AI Terms

01Overview and Scope

What these AI Terms cover and how they relate to the rest of the Agreement.

1.1 The Bluto platform is an AI-first product. AI-powered features are present throughout the Service, including financial model generation, pitch deck drafting, cap table analysis, business planning assistance, conversational AI features, and document generation tools. These AI Terms apply to all such features, collectively referred to in this document as "AI Features".

1.2 "AI Feature" means any feature of the Service that uses a large language model, machine learning model, or other AI technology to generate, analyse, summarise, or assist in the production of outputs based on inputs provided by the Subscriber or an Authorised User.

1.3 "AI Output" means any text, data, analysis, projection, document, or other content generated by an AI Feature in response to an input from the Subscriber or an Authorised User.

1.4 "AI Input" means any text, data, document, or other content submitted by the Subscriber or an Authorised User to an AI Feature for the purpose of generating an AI Output.

1.5 These AI Terms apply to all Subscribers regardless of Subscription Plan. The specific AI Features available to a Subscriber depend on their Subscription Plan and Credit allocation.

1.6 Bluto may update, replace, or discontinue individual AI Features from time to time as the underlying technology evolves. Where a change materially affects the functionality available to a paid Subscriber, Bluto will provide reasonable notice in accordance with clause 2.4 of the Terms of Service.

02Nature of AI Outputs

What AI Outputs are, their inherent limitations, and what the Subscriber must understand before relying on them.

2.1 AI Outputs are generated by probabilistic models and are not deterministic. The same input may produce different outputs at different times. Outputs are generated based on the AI Input provided and the model's training data and are not verified by Bluto before being presented to the Subscriber.

2.2 The Subscriber acknowledges and accepts the following limitations of AI Outputs:

• AI Outputs may contain errors, omissions, hallucinations, or information that is inaccurate, incomplete, misleading, or out of date
• AI Outputs do not reflect real-time information unless the relevant AI Feature is explicitly described as using live data sources
• AI Outputs generated in relation to financial projections, valuations, or business performance are estimates based on the inputs and assumptions provided and are not guarantees or predictions of future performance
• AI Outputs generated in relation to regulatory, tax, or compliance matters reflect the model's understanding as at the date of the interaction and may not reflect changes in law, guidance, or practice that have occurred since the model's training data was compiled
• AI Outputs are not a substitute for independent professional advice or for verification against primary and official sources

The Subscriber is solely responsible for verifying the accuracy, completeness, and suitability of all AI Outputs before using, distributing, or relying on them for any purpose. Bluto does not review or validate AI Outputs before they are delivered to the Subscriber.

2.3 AI Outputs generated by the Service do not constitute financial, tax, legal, accounting, regulatory, or any other form of professional advice. See clause 07 for the full scope of this disclaimer.

03Customer Content and Model Training

How Bluto handles AI Inputs and Customer Content in relation to AI model development and training.

3.1 Bluto shall not use the substantive content of AI Inputs -- including the Subscriber's financial data, revenue assumptions, business plans, pitch deck content, cap table data, or any other Customer Content submitted to an AI Feature -- to train, fine-tune, or improve any AI or machine learning model, whether operated by Bluto or by a third-party model provider, without the Subscriber's prior written consent.

3.2 This commitment extends to Bluto's contractual arrangements with third-party model providers. Bluto shall not engage a model provider that requires the right to use customer inputs for model training as a condition of its service, and shall maintain contractual protections with each model provider confirming that AI Inputs are not used for training purposes.

3.3 Where Bluto wishes to use Customer Content for model training or improvement beyond the scope permitted under clause 3.1, it shall seek the Subscriber's explicit written consent before doing so. Such consent shall be specific to the purpose and data in question and shall be freely given, separate from acceptance of these AI Terms.

3.4 Nothing in this clause 03 restricts Bluto's right to collect and use AI interaction metadata and Usage Data in accordance with clause 04.

04Usage Data and AI Interaction Metadata

How Bluto uses data about how the Subscriber interacts with AI Features.

4.1 Bluto collects Usage Data in connection with the Subscriber's use of AI Features. Usage Data in this context includes AI interaction metadata -- that is, data about how AI Features are used rather than the substantive content of what is submitted to them.

4.2 AI interaction metadata may include:

4.2.1 the structure, length, and category of AI Inputs submitted to AI Features, without retaining the full content of those inputs;

4.2.2 the sequence and pattern of interactions within AI Features, including the number of refinement steps and feature navigation paths;

4.2.3 session-level data including the duration of AI Feature interactions and the Credit consumption associated with each session; and

4.2.4 error and feedback signals generated during AI Feature interactions, including explicit feedback provided by the Subscriber.

4.3 Bluto uses AI interaction metadata to operate, maintain, and improve AI Features and to develop new AI-powered capabilities within the Service. Bluto may derive aggregated, anonymised insights from AI interaction metadata across the platform, provided that such insights do not permit identification of any individual Subscriber or their Customer Content.

4.4 AI interaction metadata is distinct from Customer Content. The collection and use of AI interaction metadata under this clause 04 does not constitute use of Customer Content for model training and is not subject to the restrictions in clause 03.

4.5 Bluto does not retain the full text of AI Inputs beyond what is necessary to generate the AI Output and to provide the Service. AI Inputs are not stored in a form that permits retrospective access by Bluto personnel except where required for a confirmed security incident investigation or as required by applicable law.

05Third-Party Model Providers

The role of third-party AI model providers and Bluto's obligations in relation to them.

5.1 AI Features within the Service are powered in whole or in part by third-party AI model providers. The specific providers used may vary by feature and may change over time as the AI landscape evolves and Bluto updates its technology stack.

5.2 When the Subscriber submits an AI Input to an AI Feature, that input is transmitted to the relevant model provider for processing. The model provider processes the input and returns an AI Output, which Bluto then delivers to the Subscriber.

5.3 Bluto applies the following criteria before engaging any third-party model provider:

5.3.1 The provider must be willing to enter into a data processing agreement with Bluto that imposes equivalent data protection obligations to those applicable to Bluto under the Data Processing Agreement at bluto.ai/legal/dpa.

5.3.2 The provider must confirm that AI Inputs submitted by Bluto's customers will not be used to train or improve the provider's models.

5.3.3 The provider must maintain security measures appropriate to the sensitivity of the data being processed, as assessed by Bluto in accordance with its sub-processor due diligence process.

5.4 A current list of AI model providers engaged as sub-processors, including their location and the AI Features they power, is included in the Sub-Processor List at bluto.ai/legal/subprocessors.

5.5 The Subscriber acknowledges that AI model providers operate their own infrastructure and that Bluto's ability to control or direct the technical operation of a model provider's systems is limited to what is agreed in the relevant contractual arrangements. Bluto shall notify the Subscriber of any material change to an AI model provider in accordance with clause 4.3 of the Data Processing Agreement.

06Subscriber Obligations

The obligations of the Subscriber in connection with its use of AI Features.

6.1 The Subscriber shall use AI Features only for lawful purposes and in accordance with these AI Terms, the Terms of Service, and the Acceptable Use Policy at bluto.ai/legal/aup.

6.2 The Subscriber shall not use AI Features to:

• generate AI Outputs that the Subscriber intends to use to deceive, defraud, or mislead investors, lenders, regulatory authorities, or any other third party
• represent AI Outputs as having been independently prepared or verified by a qualified professional unless they have been reviewed and endorsed by one
• circumvent, replace, or substitute for professional advice in relation to matters requiring regulatory authorisation or specialist expertise, including financial advice, tax advice, and legal advice
• generate AI Outputs for distribution to third parties without applying appropriate verification and, where the outputs relate to regulated matters, without obtaining independent professional review
• probe, test, or attempt to extract information about the structure, behaviour, weights, or configuration of any AI model used to power AI Features

The restrictions in this clause 6.2 are in addition to, and do not limit, the prohibited conduct set out in clause 4 of the Acceptable Use Policy.

6.3 The Subscriber shall not submit the following categories of data as AI Inputs unless it has a documented lawful basis for doing so and has notified Bluto accordingly:

• special category personal data as defined under UK GDPR, including data revealing health conditions, racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric data, or data concerning sexual orientation
• personal data of individuals who have not been informed that their data may be submitted to an AI Feature
• data subject to legal privilege, court order, or regulatory restriction that prohibits its submission to a third-party system

Where the Subscriber is uncertain whether a category of data may be submitted to an AI Feature, it should contact [email protected] before doing so.

6.4 The Subscriber is responsible for ensuring that all Authorised Users who access AI Features are aware of the limitations of AI Outputs described in clause 02, the obligations in this clause 06, and the disclaimer in clause 07.

07Regulatory and Professional Advice Disclaimer

The scope of Bluto's disclaimer in relation to AI Outputs and regulated matters.

7.1 AI Outputs generated by AI Features do not constitute professional advice of any kind. In particular, AI Outputs do not constitute:

• financial advice regulated by the Financial Conduct Authority or any equivalent regulatory body in any jurisdiction
• tax advice in relation to HMRC requirements, self-assessment, corporation tax, VAT, or any other tax matter in any jurisdiction
• legal advice in relation to any matter of English law or the law of any other jurisdiction
• accounting advice prepared in accordance with UK Generally Accepted Accounting Practice, International Financial Reporting Standards, or any other accounting framework
• regulatory advice in relation to Companies House obligations, SEIS or EIS eligibility, FCA authorisation requirements, or any other regulatory matter

This disclaimer applies regardless of the apparent specificity or confidence of an AI Output, and regardless of the Subscriber's level of expertise in the relevant subject matter. Bluto makes no representation that AI Outputs are accurate, current, or appropriate for the Subscriber's specific circumstances.

7.2 The Subscriber should seek advice from qualified and appropriately authorised professionals -- including chartered accountants, tax advisers, solicitors, and FCA-authorised financial advisers -- before making decisions based on AI Outputs, sharing AI Outputs with investors or lenders, or submitting AI Outputs to any regulatory authority or government body.

7.3 AI Outputs relating to regulatory, tax, or compliance matters are generated based on the model's training data and reflect the state of the relevant rules as understood by the model at the time of its training. They may not reflect subsequent changes in primary legislation, HMRC guidance, Companies House requirements, FCA rules, or any other regulatory framework. The Subscriber is responsible for verifying all such outputs against current official sources before relying on them.

08Liability

The limits on Bluto's liability in connection with AI Features and AI Outputs.

8.1 Bluto's liability in connection with AI Features and AI Outputs is subject to the limitations and exclusions set out in clause 11 of the Terms of Service. The limitations in clause 11 of the Terms of Service apply in full to any claim arising from or in connection with an AI Output, including any claim arising from an AI Output that is inaccurate, incomplete, misleading, or out of date.

8.2 Without prejudice to the generality of clause 11 of the Terms of Service, Bluto shall not be liable for any loss or damage arising from the Subscriber's reliance on an AI Output without independent verification, including any loss arising from a decision made on the basis of an AI Output that is subsequently found to be incorrect.

8.3 Nothing in these AI Terms excludes or limits Bluto's liability to the extent that it cannot lawfully be excluded or limited under applicable law, including the Consumer Rights Act 2015.

8.4 These AI Terms do not affect any statutory rights the Subscriber may have as a consumer under applicable law.