, refunds, plan changes, cancellation and the Care minimum commitment apply from the date the relevant paid plan becomes available to you and you accept it.

We may end the beta period at any time. We will notify you before your account moves to a paid plan, and you will not be charged unless you accept the applicable plan and price.

3. AI-assisted features and tax-related outputs

3.1 Lisa and AI-assisted features

BravoLisa may include AI-assisted features provided through “Lisa”, the AI assistant inside BravoLisa.

Lisa may help with tasks such as extracting and structuring information from uploaded documents, categorising expenses and transactions, generating or suggesting invoice content, preparing summaries, calculations, financial overviews or insights, and helping organise information relevant for bookkeeping and tax preparation.

BravoLisa may develop, add, change or remove AI-assisted or other features from time to time. The features available under each plan are described on the Plans page or inside the app.

3.2 AI outputs must be reviewed

AI-generated outputs may contain mistakes, omissions, outdated information or incorrect assumptions.

You must carefully review all AI-generated outputs before using them, especially where they relate to invoices, billing information, expense categorisation, financial summaries, calculations, tax-relevant information, legal, accounting or regulatory matters, or information shared with clients, suppliers, accountants or public authorities.

You remain responsible for any information that you approve, send, submit, file or rely on.

3.3 No professional advice through AI

AI-generated outputs are provided for informational and organisational purposes only.

They are not tax, legal or accounting advice and should not be relied upon as a substitute for professional advice.

Your use of AI features is also subject to our AI Use Notice, which forms part of these Terms.

3.4 No filing by BravoLisa unless separately agreed

BravoLisa may help you organise financial data and prepare information that may be useful for bookkeeping and tax preparation.

However, BravoLisa does not submit tax declarations, VAT returns or other filings to Luxembourg public authorities on your behalf, unless this is explicitly offered as part of a separate human accountant or tax service and agreed with you.

On Free and Smart, you review and submit.

On Care, the scope of any review, signature or submission by the professional accountant is defined by the Plans page and the separate engagement letter.

4. Human accountant and tax services

4.1 Separate engagement

Any human accountant or tax services available through BravoLisa are separate professional services provided by an individual professional accountant.

These services are not automatically included in the use of BravoLisa, Free or Smart. They are included in Care only to the extent described on the Plans page and agreed in the separate engagement letter.

4.2 Engagement letter prevails

The scope, conditions, professional responsibility, documents covered, submission rules, fees (outside Care plan), KYC requirements, cooperation duties, termination rights and any other terms of the human accountant or tax services are set out in the engagement letter.

If there is any inconsistency between these Terms and the engagement letter regarding the human accountant or tax services, the engagement letter prevails.

4.3 Your cooperation

You must provide accurate, complete and timely information, documents and explanations requested for the human accountant or tax services.

If you do not provide the requested information, or if the information is incomplete, inaccurate or inconsistent, the professional accountant may refuse to review, sign, submit or continue the relevant work.

4.4 No extension of responsibility

Unless expressly agreed in the engagement letter, the professional accountant’s review or responsibility does not extend to:

• information not provided by you;
• AI-generated outputs not reviewed and approved by the professional accountant;
• documents or filings outside the agreed scope;
• your full household tax situation or private tax matters outside your self-employed activity.

5. Fees, trial, cancellation and refunds

5.1 Fees

Fees for paid plans are described on the Plans page, inside the app, in the order flow or in the relevant engagement letter. The VAT treatment of our fees, including whether prices are displayed with or without VAT, is set out on the Plans page and at checkout.

You agree to pay the fees applicable to the plan or service you select.

We may use third-party payment providers to process payments.

5.2 Smart trial

BravoLisa may offer a free trial for Smart.

The trial duration and conditions are described on the Plans page or inside the app.

At the end of the trial, you may be invited to start a paid Smart subscription. If you do not start a paid subscription, your account may be moved to the Free plan automatically.

5.3 Billing

Billing periods, renewal conditions and payment methods are described on the Plans page, inside the app or in the order flow.

For Care, billing conditions may also be described in the engagement letter.

Because Care includes both software services and human services, the Care price is split between:

• the Smart plan tariff for the software and AI-assisted services; and
• the remaining part for the professional accountant services governed by the engagement letter.

5.4 Refunds

For the first paid Smart subscription period, we offer a 14-day satisfaction refund, unless the Plans page states more favourable conditions.

After that, Smart subscription payments are non-refundable, unless required by applicable law or expressly agreed otherwise.

For Care, we offer a 14-day satisfaction refund, provided that the professional accountant has not yet started, submitted or materially completed any professional work on your behalf. The 14-day period runs from the date you pay for Care. A refund under this clause ends your Care subscription and releases you from the minimum commitment described in clause 2.6.

Additional refund rules for the human accountant or tax services may be set out in the engagement letter.

5.5 Cancellation by you

You may cancel your subscription through your account settings or by contacting us, unless a separate engagement letter provides otherwise.

Cancellation of Smart takes effect at the end of the current billing period, unless otherwise stated on the Plans page.

Cancellation of Care may be subject to additional conditions in the engagement letter, including annual commitment, work already performed, documents already reviewed or signed, and professional obligations of the professional accountant.

Cancelling Care before the end of the minimum commitment described in clause 2.6 does not release you from the fees due for that commitment, except where you cancel because you do not accept a price change under clause 5.6, an assignment under clause 8.6 or an update to these Terms under clause 9.9, or where a refund applies under clause 5.4.

After cancellation, your access may be downgraded, restricted or terminated depending on your plan and these Terms.

5.6 Price changes

We may change our prices from time to time.

If a price change affects an existing paid subscription, we will give you at least 30 days’ advance notice by email or inside the app before the change applies.

If you do not agree to the price change, you may cancel your subscription before the change takes effect.

Your continued use of the paid plan after the effective date of the price change means that you accept the new price.

5.7 Plan changes

Upgrades within Smart take effect immediately and are charged pro rata for the remainder of the current billing period.

If you upgrade from Smart to Care, the unused part of your Smart subscription is credited pro rata, and Care is charged for the period from the upgrade date to 31 December of the same year. From the following year, Care runs from 1 January to 31 December.

Downgrades take effect at the end of the current billing period. Cancellation or downgrade may result in loss of access to plan-specific features, analytics and export formats, as described in section 6.7.

6. Data, privacy, retention and export

6.1 Your data

Your data remains yours.

We do not claim ownership over the business records, documents, invoices, receipts, accounting data or other content you upload or create in BravoLisa.

You grant us the right to host, process, structure, display, copy, back up and otherwise use your data as necessary to provide, secure and support BravoLisa, including AI-assisted features, customer support, billing, compliance and legal defence. We may use aggregated or irreversibly anonymised service information to improve BravoLisa. We use identifiable or pseudonymised user or third-party data for product-improvement purposes only where you have separately opted in.

6.2 Privacy

Our processing of personal data is described in our Privacy Policy.

By using BravoLisa, you acknowledge that we process personal data as described in the Privacy Policy, including data related to your account, use of the service, uploaded documents, invoices, expenses, clients, suppliers, support requests, payments and AI-assisted features.

6.3 Data processing terms

Where you use BravoLisa to process personal data of your clients, suppliers, invoice recipients or other third parties, the Data Processing Terms apply.

The Data Processing Terms are incorporated into these Terms and are accepted electronically when you accept these Terms during registration. They govern our processing of that third-party data on your behalf.

You are responsible for ensuring that you have a lawful basis and the necessary notices for any third-party personal data you upload or process through BravoLisa.

6.4 Hosting and service providers

We host and process data using service providers, including hosting, analytics, payment, AI, support, security and infrastructure providers.

Where required, we enter into appropriate data processing terms with our service providers.

Information about where your data is hosted, about any access to or transfer of data outside the European Economic Area, and about the safeguards that apply to such access or transfer, is set out in our Privacy Policy.

6.5 Retention and deletion

We retain your business records and third-party data for as long as necessary to provide BravoLisa and then follow the deletion or return process in the Data Processing Terms. You remain responsible for maintaining original documents and records, and for meeting any retention obligation that applies to your business.

After account closure or a valid deletion instruction, business records and third-party data are normally removed from active systems within 30 days and from protected backups within 90 days. A future paid archiving service may offer a different retention arrangement on separately stated terms.

BravoLisa may retain only the limited records it needs for its own accounting, security, legal compliance or the establishment, exercise or defence of legal claims, such as its own invoices and payment records, essential account identifiers, security logs, deletion-request records and relevant correspondence. We do not retain your full Workspace merely because a limited BravoLisa record must be kept.

If you cancel a paid plan or downgrade, the applicable plan change may affect access to paid features. It does not itself create a right for BravoLisa to keep your full business records beyond the deletion or return process described above.

During beta, no long-term archiving service is included. We may introduce a paid archiving option later; its scope, retention period, access conditions and price will be described separately before it is offered.

Where a separate human accountant or tax engagement applies, the engagement letter and applicable professional obligations govern the retention of records created or held for that engagement.

Detailed information about retention and deletion is provided in the Privacy Policy and, for third-party data, the Data Processing Terms.

Deletion of an account may not be immediate while we verify the request or where limited BravoLisa records must lawfully be retained. We do not use retained records for unrelated purposes.

You may ask us about deletion by contacting privacy [at] bravolisa [dot] lu.

The data-subject rights described in the Privacy Policy are not limited by the availability of a particular plan feature.

6.6 Export

During beta, an in-app export function may not be available. If you need access to your data or wish to request deletion, contact privacy [at] bravolisa [dot] lu. This does not limit any applicable statutory data-protection right.

If we introduce export functionality, the available formats and any plan-specific features will be described on the Plans page or inside the app.

Any access or retrieval request will be handled within a reasonable period, taking account of technical feasibility, security and applicable law.

Migration of records from another bookkeeping tool into BravoLisa is not supported during beta.

6.7 Paid archiving

We may offer a paid archiving option to preserve access to your records, historical reports or other data after cancellation, downgrade, termination or end of activity.

The features, limits and price of any paid archiving option will be described on the Plans page, inside the app or in a separate offer.

Where you purchase paid archiving before the end of the preservation period described in clause 6.5, the terms of the archiving option apply to the archived records instead of that preservation period.

Unless you choose paid archiving, cancellation or downgrade may result in loss of access to certain paid features, analytics, formatted exports, historical views or other plan-specific functionality, even where the underlying records are retained for legal or technical reasons.

7. Your obligations and acceptable use

7.1 Your responsibility

You are responsible for:

• providing accurate and complete information in BravoLisa;
• reviewing AI-generated outputs before using them;
• correcting any errors or omissions;
• maintaining original documents and records as required by applicable law;
• ensuring that your invoices, financial records and tax-related information comply with Luxembourg legal and tax requirements;
• submitting tax declarations, VAT returns, invoices or other documents where submission is not expressly provided by BravoLisa or the professional accountant service;
• responding to requests for information, explanations or documents;
• ensuring that you have the right to upload, process and use any data, documents or information you provide to BravoLisa.

You remain responsible for any information that you approve, send, submit, file or rely on.

7.2 Account security

You are responsible for keeping your login credentials secure and for all activity carried out through your account.

You must notify us promptly if you suspect unauthorised access to your account.

We may refuse registration, suspend access or terminate an account where we reasonably believe that the account information is inaccurate, fraudulent, misleading, unlawful or creates legal, security or compliance risks.

7.3 Uploaded content

You may upload receipts, invoices, bank statements, screenshots, PDFs, images and other documents relevant to your self-employed activity or small business.

You must not upload documents or content that are unrelated to the purpose of BravoLisa, including personal photos, private documents unrelated to your business administration, sensitive information not required for using the service, unlawful content, malware or third-party content that you are not entitled to use.

In particular, you must not upload special categories of personal data within the meaning of Article 9 GDPR — including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data, health data, or data concerning a person’s sex life or sexual orientation — or photographs of individuals, unless the data is strictly necessary for a business record you are required to keep.

We do not actively pre-screen all uploaded content. However, if we become aware of unlawful, harmful or non-compliant content, we may remove it, restrict access to it, suspend the account or terminate the account.

Where content is unrelated to your business administration but is not unlawful, we will notify you and give you 30 days to remove or relocate it yourself. If you do not act within that period, we may delete it. Repeated or large-scale misuse may lead to suspension or termination of your account.

If you believe that content stored in BravoLisa breaches these Terms or applicable law, please contact us at legal [at] bravolisa [dot] lu.

7.4 Prohibited use

You must not:

• use BravoLisa for unlawful, fraudulent, misleading or abusive purposes;
• use BravoLisa as a generic cloud storage service;
• abuse, threaten, harass, insult or discriminate against our staff, our service providers or the professional accountant, or the AI assistant, or make defamatory statements about them or about BravoLisa;
• upload content unrelated to your business administration or self-employed activity;
• upload malware, viruses or harmful code;
• attempt to access another user’s account or data;
• interfere with the security, availability or integrity of BravoLisa;
• scrape, copy, reverse engineer or misuse the service;
• create multiple accounts to bypass Free plan limits or other restrictions;
• use BravoLisa in a way that breaches Luxembourg or EU law;
• use BravoLisa to process data you are not authorised to process.

We may remove content, restrict features, suspend or terminate accounts where we reasonably believe that this section has been breached.

8. Suspension, termination and assignment

8.1 Suspension

We may suspend access to BravoLisa, your account, a plan, a feature, the Care plan, the human services component or any part of the services if:

• you breach these Terms or any other agreement with us;
• you fail to pay fees when due;
• you misuse BravoLisa or attempt to bypass plan limits;
• you provide false, incomplete or misleading information;
• you abuse, threaten, harass, insult or discriminate against our staff, our service providers or the professional accountant, the AI assistant, or make defamatory statements about them or about BravoLisa;
• you upload unlawful, harmful, infringing or irrelevant content;
• you fail to provide required KYC, onboarding or verification information;
• you do not pass KYC, AML, sanctions, professional or risk checks;
• providing the service would breach applicable law, professional obligations, sanctions rules, internal risk policies or third-party provider requirements;
• your use creates security, legal, operational, reputational or compliance risks;
• we are required to do so by law, public authority, court order, payment provider, professional accountant or professional service provider.

8.2 Termination by BravoLisa with notice

We may terminate your access to BravoLisa, your account, a plan, a feature, the Care plan, the human services component or any part of the services by giving notice where:

• we decide to discontinue a service, plan or feature;
• we change our business model;
• we end support for a feature;
• we close inactive accounts;
• we manage legal, compliance, operational or security risk;
• we have another legitimate business reason to do so.

Where reasonably possible, we will give you advance notice and an opportunity to retrieve your data. If we discontinue BravoLisa as a whole, we will give you at least 60 days’ written notice and, where technically feasible, provide a reasonable way to retrieve your data throughout the notice period and for 30 days after the service ends.

8.3 Termination by BravoLisa without notice

We may terminate immediately and without notice where:

• you materially breach these Terms or another agreement with us;
• immediate termination is required by law, public authority, court order, payment provider, professional accountant or professional service provider;
• your use creates serious legal, security, compliance, operational or reputational risk;
• you fail or refuse to complete required KYC or onboarding;
• you do not pass KYC, AML, sanctions, professional or risk checks;
• continuing the service would breach applicable law or professional obligations;
• you misuse the service, provide fraudulent information or upload unlawful content;
• you seriously or repeatedly abuse, threaten, harass, insult or discriminate against our staff, our service providers or the professional accountant.

8.4 Termination of all or part of the services

BravoLisa may terminate all agreements with you or only some of them.

For example, we may terminate the human services engagement while keeping your software account active on Smart or Free, or we may terminate access to BravoLisa entirely where necessary.

Termination of one agreement does not automatically terminate all other agreements unless we state this, the agreements are functionally dependent on each other, or continuing the remaining agreement is not legally, technically or commercially possible.

8.5 Effect of termination

After termination, you may lose access to your account, paid features, AI-assisted tools, analytics, exports, human services or other functionality.

We may allow you a reasonable period to retrieve your data unless immediate termination, legal restrictions, security concerns or other serious reasons prevent this. This does not affect the access period we commit to under clause 8.2 where we discontinue BravoLisa as a whole.

Termination does not affect:

• fees already due;
• retention obligations;
• rights and obligations that by their nature should continue;
• our right to retain limited records for legal compliance, professional obligations or the establishment, exercise or defence of legal claims;
• limitations of liability;
• intellectual property rights;
• confidentiality, where applicable.

8.6 Assignment by BravoLisa

We may assign, transfer or otherwise dispose of our rights and obligations under these Terms, in whole or in part, to another entity, including in connection with a restructuring, merger, acquisition, sale of business, transfer of assets or change of service provider.

We will notify you at least 15 days before the assignment takes effect, unless a shorter period is required for legal, regulatory, security or operational reasons.

If the assignment materially affects your rights and you do not agree to it, you may stop using BravoLisa and cancel your paid subscription before the assignment takes effect.

8.7 Assignment by you

You may not assign, transfer or otherwise dispose of your rights or obligations under these Terms without our prior written consent.

Any attempted assignment without our consent is ineffective.

9. Intellectual property, liability and legal terms

9.1 BravoLisa intellectual property

BravoLisa, including the app, website, software, design, trademarks, content, documentation, workflows, AI prompts, templates and other materials, belongs to BravoLisa or its licensors.

You may use BravoLisa only as permitted by these Terms.

You must not copy, reproduce, distribute, modify, reverse engineer, decompile, resell, sublicense or otherwise exploit BravoLisa unless expressly permitted by us or by applicable law.

9.2 Feedback

If you provide feedback, suggestions or ideas about BravoLisa, you allow us to use them without restriction or compensation.

We may use feedback to improve, develop or modify BravoLisa.

9.3 Service availability and changes

We aim to make BravoLisa reliable and available, but we do not guarantee uninterrupted, error-free or permanent availability.

We may update, modify, suspend, limit or discontinue features from time to time.

We may perform maintenance, introduce new features, remove outdated features, change technical requirements, update AI models, change service providers or adapt the service to legal, tax, accounting, security or operational requirements.

We will try to avoid material disruption to paid users where reasonably possible.

9.4 No guarantee of tax outcome

BravoLisa helps you organise information and prepare documents, but we do not guarantee any specific tax, accounting, administrative, financial or business outcome.

We do not guarantee that Luxembourg tax authorities, VAT authorities, social security authorities or any other public authority will accept any filing, declaration, classification, calculation, invoice, deduction, position or document.

You remain responsible for ensuring that your filings, invoices, business records and tax-related information are accurate, complete and compliant.

Where human accountant or tax services are provided, the scope of responsibility is limited to the work expressly agreed in the engagement letter.

9.5 Third-party services

BravoLisa may rely on third-party services, including hosting providers, AI providers, payment processors, analytics providers, support tools, email providers, authentication providers, tax data providers, professional service providers or other service providers.

We are not responsible for third-party services except to the extent required by applicable law or expressly stated in these Terms.

Your use of third-party services may be subject to their own terms and privacy notices.

9.6 Limitation of liability

BravoLisa is provided as a software and business administration tool.

To the maximum extent permitted by applicable law, we are not liable for:

• loss of profit, revenue, business opportunity or goodwill;
• indirect, incidental, special or consequential loss;
• loss caused by inaccurate, incomplete or outdated information provided by you;
• loss caused by your failure to review AI-generated outputs;
• loss caused by tax authority decisions, reassessments, penalties or rejected filings, except where caused by our proven fault and within the limits of applicable law;
• loss caused by third-party services outside our reasonable control;
• loss caused by unauthorised access resulting from your failure to keep credentials secure.

Our total liability for claims relating to BravoLisa will be limited to the amount paid by you to BravoLisa for the relevant service during the 12 months preceding the event giving rise to the claim, unless a different mandatory rule applies.

Nothing in these Terms excludes or limits liability where it cannot be excluded or limited under applicable law.

For Care, the liability of the professional accountant may be governed by the separate engagement letter and applicable professional rules.

9.7 Indemnity

Where permitted by law, you agree to compensate us for losses, costs, claims or expenses resulting from:

• your breach of these Terms;
• your unlawful use of BravoLisa;
• inaccurate, incomplete or misleading information provided by you;
• content or data you upload without the required rights or legal basis;
• your failure to comply with legal, tax, accounting or professional obligations applicable to you.

9.8 Force majeure

We are not responsible for delay or failure to perform where this is caused by events outside our reasonable control, including internet failures, hosting outages, cyberattacks, power failures, strikes, natural disasters, war, public authority actions, legal changes, payment provider failures or third-party service disruption.

9.9 Changes to these Terms

We may update these Terms from time to time.

If we make material changes, we will notify you by email, inside the app or through another appropriate channel.

If you do not agree to the updated Terms, you must stop using BravoLisa and cancel your subscription before the updated Terms take effect.

Your continued use of BravoLisa after the effective date of the updated Terms means that you accept them.

9.10 Governing law and jurisdiction

These Terms are governed by the laws of Luxembourg.

The courts of Luxembourg have jurisdiction, unless mandatory law provides otherwise.

9.11 Contact

For questions about these Terms, please contact us using the contact details provided in the About Us section.

Annex. Data Processing Terms

These Data Processing Terms govern our processing of personal data that you, as a user of BravoLisa, upload or enter about your clients, suppliers, invoice recipients and other third parties. For that data you are the controller and BravoLisa acts as your processor within the meaning of Article 28 GDPR.

These Terms do not apply to personal data for which BravoLisa is itself the controller – your account, authentication, billing, support and security data. That processing is described in our Privacy Policy.

1. How these Terms apply

These Data Processing Terms are incorporated into the Terms of Use. They are accepted electronically when you accept the Terms of Use during registration and apply when you use BravoLisa to process personal data about your clients, suppliers, invoice recipients or other third parties.

You may request the current version at any time by writing to privacy [at] bravolisa [dot] lu. Article 28(9) GDPR permits a data processing contract to be concluded in electronic form; a handwritten signature is not required.

These Terms form part of the contractual framework described in clause 1.5 of the Terms of Use. They remain in force for as long as we process personal data on your behalf.

In these Terms, “you” and “your” mean the BravoLisa user acting as controller; “we”, “us”, “our” and “BravoLisa” mean the person or entity identified in the About Us section, as set out in clause 1.2 of the Terms of Use. “GDPR” means Regulation (EU) 2016/679. Terms such as “personal data”, “processing”, “controller”, “processor”, “sub-processor”, “data subject” and “personal data breach” have the meanings given in the GDPR.

2. Subject matter and details of the processing

The subject matter, duration, nature and purpose of the processing, the types of personal data and the categories of data subjects are set out in Annex 1.

3. Processing on your instructions

We process personal data on your behalf only on your documented instructions, including in relation to transfers of personal data to a third country, unless we are required to process it by Union or Member State law to which we are subject. In that case we will inform you of the legal requirement before processing, unless that law prohibits us from doing so on important grounds of public interest.

Your instructions are given by:

• these Terms and the Terms of Use;
• your use of the features and settings available in BravoLisa, including uploading documents, creating records and using AI-assisted features; and
• any further written instruction you send to privacy [at] bravolisa [dot] lu that we accept.

We will inform you if, in our opinion, an instruction infringes the GDPR or other Union or Member State data protection law. We may decline to act on an instruction that is unlawful, technically impossible, or outside the scope of the service.

4. Confidentiality

We ensure that persons authorised to process personal data on your behalf are bound by an appropriate obligation of confidentiality, whether contractual or statutory, and that access is limited to those who need it to provide the service.

5. Security

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the risk to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures under Article 32 GDPR. The measures in place at the date of these Terms are described in Annex 2.

We may update these measures as the service develops. We will not reduce the overall level of security provided.

6. Sub-processors

You give us a general written authorisation to engage sub-processors for the processing carried out on your behalf. A current list of sub-processors and relevant processing locations is available on request at privacy [at] bravolisa [dot] lu.

We impose on each sub-processor, by contract, data protection obligations that are no less protective than those set out in these Terms. We remain fully liable to you for the performance of each sub-processor's obligations.

We will inform you before we add or replace a sub-processor, by email or through the service. If you do not accept the change, your remedy is to stop using the affected feature and, if you wish, terminate your subscription in accordance with the Terms of Use.

7. International transfers

Some sub-processors may be established outside the European Economic Area or may process personal data outside it. The current sub-processor list and relevant processing information are available on request at privacy [at] bravolisa [dot] lu.

Where personal data processed on your behalf is transferred or made accessible outside the EEA, we use one of the lawful transfer mechanisms permitted by Chapter V GDPR, as appropriate to the relevant transfer. This may include an adequacy decision, the European Commission's Standard Contractual Clauses and supplementary safeguards. Information about the safeguards applicable to a given sub-processor is available on request at privacy [at] bravolisa [dot] lu.

8. Assistance with data subject rights

Taking into account the nature of the processing, we assist you by appropriate technical and organisational measures, insofar as this is possible, in fulfilling your obligation to respond to requests from data subjects exercising their rights under Chapter III GDPR.

If a data subject contacts us directly in relation to personal data processed on your behalf, we will not respond on the substance. We will inform you without undue delay and refer the data subject to you, unless you have instructed us otherwise in writing.

The functions available in BravoLisa and written requests to privacy [at] bravolisa [dot] lu are the primary means by which you exercise access, rectification and erasure in respect of the data you control. During beta, an in-app export function may not be available. Assistance beyond the available functions is provided at reasonable cost where the request is repetitive, complex or manifestly excessive.

9. Assistance with security, breach notification and impact assessments

Taking into account the nature of the processing and the information available to us, we assist you in complying with your obligations under Articles 32 to 36 GDPR, namely security of processing, notification of a personal data breach to the supervisory authority and to data subjects, data protection impact assessments and prior consultation.

10. Personal data breaches

We notify you without undue delay after becoming aware of a personal data breach affecting personal data processed on your behalf.

Our notification will describe, to the extent known at the time, the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, the measures taken or proposed, and a contact point for further information. Where the information is not available at once, we provide it in phases as it becomes available.

As controller, you are responsible for deciding whether the breach must be notified to the supervisory authority under Article 33 GDPR or communicated to data subjects under Article 34 GDPR, and for making any such notification.

11. Information and audit

We make available to you the information necessary to demonstrate compliance with the obligations laid down in Article 28 GDPR.

We provide this information in documentary or remote form: a description of our technical and organisational measures, the current sub-processor list, written responses to reasonable security and data-protection questionnaires, and any third-party certification or audit report we hold. We provide it within a reasonable period of a written request, and not more than once in any twelve-month period unless a personal data breach has occurred or a supervisory authority requires otherwise.

We do not offer on-site inspections. Compliance information and audit support are provided remotely or in documentary form.

12. Return and deletion of personal data

At the end of the provision of services relating to processing, we will, at your choice, delete or return to you the personal data processed on your behalf, and delete existing copies.

You may make that choice by writing to privacy [at] bravolisa [dot] lu. If you do not tell us otherwise within 30 days of the end of the service, we will delete the data.

Deletion follows the cycle described in our Privacy Policy: removal from active systems within 30 days and from backups within 90 days.

This clause does not apply only to personal data that Union or Member State law requires BravoLisa itself to store, or which BravoLisa is professionally required to retain under a separate engagement. We hold any such data only for the applicable legal or professional purpose or for the establishment, exercise or defence of legal claims.

13. Your obligations as controller

You warrant that:

• you have a lawful basis under Article 6 GDPR for the personal data you upload or enter into BravoLisa about third parties;
• you have provided the information required by Articles 13 and 14 GDPR to the data subjects concerned;
• your instructions to us comply with applicable data protection law;
• you upload only personal data that is relevant to your business administration, and you do not upload special categories of personal data within the meaning of Article 9 GDPR, or photographs of individuals, unless strictly necessary for a business record you are required to keep; and
• you have taken reasonable steps to check the accuracy of the personal data you provide.

Where free-text fields or uploaded documents incidentally contain special categories of personal data, we process that data only as necessary to provide the service and on your instructions. We do not seek out such data and do not use it for any other purpose.

14. Liability and order of precedence

The limitations of liability set out in clause 9.6 of the Terms of Use apply to these Terms, except where the GDPR provides otherwise. Article 82 GDPR governs liability towards data subjects and is not affected by these Terms.

If there is a conflict between these Terms and the Terms of Use or the Privacy Policy in relation to the processing of personal data on your behalf, these Terms prevail. In all other respects the Terms of Use prevail.

15. Term, changes, governing law and contact

These Terms take effect when you electronically accept the Terms of Use during registration and remain in force for as long as we process personal data on your behalf. Clauses 4, 11, 12 and 14 survive termination.

We may update these Terms where the service, our sub-processors or the law change. If a change materially affects your rights, we will give you notice before it takes effect.

These Terms are governed by the laws of Luxembourg. The courts of Luxembourg have jurisdiction, unless mandatory law provides otherwise.

Contact for all matters under these Terms: privacy [at] bravolisa [dot] lu.

Annex 1 – Details of the processing

Annex 2 – Technical and organisational measures

The following measures are in place at the date of these Terms.

Encryption

Encryption in transit (HTTPS/TLS) between your browser, our application servers and our sub-processors. Encryption at rest for the production database and for uploaded files, provided by the relevant infrastructure providers.

Access control

Authentication and session management delegated to a specialist provider. Named individual accounts for technical access, VPN access, and logging of administrative activity. Access limited to those who need it to operate the service.

Data separation

All business records are scoped to a Workspace, enforced at the application's data-access layer, so that one user's records cannot be reached from another user's account.

Integrity

A SHA-256 hash is recorded for every uploaded file, used for integrity checking and deduplication.

Restrictions on personnel

Confidentiality obligations for everyone with technical access, and a contractual prohibition on downloading production personal data.

Resilience

Regular backups of the production database, with a defined overwrite cycle. Monitoring and an incident-response procedure.

Sub-processor governance

Review of each provider's security posture and data processing terms before engagement, and periodically thereafter.

Data minimisation in AI features

We limit the information sent to AI providers to what is relevant to the requested function. AI-provider processing is subject to the applicable provider terms and data-protection arrangements.

Annex 3 – Sub-processors

The current list of sub-processors, purposes, processing locations and relevant transfer information is available on request at privacy [at] bravolisa [dot] lu. It may be updated in accordance with clause 6.

Where a sub-processor is located outside the EEA, or may process personal data outside it, the transfer safeguards described in clause 7 apply.

Other providers may process personal data for which BravoLisa is itself the controller. They are not sub-processors under these Terms and are described in the Privacy Policy or available on request.