Terms of use

1.1 Defined terms

1.1.1 In these Terms of Use, the following terms have the meanings set out below and in the definitions appendix in section 49. Defined terms are bold on first use and capitalised throughout.

1.1.2 Sirius Consulting FZCO is a free zone company established in the United Arab Emirates and trading as Cosmos (trade licence number 43190, registered office The Bureau, Opera Grand, Downtown, Dubai, United Arab Emirates). Sirius Consulting FZCO operates the Website and acts as the contracting party and data controller in respect of the Website. This is the only operator definition in these Terms of Use, and it applies to every part of this page.

1.1.3 Affiliate means, in relation to any entity, any other entity that directly or indirectly Controls, is Controlled by, or is under common Control with that entity, where Control means the ownership of more than fifty per cent of the voting securities or the power to direct the management and policies of an entity whether through ownership of voting securities, by contract, or otherwise.

1.1.4 Cosmos, Cosmos Group, we, us and our mean Sirius Consulting FZCO together with its Affiliates.

1.1.5 Website means the website at https://cosmos.global and any associated pages operated by Cosmos, including the Onboarding Flow and on-site payment functionality, but expressly excluding the Platform.

1.1.6 Platform means the separate AI-powered software-as-a-service platform made available by Cosmos on a subdomain and governed by the Master Services Agreement.

1.1.7 Master Services Agreement or MSA means the separate agreement governing access to and use of the Platform.

1.1.8 Onboarding Flow means the guided intake process on the Website through which a prospective client submits information to Cosmos.

1.1.9 Onboarding Submission means any information, document or material submitted by a User through the Onboarding Flow.

1.1.10 User, you and your mean any person who accesses or uses the Website.

1.1.11 Content means all text, graphics, data, software and other material made available on or through the Website.

1.1.12 User Content means any material submitted by a User, including any Onboarding Submission.

1.1.13 Services means the corporate services and compliance technology services offered by Cosmos.

1.1.14 Business Day means a day other than a Friday, Saturday or public holiday in the Abu Dhabi Global Market.

1.2 Construction

1.2.1 References to a statute or statutory provision include any subordinate legislation made under it and any amendment, re-enactment or replacement of it from time to time in force.

1.2.2 The singular includes the plural and vice versa. References to a person include any individual, body corporate, partnership, unincorporated association, government authority or other entity.

1.2.3 Clause and section headings are for convenience only and do not affect interpretation.

1.2.4 "Including" and similar expressions are not words of limitation.

1.2.5 Where a provision requires something to be done in writing, email satisfies that requirement unless expressly stated otherwise.

2.1 Age requirement

2.1.1 The Website is intended solely for use by persons who are at least 18 years of age. By accessing or using the Website, you represent and warrant that you are at least 18 years old.

2.1.2 If you are under 18 years of age, you must not access or use the Website. We do not knowingly collect Personal Data from persons under 18. If we become aware that we have collected information from a person under 18, we will delete that information promptly.

2.2 Legal capacity and authority

2.2.1 By using the Website, you represent and warrant that:

• you have full legal capacity to enter into binding obligations under these Terms of Use;
  
• if you are using the Website on behalf of a company, partnership, trust, or other organisation, you have authority to bind that organisation to these Terms of Use, and references to "you" include that organisation; and
  
• your use of the Website does not violate any applicable law or regulation, including any sanctions, export control or anti-money-laundering law.
  

2.2.2 If you are acting on behalf of an organisation, the individual accepting these Terms of Use also represents that they are authorised to do so.

2.3 Jurisdictional restrictions

2.3.1 The Website is not directed at any person in any jurisdiction where making the Website available would be contrary to applicable law or regulation, or would subject Cosmos to any licensing, registration, or other regulatory requirement in that jurisdiction. Access to the Website from certain jurisdictions may be restricted in accordance with the sanctions and export controls provisions in section 17.

2.3.2 It is your responsibility to ensure that your access to and use of the Website complies with all laws and regulations applicable to you in your jurisdiction.

3.1 How you accept these Terms of Use

3.1.1 These Terms of Use form a binding legal agreement between you and Cosmos. You accept these Terms of Use by:

• accessing or browsing the Website;
• submitting an Onboarding Submission; or
  
• making a payment through the Website.
  

3.1.2 If you do not accept these Terms of Use in their entirety, you must leave the Website immediately and refrain from using it.

3.2 Updates and changes

3.2.1 We may update these Terms of Use from time to time in accordance with the variation provisions in section 45. The version in force at the time you access the Website governs that access. We encourage you to review these Terms of Use each time you visit.

3.2.2 Your continued use of the Website after any update constitutes your acceptance of the updated terms, provided that we have given you reasonable advance notice of material changes in accordance with section 45.

4.1 What these Terms of Use cover

4.1.1 These Terms of Use govern:

• browsing and use of the Website and its Content;
  
• Onboarding Submissions made through the Onboarding Flow; and
  
• payments made through the Website for simple client engagements.

4.2 Express carve-out: the Platform

4.2.1 These Terms of Use do not govern use of the Platform. The Platform is a separate product provided on a subdomain and is governed exclusively by the MSA.

4.2.2 If you are a subscriber to the Platform, your use of the Platform is governed by the MSA. To the extent of any inconsistency between these Terms of Use and the MSA in relation to the Platform, the MSA prevails.

4.2.3 Access to the Platform may require separate onboarding, identity verification, and agreement to the MSA and associated schedules.

4.3 No accounts on the Website

4.3.1 No user accounts are created on the Website. The Website does not provide a login, dashboard, or persistent user profile. Any account functionality is part of the Platform and is governed by the MSA.

4.3.2 Completion of the Onboarding Flow does not itself create an account or entitle you to access the Platform.

5.1 User warranties in relation to Onboarding Submissions

5.1.1 When you submit an Onboarding Submission, you represent and warrant to Cosmos that:

• all information, documents and materials in the Onboarding Submission are accurate, complete, and not misleading in any material respect at the time of submission;
  
• you have full authority to submit the Onboarding Submission, including where it contains information relating to a company, trust, or other legal entity, whether as a director, officer, authorised signatory, or duly authorised representative;
  
• the Onboarding Submission does not infringe the intellectual property rights, privacy rights, or any other legal rights of any third party;
  
• you have obtained all necessary consents to share with Cosmos any Personal Data of third parties included in the Onboarding Submission;
  
• the Onboarding Submission is not made in connection with any fraudulent, unlawful, or prohibited activity, including any activity that would engage any sanctions regime referred to in section 17; and
  
• the Onboarding Submission complies with the acceptable use provisions in sections 20 to 26.

5.2 Cosmos reliance on Onboarding Submissions

5.2.1 You acknowledge and agree that Cosmos relies on the accuracy and completeness of your Onboarding Submission when evaluating whether and how to engage with you as a prospective client. Any inaccuracy or omission may affect Cosmos's ability to provide Services and may affect the services ultimately delivered.

5.2.2 Cosmos is not obliged to verify the accuracy or completeness of any Onboarding Submission independently. Cosmos's reliance on an Onboarding Submission does not limit your liability for any inaccuracies or omissions.

5.2.3 You agree to notify Cosmos promptly if you become aware of any inaccuracy in, or material change to, information contained in an Onboarding Submission.

5.3 Cosmos's right to decline

5.3.1 Cosmos reserves the right, in its absolute discretion and without liability to you, to:

• decline to proceed with any Onboarding Submission;
  
• request further information, documentation, or verification before proceeding; or
  
• suspend or discontinue the Onboarding Flow at any time.
  

5.3.2 Cosmos is not required to give reasons for declining an Onboarding Submission, except where expressly required to do so by applicable law.

5.3.3 Nothing in this section prejudices Cosmos's rights under the termination and suspension provisions in section 16 or under applicable law.

6.1 Scope and pricing

6.1.1 Cosmos accepts payments through the Website in connection with simple client engagements for which pricing has been agreed prior to payment. These Terms of Use govern Website payments; the commercial terms of any resulting Services engagement will be set out in a separate engagement letter or other agreement.

6.1.2 Prices displayed on the Website or quoted in connection with an Onboarding Submission are quoted and charged in US dollars (**USD**) as the primary currency. Cosmos may also offer prices in pounds sterling (GBP), UAE dirhams (AED), Singapore dollars (SGD), and euros (EUR) as stated on the relevant page or in the relevant quotation. All currency-conversion costs and exchange-rate risk arising from payment in a currency other than the currency in which the price is stated are borne by you.

6.1.3 All prices are stated inclusive or exclusive of applicable taxes as specified on the relevant page. Where taxes are not separately shown, they are included in the stated price.

6.1.4 Cosmos reserves the right to change its published pricing at any time without prior notice, provided that any price change does not affect payments already submitted and confirmed by Cosmos.

6.2 Taxes

6.2.1 You are responsible for any taxes, duties, levies, or charges applicable to your purchase under the laws of your jurisdiction, including value added tax, goods and services tax, sales tax, and withholding tax. Cosmos will charge applicable UAE value added tax where required by UAE Federal Decree-Law No. 8 of 2017 on Value Added Tax and its Executive Regulations.

6.2.2 Where Cosmos is required by law to withhold or deduct tax from a payment, the amount payable by you will be grossed up so that Cosmos receives the full amount stated after deduction of any required withholding.

6.3 Payment processor

6.3.1 Payments on the Website are processed by Stripe, the third party payment processor. By making a payment through the Website, you agree to Stripe's terms of service and privacy policy in addition to these Terms of Use. Cosmos has no control over Stripe's terms and is not responsible for errors or delays caused by Stripe.

6.3.2 Cosmos does not store your full payment card details. Payment card data is held by Stripe in accordance with applicable PCI-DSS standards.

6.3.3 Cosmos is not responsible for any fees, charges, or foreign exchange losses imposed by your bank, card issuer, or Stripe in connection with a transaction.

6.4 Invoicing

6.4.1 Cosmos will issue an invoice or payment confirmation to the email address you provide in connection with the Onboarding Flow promptly following confirmation of payment.

6.4.2 Invoices are issued by Sirius Consulting FZCO and will include any information required under applicable law, including any applicable UAE VAT registration number.

6.5 Currency conversion

6.5.1 Where a payment is made in a currency other than the currency in which the price is stated, currency conversion will be applied by Stripe or your card issuer. You bear all currency-conversion costs and exchange-rate risk. Cosmos is not responsible for any exchange rate applied or any resulting currency conversion loss.

6.5.2 Cosmos does not guarantee that pricing shown in multiple currencies on the Website will be equivalent at the time of payment.

6.6 Refunds and cancellation policy

6.6.1 All fees paid through the Website are non-refundable once paid, subject only to:

• section 6.7 (Statutory consumer cancellation rights), to the extent that a refund is required by mandatory consumer protection law applicable to a User who is a consumer resident in the EU or EEA, the UK, or Singapore; and
  
• any refund that Cosmos agrees in writing at its sole discretion in the circumstances of a particular case.
  

6.6.2 If Cosmos is unable to fulfil a confirmed engagement for reasons within its control, Cosmos will consider an appropriate refund of fees paid to the extent that Services have not been delivered. Any such refund will be agreed in writing and will be processed in accordance with section 6.6.3. Cosmos's liability in that event is limited to the amount of any refund agreed and does not extend to any consequential, indirect, or other losses.

6.6.3 Cancellation requests and refund queries must be submitted to legal@cosmos.global. Cosmos will acknowledge any such request within five Business Days. Where a refund is agreed, it will be processed through Stripe to the original payment method within 14 Business Days of confirmation, subject to Stripe's processing timelines.

6.7 Statutory consumer cancellation rights

6.7.1 Nothing in these Terms of Use limits or excludes any statutory cancellation or cooling-off rights that apply to you under the mandatory laws of your jurisdiction of residence, including:

• the right of cancellation within 14 calendar days under Directive 2011/83/EU of the European Parliament and of the Council, for consumers resident in the EU or EEA, as implemented in the relevant member state;
  
• the right of cancellation within 14 calendar days under the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, for consumers resident in the United Kingdom; and
  
• any applicable cancellation rights under the Consumer Protection (Fair Trading) Act 2003 or the Consumer Protection Act 2006, for consumers resident in Singapore.
  

6.7.2 Where you, as a consumer, expressly request that the Services begin within the applicable statutory cancellation period, and you acknowledge that you will lose your statutory right of cancellation once the Services have been fully performed, your statutory right of cancellation will be lost upon full performance of the Services. Cosmos will draw your attention to this at the point of purchase where required by applicable law and will obtain the necessary acknowledgement from you at that time.

6.7.3 Statutory cancellation rights under this section are in addition to, and do not limit, any contractual cancellation rights set out in an applicable engagement letter.

6.8 Chargebacks

6.8.1 If you initiate a chargeback or payment dispute in relation to a payment made on the Website, you agree to notify Cosmos at legal@cosmos.global before doing so, and to give Cosmos a reasonable opportunity to resolve the dispute in accordance with section 6.6.

6.8.2 Cosmos reserves the right to recover from you any costs, fees, or losses, including Stripe chargeback fees, incurred as a result of a chargeback that is not upheld or that relates to a payment that was validly made in accordance with these Terms of Use.

7.1 Availability

7.1.1 Cosmos uses commercially reasonable efforts to keep the Website available. The Website is provided on an "as is" and "as available" basis. Cosmos does not guarantee that the Website will be continuously available, free from interruption, or free from errors or defects.

7.1.2 Access to the Website may be interrupted for the purposes of maintenance, updates, security patching, or circumstances beyond Cosmos's reasonable control. Cosmos will use commercially reasonable efforts to minimise the duration and frequency of any such interruptions.

7.2 No service level guarantee

7.2.1 Cosmos makes no representations or warranties as to any specific level of availability, uptime, or response time for the Website. No service level agreement applies to the Website. Service levels for the Platform are governed exclusively by the MSA.

7.3 Modifications to the Website

7.3.1 Cosmos reserves the right to modify, suspend, or discontinue the Website or any part of it at any time, with or without notice, including during the Onboarding Flow. Cosmos is not liable to you for any such modification, suspension, or discontinuation.

8.1 General obligations

8.1.1 You agree to use the Website in accordance with these Terms of Use, including the acceptable use provisions in sections 20 to 26, all applicable laws and regulations, and any other instructions or guidelines published by Cosmos on the Website from time to time.

8.1.2 You are responsible for ensuring that all persons who access the Website through your internet connection or devices are aware of these Terms of Use and comply with them.

8.2 User warranties

8.2.1 You represent and warrant to Cosmos that:

• the information you provide to Cosmos through the Website is and will remain accurate, complete, and not misleading;
  
• you will promptly update any information you have provided if it becomes inaccurate or incomplete;
  
• you will not use the Website in a manner that infringes the rights of any third party or that violates any applicable law or regulation;
  
• you have obtained all necessary licences, consents, and approvals required for your use of the Website and for any Onboarding Submission; and
  
• you comply with all applicable sanctions and export control laws as further described in section 17.

8.3 Technical obligations

8.3.1 You agree not to:

• use any automated means, bot, crawler, spider, data-mining tool, or data-gathering device to access or collect data from the Website without Cosmos's prior written consent;
  
• attempt to gain unauthorised access to any part of the Website, its server, or any database, system, or network connected to the Website;
  
• introduce any virus, Trojan horse, worm, logic bomb, or other malicious or technologically harmful material to the Website; or
  
• transmit any unsolicited commercial communications through the Website.

9.1 Cross-reference to the acceptable use provisions

9.1.1 Your use of the Website is subject to the acceptable use provisions in sections 20 to 26, which form part of the agreement between you and Cosmos. You must read and comply with those provisions at all times.

9.2 General prohibition

9.2.1 You must not use the Website for any purpose that is unlawful, fraudulent, harmful, abusive, harassing, threatening, defamatory, obscene, or otherwise objectionable.

9.2.2 Without limiting section 9.1, you must not use the Website:

• to carry out, facilitate, or conceal any unlawful activity;
  
• in breach of any applicable sanctions regime, as further described in section 17;
  
• to infringe the intellectual property rights, privacy rights, or any other legal rights of any person;
  
• in a manner that could damage the reputation or goodwill of Cosmos or any member of the Cosmos Group; or
  
• to engage in any activity that could constitute market manipulation, fraud, money laundering, terrorist financing, or any other financial crime.
  

9.2.3 Breach of this section may result in immediate suspension or termination of your access to the Website in accordance with section 16 and may be referred to law enforcement authorities.

10.1 Ownership

10.1.1 The Website and all Content are owned by or licensed to Cosmos. All intellectual property rights in the Website and Content, including copyright, database rights, trade marks, trade names, logos, service marks, and design rights, are reserved to Cosmos or its licensors.

10.1.2 The Cosmos name, logo, and all related marks and designs are trade marks of Sirius Consulting FZCO. Nothing in these Terms of Use grants you any right to use any trade mark, logo, or trade name of Cosmos.

10.1.3 The full statement of the intellectual property rights subsisting in the Website and Content, and the permissions granted, is set out in the intellectual property provisions in sections 33 to 41.

10.2 Limited licence

10.2.1 Subject to your compliance with these Terms of Use, including the acceptable use provisions in sections 20 to 26, Cosmos grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to:

• access and browse the Website for your personal or internal business purposes; and
  
• download or print individual pages of the Website for those same purposes, provided that you do not alter or modify those pages and that you retain all copyright and proprietary notices.
  

10.2.2 This licence does not permit you to:

• use any Content for commercial purposes without Cosmos's prior written consent;
  
• systematically copy, reproduce, or republish any part of the Website or Content;
  
• create any derivative work based on the Content; or
  
• remove or obscure any copyright notice, trade mark, or other proprietary rights notice on the Website.

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10.3 User Content licence

10.3.1 By submitting any User Content through the Website, you grant Cosmos a non-exclusive, royalty-free, worldwide, perpetual licence to use, copy, store, process, and disclose that User Content to the extent necessary to:

• operate and improve the Website and provide the Services; and
  
• comply with applicable law and any lawful request from a competent authority.
  

10.3.2 You retain ownership of your User Content. The licence granted in section 10.3.1 does not transfer ownership of your User Content to Cosmos.

10.3.3 You represent and warrant that you have all rights necessary to grant the licence in section 10.3.1 and that your User Content does not infringe any third party's rights.

11.1 Third party links

11.1.1 The Website may contain links to third party websites, resources, or services that are not owned or controlled by Cosmos. Cosmos has no control over the content, privacy practices, or terms of any third party website and accepts no responsibility for them.

11.1.2 Links to third party websites are provided for information only and do not constitute an endorsement by Cosmos of those websites or any content, product, or service they offer.

11.1.3 You access any linked third party website entirely at your own risk and subject to that website's own terms and conditions. Cosmos is not responsible for any loss or damage arising from your use of any linked third party website.

11.2 Third party services

11.2.1 The Website may incorporate or interact with third party services, including the payment processing services of Stripe. Your use of any third party service is subject to that third party's own terms of service and privacy policy.

12.1 No advice

12.1.1 Nothing on the Website constitutes legal, tax, accounting, audit, investment, immigration, financial planning, or any other regulated professional advice. The Content is general information only. You should not rely on any Content as advice or guidance specific to your circumstances without obtaining independent professional advice from a suitably qualified adviser.

12.1.2 For the avoidance of doubt, Cosmos does not provide legal services, and nothing on the Website creates a solicitor-client relationship, a lawyer-client relationship, or any other professional advisory relationship between you and Cosmos.

12.1.3 The full statement of the scope and limitations of the Content is set out in the disclaimer and no advice provisions in sections 27 to 32.

12.2 No warranty

12.2.1 To the fullest extent permitted by applicable law, Cosmos provides the Website and Content on an "as is" and "as available" basis without any representation or warranty, express or implied, including any warranty of:

• merchantability or fitness for a particular purpose;
  
• accuracy, completeness, timeliness, or reliability of any Content;
  
• non-infringement;
  
• error-free operation or compatibility with your equipment or software; or
  
• the absence of viruses or other harmful components.
  

12.2.2 Cosmos does not warrant that the Website or any Content is free from inaccuracies, errors, or omissions, or that any such inaccuracies, errors, or omissions will be corrected.

12.3 AI-generated content

12.3.1 Certain Content on the Website may be generated or assisted by artificial intelligence. AI-generated content may contain inaccuracies, errors, or omissions. You must not rely on AI-generated content as professional or regulatory advice without independent verification. For further information, please refer to the Responsible AI Notice on the Website.

13.1 Aggregate cap

13.1.1 Subject to section 13.3, Cosmos's aggregate liability to you under or in connection with these Terms of Use, whether in contract, tort including negligence, breach of statutory duty, or otherwise, in respect of all claims arising in any period of twelve consecutive months is limited to the greater of:

• the total fees paid by you to Cosmos in connection with the Website in the twelve calendar months immediately preceding the event giving rise to the claim; and
  
• one thousand US dollars (USD 1,000), or the equivalent in the currency of payment at the exchange rate prevailing on the date the claim arises.

13.2 Exclusion of consequential loss

13.2.1 Subject to section 13.3, Cosmos is not liable to you for any:

• loss of profits;
  
• loss of revenue;
  
• loss of business;
  
• loss of data or corruption of data;
  
• loss of goodwill or reputation;
  
• wasted management or staff time;
  
• indirect or consequential loss; or
  
• special or exemplary damages,
  

whether or not Cosmos had been advised of the possibility of such loss.

13.3 Exceptions

13.3.1 Nothing in these Terms of Use limits or excludes Cosmos's liability for:

• fraud or fraudulent misrepresentation;
  
• death or personal injury caused by Cosmos's negligence;
  
• wilful misconduct; or
  
• any liability that cannot lawfully be excluded or limited under applicable law, including mandatory consumer protection laws applicable to consumers resident in the EU, the EEA, the UK, or Singapore.

13.4 Consumer rights

13.4.1 If you are a consumer resident in the EU, the EEA, the UK, or Singapore, nothing in this section 13 limits or excludes any right or remedy available to you under mandatory consumer protection laws applicable in your jurisdiction of residence.

14.1 User indemnity

14.1.1 You agree to indemnify, defend, and hold harmless Cosmos and its Affiliates, directors, officers, employees, agents, licensors, and service providers from and against all claims, liabilities, losses, damages, costs, and expenses, including reasonable legal fees, arising out of or in connection with:

• your use of the Website in breach of these Terms of Use;
  
• any Onboarding Submission made by you that contains inaccurate, incomplete, or misleading information;
  
• your breach of any representation or warranty made in these Terms of Use;
  
• your infringement of any third party's intellectual property rights, privacy rights, or other legal rights; or
  
• your violation of any applicable law or regulation.
  

14.1.2 Cosmos will promptly notify you of any claim for which it seeks indemnity, will give you reasonable control of the defence and settlement of that claim, subject to Cosmos's right to approve any settlement that imposes obligations on Cosmos, and will provide reasonable cooperation at your expense.

14.2 Cosmos's obligations

14.2.1 Cosmos will use commercially reasonable efforts not to make any admission or settlement in relation to a claim to which your indemnity under section 14.1 applies without your prior written consent, which must not be unreasonably withheld or delayed.

15.1 Definition

15.1.1 A Force Majeure Event means any event or circumstance beyond a party's reasonable control, including acts of God, natural disasters, pandemic or epidemic including any government response thereto, war, civil unrest, terrorism, government action, regulatory change, strikes or labour disputes, failure of third party systems or networks, or internet or telecommunications failures.

15.2 Effect

15.2.1 Neither party is in breach of these Terms of Use or liable to the other for any delay or failure to perform any obligation that is caused by a Force Majeure Event, provided that the affected party:

• gives notice to the other party as soon as reasonably practicable of the Force Majeure Event and its expected duration; and
  
• uses reasonable endeavours to mitigate the effect of the Force Majeure Event and to resume performance as soon as practicable.
  

15.2.2 Force Majeure Events do not affect payment obligations for Services already rendered.

16.1 Cosmos's right to suspend or terminate

16.1.1 Cosmos may, immediately and without prior notice or liability to you, suspend or terminate your access to the Website if:

• you breach any provision of these Terms of Use, including the acceptable use provisions in sections 20 to 26;
  
• Cosmos is required to do so by applicable law, regulation, or the order of a competent authority;
  
• your use of the Website poses a risk to the security, integrity, or availability of the Website or the Cosmos Group's systems;
  
• Cosmos has reasonable grounds to believe you are a sanctioned person or are acting on behalf of a sanctioned person, as described in section 17; or
  
• Cosmos, in its reasonable discretion, determines that it is necessary or appropriate to do so for any other legitimate business reason.
  

16.1.2 Cosmos may give notice of suspension or termination in writing to the email address you have provided, where practicable, but is not required to give advance notice in the circumstances described in section 16.1.1.

16.2 Your right to stop using the Website

16.2.1 You may stop using the Website at any time without notice to Cosmos. Your obligation to pay for Services already agreed remains unaffected.

16.3 Effect of termination

16.3.1 On termination of these Terms of Use, howsoever arising, the following provisions continue in force: section 1 (Interpretation and definitions), section 10 (Intellectual property on the Website), section 12 (Disclaimers), section 13 (Limitation of liability), section 14 (Indemnity), section 18 (Anti-bribery and anti-corruption), section 19 (Confidentiality), the intellectual property provisions in sections 33 to 41, the disclaimer and no advice provisions in sections 27 to 32, the closing provisions in sections 42 to 48, and the definitions appendix in section 49.

16.3.2 Termination does not affect accrued rights, remedies, obligations, or liabilities as at the date of termination.

17.1 Sanctions compliance

17.1.1 You represent and warrant that:

• you are not, and are not acting on behalf of, any person or entity that is designated on the Specially Designated Nationals and Blocked Persons List maintained by the United States Office of Foreign Assets Control (OFAC), subject to any sanction, restriction, or embargo administered or enforced by the European Union, subject to any sanction, restriction, or embargo administered or enforced by His Majesty's Treasury in the United Kingdom, or subject to any sanction, restriction, or prohibition administered or enforced by the UAE Supreme Council for National Security or any other competent UAE authority (together, Sanctioned Persons);
  
• you are not located in, organised under the laws of, or ordinarily resident in any jurisdiction that is subject to comprehensive sanctions administered or enforced by OFAC, the EU, or HM Treasury; and
  
• your use of the Website will not cause Cosmos or any member of the Cosmos Group to violate any applicable sanctions law or regulation.

17.2 Prohibited use by sanctioned persons

17.2.1 Access to and use of the Website by any Sanctioned Person is strictly prohibited. Cosmos reserves the right to block or restrict access to the Website from any jurisdiction subject to comprehensive sanctions.

17.3 Export controls

17.3.1 You agree to comply with all applicable export control laws and regulations, including those administered by the United States Bureau of Industry and Security and the UAE Ministry of Economy.

17.3.2 You must not export, re-export, transfer, or use the Website or any Content in violation of any applicable export control law or regulation.

17.4 Notification

17.4.1 If you become aware that you or any person associated with an Onboarding Submission may be a Sanctioned Person or otherwise subject to sanctions or export control restrictions, you must notify Cosmos immediately at legal@cosmos.global.

18.1 Cosmos's position and User obligations

18.1.1 Cosmos is committed to operating to the highest ethical and legal standards and maintains a zero-tolerance approach to bribery and corruption. The detailed statement of Cosmos's approach to anti-bribery and anti-corruption compliance is set out on the Legal and compliance page.

18.1.2 You agree that, in connection with your use of the Website and any resulting engagement with Cosmos, you will not make, offer, promise, authorise, accept, request, or receive any payment, financial advantage, or other benefit that would constitute bribery or corruption under any applicable law, including the UK Bribery Act 2010, UAE Federal Law No. 31 of 2021 on Issuance of the Crimes and Penalties Law, or any other applicable anti-corruption legislation.

18.1.3 If you become aware of any actual or suspected bribery, corruption, or facilitation of tax evasion involving Cosmos or any member of the Cosmos Group, you must report it to legal@cosmos.global.

19.1 Confidentiality

19.1.1 Given the nature of the Website as a publicly accessible marketing and onboarding platform, these Terms of Use do not impose general obligations of confidentiality. However, to the extent that either party discloses to the other any information that is expressly designated as confidential or that by its nature is plainly confidential, the receiving party agrees to:

• keep such information strictly confidential and not disclose it to any third party without the disclosing party's prior written consent, except as required by applicable law or regulatory authority; and
  
• use such information solely for the purpose for which it was disclosed.

19.2 Data protection

19.2.1 Personal Data submitted by you through the Website or the Onboarding Flow is processed by Sirius Consulting FZCO acting as controller for the purposes of applicable data protection law.

19.2.2 The full details of how Cosmos processes your Personal Data, your rights as a data subject, the legal bases for processing, international transfers, cookies, and the exercise of data subject rights are set out in the Privacy policy published on the Website. Where Cosmos processes Personal Data on your behalf in connection with the Services, the terms of that processing are set out in the Data processing addendum. You should read the Privacy policy carefully before submitting any Personal Data through the Website.

20.1 Application

20.1.1 Sections 20 to 26 set out the acceptable use provisions that tell you what you may and may not do when using the Website. They form part of these Terms of Use and apply to all Users, including persons browsing the Website, persons completing the Onboarding Flow, and persons making payments through the Website.

20.1.2 By accessing or using the Website, you agree to comply with the acceptable use provisions. If you do not agree, you must leave the Website immediately and refrain from using it.

20.2 Relationship with other provisions and pages

20.2.1 The acceptable use provisions should be read together with the intellectual property provisions in sections 33 to 41 and the Privacy policy published on the Website.

20.2.2 To the extent of any inconsistency between the acceptable use provisions and the other provisions of these Terms of Use in relation to the use of the Website, the other provisions of these Terms of Use prevail.

21.1 Unlawful use

21.1.1 You must not use the Website for any purpose that is unlawful under any applicable law or regulation, including the laws of the United Arab Emirates, the laws of the Abu Dhabi Global Market, and the laws of your jurisdiction of residence or operation.

21.1.2 Without limiting section 21.1.1, you must not use the Website to:

• carry out, solicit, facilitate, or promote any activity that constitutes a criminal offence or that gives rise to civil liability in any jurisdiction;
  
• obtain or attempt to obtain goods, services, information, or access by deception, impersonation, or misrepresentation;
  
• engage in or facilitate market manipulation, insider trading, or any other conduct that contravenes applicable financial services or securities laws; or
  
• evade or assist in the evasion of any tax, duty, or levy under applicable law, including the corporate tax and value added tax regimes applicable in the UAE.

21.2 Infringement of third party rights

21.2.1 You must not use the Website to infringe or facilitate the infringement of the intellectual property rights of any third party, including copyright, trade mark, patent, design rights, or database rights. Further details on the intellectual property rights subsisting in the Website and Content are set out in the intellectual property provisions in sections 33 to 41.

21.2.2 You must not use the Website to infringe the privacy, confidentiality, or data protection rights of any person, including by submitting another person's Personal Data without authority or without the required consent.

21.2.3 You must not collect, harvest, or use any information obtained from the Website in a manner that infringes the rights of any person.

21.3 Distribution of malware and harmful code

21.3.1 You must not upload, transmit, or introduce to the Website any:

• virus, Trojan horse, worm, logic bomb, spyware, adware, ransomware, or other malicious or technologically harmful software or code;
  
• material that contains corrupted data or that is designed to interfere with, disrupt, or damage the operation of any computer system or software; or
  
• unsolicited bulk communications, including spam, phishing communications, or fraudulent solicitations.

21.4 Scraping and automated access

21.4.1 You must not use any automated means to access, monitor, scrape, harvest, or collect data from the Website without Cosmos's prior written consent, including:

• robots, spiders, crawlers, scrapers, or data-mining tools;
  
• automated scripts or software that mimic human browsing; or
  
• any technique that places excessive or unreasonable demand on Cosmos's servers or infrastructure.
  

21.4.2 Cosmos reserves the right to block any IP address, user agent, or automated process that appears to be scraping or placing unreasonable load on the Website.

21.5 Reverse engineering and circumvention of security

21.5.1 You must not attempt to:

• reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code, algorithms, or structure of any part of the Website;
  
• circumvent, disable, bypass, or interfere with any security feature, access control, authentication mechanism, or technical protection measure on the Website;
  
• probe, scan, or test the vulnerability of the Website or any network or system connected to it without Cosmos's prior written authorisation; or
  
• access any part of the Website, its servers, or any database or system connected to the Website to which you have not been granted access.

21.6 Impersonation and fraud

21.6.1 You must not:

• impersonate any person or entity, including any Cosmos employee, director, officer, or representative, any government official, or any other User;
  
• misrepresent your identity, your organisation, your authority to act, or your jurisdiction of residence or operation in any Onboarding Submission or other communication with Cosmos;
  
• create false or misleading impressions about yourself or your business for the purpose of obtaining Services from Cosmos or otherwise; or
  
• forge, alter, or misrepresent any document, identity credential, or corporate record in connection with your use of the Website.

21.7 Harassment and harmful conduct

21.7.1 You must not use the Website to engage in, encourage, or facilitate conduct that is:

• abusive, threatening, harassing, or intimidating toward any person;
  
• defamatory, libellous, or likely to cause unwarranted harm to the reputation of any person; or
  
• designed to cause distress, alarm, or harassment to any person.

21.8 Sanctions violations

21.8.1 You must not use the Website in violation of any applicable sanctions law or regulation, including those administered or enforced by:

• the United States Office of Foreign Assets Control (OFAC), including the Specially Designated Nationals and Blocked Persons List and any sectoral sanctions;
  
• the European Union;
  
• His Majesty's Treasury in the United Kingdom; or
  
• the UAE Supreme Council for National Security or any other competent UAE authority.
  

21.8.2 You must not use the Website to facilitate or conceal any transaction or dealing with or for the benefit of any Sanctioned Person, or to circumvent any applicable sanctions programme.

21.9 Money laundering and terrorist financing

21.9.1 You must not use the Website to:

• engage in, facilitate, or conceal any activity that constitutes money laundering under any applicable law, including UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations and its implementing regulations, and the Proceeds of Crime Act 2002 (UK);
  
• finance, facilitate, or promote terrorism or any terrorist organisation; or
  
• transfer, conceal, disguise, or convert any property that represents the proceeds of criminal conduct.

21.10 Facilitation of tax evasion

21.10.1 You must not use the Website to facilitate the evasion of any tax, duty, or levy, whether in the UAE or any other jurisdiction, including by making false representations in connection with an Onboarding Submission or otherwise.

21.10.2 Cosmos maintains a zero-tolerance approach to the facilitation of tax evasion and reserves the right to report any suspected activity to the relevant authorities.

22.1 Application

22.1.1 This section applies to all User Content submitted during the Onboarding Flow or otherwise through the Website.

22.2 Accuracy and completeness

22.2.1 All User Content submitted through the Onboarding Flow must be accurate, complete, and not misleading in any material respect. You must not submit information that you know or suspect to be false.

22.2.2 Documents submitted as part of an Onboarding Submission must be genuine and unaltered. Submission of a forged, altered, or otherwise inauthentic document is a serious breach of these provisions and may constitute a criminal offence.

22.3 Third party content and personal data

22.3.1 Where User Content includes Personal Data relating to third parties, you confirm that you have the authority to share that information with Cosmos and, where required by applicable data protection law, that you have obtained the necessary consents.

22.3.2 Where User Content includes any document, image, or other material belonging to a third party, you confirm that you have the right to submit that material and that doing so does not infringe any third party's intellectual property rights.

22.4 Prohibited content

22.4.1 You must not submit any User Content that:

• is obscene, offensive, discriminatory, or otherwise objectionable;
  
• contains, depicts, or promotes violence or harm toward any person or group;
  
• relates to or is designed to facilitate any prohibited activity described in section 21; or
  
• constitutes unsolicited commercial or promotional material.

23.1 Your security obligations

23.1.1 You are responsible for maintaining the security and confidentiality of any information you submit through the Website, including any login credentials used in connection with the Platform.

23.1.2 You must not attempt to access the Website or any connected system, database, or infrastructure in any manner that is not authorised by Cosmos or that could interfere with the security or integrity of the Website.

23.1.3 If you become aware of any security vulnerability or incident affecting the Website, you must not exploit it and must report it promptly in accordance with section 23.2.

23.2 Responsible disclosure programme

23.2.1 Cosmos maintains a responsible disclosure programme. If you discover a security vulnerability in the Website, you are encouraged to report it to Cosmos at security@cosmos.global, providing:

• a clear description of the vulnerability and the steps required to reproduce it;
  
• any supporting evidence, such as screenshots or proof-of-concept code; and
  
• your contact details, if you are willing to receive follow-up queries.
  

23.2.2 Cosmos will acknowledge receipt of any responsible disclosure report within five Business Days and will work in good faith to investigate and address any genuine vulnerability.

23.2.3 Cosmos does not offer monetary reward under this programme, but reserves the right to do so at its discretion in respect of a significant vulnerability that is reported in good faith and that Cosmos is not already aware of.

23.2.4 The responsible disclosure programme does not authorise you to:

• access, copy, modify, or delete any data belonging to Cosmos or any User;
  
• disrupt the operation of the Website; or
  
• disclose any vulnerability publicly before Cosmos has had a reasonable opportunity to address it.

24.1 Cosmos's right to investigate

24.1.1 Cosmos reserves the right to investigate any actual or suspected breach of the acceptable use provisions or any activity that may affect the security, integrity, or availability of the Website.

24.1.2 In connection with any investigation, Cosmos may:

• review, retain, and disclose any User Content, Onboarding Submission, or other information submitted by or associated with you, to the extent permitted by applicable law;
  
• cooperate fully with any law enforcement authority, regulatory authority, or competent court that requests information or assistance in connection with any activity arising out of or connected to your use of the Website; and
  
• preserve and produce records as required by applicable law, court order, or regulatory direction.

24.2 Cooperation with law enforcement

24.2.1 Cosmos will cooperate with law enforcement authorities and regulatory bodies in accordance with applicable law, including by providing information about Users where required by a valid court order, search warrant, regulatory direction, or other lawful request.

24.2.2 Cosmos will use reasonable endeavours to notify the relevant User of a law enforcement request before complying with it, except where prohibited from doing so by applicable law, court order, or the terms of the request.

24.3 Enforcement rights

24.3.1 If Cosmos determines, in its reasonable judgement, that you have breached or may have breached the acceptable use provisions, Cosmos may, immediately and without prior notice:

• suspend or terminate your access to the Website;
  
• remove or disable access to any User Content associated with you;
  
• take legal action against you, including seeking injunctive relief or damages; or
  
• refer the matter to relevant law enforcement or regulatory authorities.
  

24.3.2 Cosmos's rights under this section are in addition to, and do not limit, any rights or remedies available under the other provisions of these Terms of Use or applicable law.

25.1 How to report

25.1.1 If you become aware of any use of the Website that you believe breaches the acceptable use provisions, or if you wish to report abuse, fraudulent activity, or security concerns, please contact us at abuse@cosmos.global.

25.1.2 Security vulnerabilities should be reported separately at security@cosmos.global in accordance with the responsible disclosure programme set out in section 23.2.

25.1.3 When reporting abuse, please provide:

• a description of the activity you are reporting;
  
• any supporting evidence, for example screenshots, URLs, or dates and times; and
  
• your contact details, if you are willing to receive follow-up queries.
  

25.1.4 Cosmos will use commercially reasonable efforts to acknowledge abuse reports within five Business Days and to investigate credible reports promptly. Cosmos is not obliged to disclose the outcome of any investigation to the person who submitted the report.

26.1 Suspension and termination

26.1.1 A breach of the acceptable use provisions is a material breach of these Terms of Use and may result in the immediate suspension or termination of your access to the Website, without prior notice and without liability to you, in accordance with the termination and suspension provisions in section 16.

26.2 Referral to authorities

26.2.1 Where a breach of the acceptable use provisions involves or may involve criminal conduct, fraud, sanctions violations, money laundering, terrorist financing, or any other serious matter, Cosmos reserves the right to refer the matter to relevant law enforcement authorities, regulatory bodies, or financial intelligence units, both in the UAE and in any other relevant jurisdiction.

26.3 Indemnity for harm caused

26.3.1 You agree to indemnify, defend, and hold harmless Cosmos and its Affiliates, directors, officers, employees, agents, and service providers from and against all claims, liabilities, losses, damages, costs, and expenses, including reasonable legal fees, arising out of or in connection with any breach of the acceptable use provisions by you, in accordance with the indemnity provisions in section 14.

26.3.2 This includes any claim brought by a third party whose rights have been infringed as a result of your use of the Website in breach of the acceptable use provisions.

27.1 Application

27.1.1 Sections 27 to 32 set out the basis on which the Content is provided and the disclaimer and no advice position that applies to it. They form part of these Terms of Use. By accessing or using the Website, you confirm that you have read and understood these provisions and that you accept them. If you do not accept them, you must leave the Website immediately.

27.1.2 These provisions apply to all persons who access or use the Website, including persons using the Website for general information, persons completing the Onboarding Flow, and persons who make payments on the Website.

27.1.3 These provisions do not apply to your use of the Platform. The Platform is governed by the MSA and associated product documentation.

28.1 General no-advice position

28.1.1 Nothing on the Website, including any text, graphic, tool, output, Onboarding Flow prompt, or other material, constitutes, or should be construed as constituting, any form of professional advice of any kind. Without limiting the generality of the foregoing, the Content does not constitute:

• legal advice of any kind, including advice on corporate law, commercial law, employment law, litigation, or any other area of law;
  
• tax advice, including advice on UAE corporate tax, value added tax, transfer pricing, international tax structuring, or any other tax matter;
  
• accounting or audit advice, including any form of assurance, financial statement preparation guidance, or statutory audit opinion;
  
• investment advice or financial advice within the meaning of any applicable financial services law or regulation, including any advice on the acquisition, disposal, or management of any financial instrument or investment product;
  
• immigration advice, including advice on residence visas, Golden Visas, investor visas, or any other immigration route in any jurisdiction
  
• financial planning advice; or
  
• any other advice that is regulated by a professional regulatory body in any jurisdiction.

28.2 General information only

28.2.1 The Content is provided for general information purposes only. It is intended to give Users a broad, non-exhaustive overview of the types of corporate services and compliance matters that Cosmos addresses through its platform and its network of professional service providers.

28.2.2 The Content does not take account of your specific circumstances, objectives, financial situation, risk appetite, or legal and regulatory position. It cannot and does not constitute advice tailored to you.

28.2.3 You must not treat the Content as a substitute for obtaining independent professional advice from a suitably qualified and appropriately regulated adviser who is familiar with your specific circumstances and jurisdiction.

28.3 No solicitor-client or advisory relationship

28.3.1 Nothing on the Website, and no interaction between you and Cosmos through the Website, including any interaction through the Onboarding Flow, creates, or is intended to create:

• a solicitor-client relationship, a lawyer-client relationship, or any other professional legal relationship between you and Cosmos or any of its Affiliates;
  
• a financial advisory relationship or any other regulated advisory relationship between you and Cosmos or any of its Affiliates; or
  
• any duty of care owed by Cosmos to you in connection with the Content.
  

28.3.2 The Cosmos Group does not employ lawyers in private practice and does not provide legal services within the meaning of any applicable legal profession legislation. Where Cosmos introduces you to external professional advisers, those advisers are independent of Cosmos and any engagement between you and an external adviser is governed exclusively by the terms agreed between you and that adviser.

29.1 General position

29.1.1 Sirius Consulting FZCO and its Affiliates are not authorised or regulated by any financial services regulator in any jurisdiction. Nothing on the Website is provided in the course of a regulated activity. Cosmos works with regulated partners who provide regulated services to clients directly under their own terms and regulatory permissions. For example, Clara is regulated in the Abu Dhabi Global Market and the Dubai International Financial Centre, and any regulated services provided by Clara to clients are provided by Clara under its own regulatory authorisations, not by Cosmos. This position applies unless expressly and specifically stated otherwise in accordance with section 29.2.

29.1.2 Nothing on the Website constitutes:

• a financial promotion or financial communication within the meaning of any applicable financial services legislation;
  
• an offer of, or invitation to subscribe for, any financial instrument, investment, or regulated product;
  
• a recommendation or solicitation to buy, sell, or hold any financial instrument or investment; or
  
• the carrying on of a regulated activity within the meaning of any applicable financial services legislation.
  

29.1.3 Users must not rely on the Content as constituting regulated financial advice, regulated investment advice, regulated credit advice, or any other regulated activity. Any such reliance is at the User's sole risk.

29.2 Exceptions where an Affiliate is authorised

29.2.1 Where any Affiliate of Sirius Consulting FZCO holds a specific authorisation, licence, or permission from a financial services regulatory authority in a particular jurisdiction to carry on regulated activities, that Affiliate will state that authorisation expressly on its own website, letterhead, and engagement documentation.

29.2.2 The existence of such an authorisation in respect of a specific Affiliate does not extend to Sirius Consulting FZCO as a whole or to any other Affiliate that does not itself hold the relevant authorisation.

29.2.3 Any regulated activity carried on by an authorised Affiliate is subject to the supervision and rules of the relevant regulator and is governed by the terms of that Affiliate's specific engagement documentation, not by these Terms of Use.

29.2.4 If you are in any doubt as to whether an Affiliate is authorised to carry on a regulated activity relevant to you, you should contact legal@cosmos.global before proceeding.

30.1 Use of artificial intelligence

30.1.1 Certain Content on the Website, including elements of the Onboarding Flow and supporting materials, may be generated or assisted by artificial intelligence tools, large language models, or machine learning systems (together, AI Tools).

30.1.2 AI-generated or AI-assisted Content:

• may contain factual inaccuracies, errors, omissions, or outdated information;
  
• may reflect biases or limitations inherent in the underlying AI model;
  
• does not constitute professional advice of any kind, regardless of how it is presented; and
  
• must not be relied upon as a substitute for human expert review or independent professional advice.
  

30.1.3 Cosmos endeavours to review and quality-check AI-assisted Content before publication, but does not warrant or guarantee the accuracy, completeness, or currency of any AI-generated output.

30.1.4 For a full explanation of how Cosmos uses AI, the limitations of AI outputs, and the safeguards Cosmos applies, please refer to the Responsible AI Notice published on the Website.

30.1.5 Cosmos does not itself train, develop, or fine-tune any AI model, and does not use User inputs or Onboarding Submissions to train any model that Cosmos controls. Cosmos delivers AI features using third-party model providers, currently OpenAI, Anthropic, and Mistral AI. Inputs sent to those providers may be used by them to train or improve their models. You should not enter confidential information, or any special category personal data, into the AI-assisted features. Further details are set out in the Responsible AI Notice and the Privacy policy.