1. About Cleo
Cleo is operated by CLFNCE OÜ (“Cleo,” “we,” “us,” “our”), a company registered in Estonia under company number 17165857, VAT identification number EE102826959, with its registered office at Harju maakond, Tallinn, Kesklinna linnaosa, Järvevana tee 9, 11314, Estonia.
These Terms of Use (“Terms”) govern your access to and use of the Cleo trading platform and related software, available via cleo.finance, our mobile applications for iOS and Android, and any other interface we make available (together, the “Platform”). Functionality differs across devices; the web application offers the most complete feature set.
What Cleo is. Cleo provides trading platform technology - software interfaces and tools for simulated trading, market analysis, and backtesting against historical market data. Cleo does not execute trades on any market; does not custody, hold, or transfer any funds or crypto-assets at any time; does not act as a broker, dealer, exchange, market maker, or counterparty; and does not provide investment, financial, tax, or legal advice. Cleo is not authorized as an investment firm under Directive 2014/65/EU (MiFID II), as a Crypto-Asset Service Provider under Regulation (EU) 2023/1114 (MiCA), or under any equivalent regime - and is not required to be so authorized for the activities described in these Terms.
Acceptance. By creating an account, signing in, or otherwise using the Platform, you accept these Terms. If you do not accept them, do not use the Platform.
2. How you reached Cleo
There are two ways people use the Platform. Some sections of these Terms apply only to one path; we mark them clearly.
(a) Prop firm partner path.A proprietary trading firm we partner with (a “Prop Firm Partner”) created your account so you can use the Platform to participate in their evaluation, challenge, or funded program. Your contract for the trading service - including the rules of the challenge, any fees you paid, any payouts you may receive, and any disputes about your trading results or account - is between you and your Prop Firm Partner. Cleo provides only the software interface. These Terms govern your use of that interface; your separate agreement with your Prop Firm Partner governs everything else.
(b) Direct subscription path. You signed up with Cleo directly - typically to access backtesting on historical market data, premium analytical features, automated risk-management tools, trading guardrails, or our partner discount portal. These Terms are your full agreement with Cleo for that purpose.
If both paths apply to you (you have a direct subscription and also use the Platform via a Prop Firm Partner), each path applies to the relevant part of your usage.
3. What the Platform is
The Platform is a simulated trading and analysis environment. It includes:
- Simulated trading on demo accounts you create, using virtual funds;
- Simulated trading on accounts created by Prop Firm Partners on your behalf, using virtual funds;
- Backtesting against historical market data;
- Performance statistics, trading calendars, and challenge progress tracking;
- Charts and price data for crypto perpetual futures and contracts-for-difference (CFDs) referencing foreign exchange, stocks, indices, and commodities;
- Where applicable to your subscription, automated risk-management tools that operate within the simulation environment (such as trailing stop-losses, automated take-profit or stop-loss adjustments, position-size limits, and automated rules that prevent or restrict trades based on conditions you configure), and a partner discount portal.
Nothing you do on the Platform is a real-world trade, order, transaction, or transfer of value. Prices shown are reference prices only. Virtual funds have no monetary value and cannot be exchanged or withdrawn. Past performance, simulated performance, and backtesting results do not predict or guarantee future results - including because real trading involves execution, slippage, fees, liquidity, and counterparty risks that simulations do not fully replicate.
If your Prop Firm Partner pays you real money based on your simulated performance under their challenge or evaluation rules, that payment is made by them under their contract with you - not by Cleo.
4. Eligibility and geographic restrictions
To use the Platform, you must:
(a) be at least 18 years old, or the age of majority in your jurisdiction if higher;
(b) have legal capacity to enter into these Terms;
(c) not be located in, ordinarily resident in, or a national of any country or territory subject to comprehensive sanctions by the European Union, the United Nations Security Council, the United States (OFAC SDN list), or the United Kingdom;
(d) not be listed on any sanctions or asset-freeze list maintained by the bodies referred to in (c).
You represent and warrant that you meet the eligibility requirements in this Section 4 and will continue to meet them throughout your use of the Platform. You will notify us promptly if any of these representations ceases to be true.
You are solely responsible for ensuring that your use of the Platform complies with the laws of your jurisdiction. If you access the Platform from outside Estonia, you do so on your own initiative and at your own risk.
Access may also be blocked by our infrastructure providers (including authentication, hosting, content-delivery, and payment providers) for compliance, security, or technical reasons. Where access is blocked at the infrastructure level, we cannot always restore it on request.
The Platform is for personal use. Use by legal entities or persons acting in the course of a trade or business requires a separate written agreement with Cleo (and, where applicable, a signed Data Processing Agreement).
5. Your account
You need an account to use the Platform. Depending on your path (Section 2), your account is either created by you directly or created on your behalf by a Prop Firm Partner using your email address - in which case you set or are issued a password.
You are responsible for:
(a) keeping your account secure, including your login credentials and any third-party authentication accounts (such as Google or Facebook accounts) you use to sign in to the Platform - see our Privacy Policy Section 3.1 for what data we receive when you sign in via OAuth;
(b) all activity on your account that occurs before you notify us under (c), except where the unauthorized activity results from a failure of our reasonable security measures; and
(c) notifying us within 72 hours of becoming aware of any unauthorized use of your account or other security incident affecting your account.
Cleo does not store, see, or have access to your password. Email is the official channel for account-related notices. You must keep your registered email address current. If our notices to your registered email bounce, we may suspend your account until you verify a working address.
You may delete your account at any time from your account settings. After deletion, your account enters a 30-day pending state during which it can be restored. After 30 days it is permanently deleted, subject to data we are required to retain by law (see our Privacy Policy).
6. Prop Firm Partner accounts
This Section 6 applies only if you reached Cleo via the prop firm partner path described in Section 2(a).
(a) Your trading service contract is with your Prop Firm Partner. They set the challenge rules, the entry fees, the payout terms, the breach criteria, and any other commercial terms.
(b) Cleo provides the software only. Cleo does not decide whether you have passed or failed a challenge; does not decide whether you receive a payout; does not process payments between you and your Prop Firm Partner; and does not hold any of your funds.
(c) Disputes about your account, evaluation results, or payouts must be resolved with your Prop Firm Partner. Cleo is not a party to those disputes and cannot adjudicate them. We will reasonably cooperate with valid requests from your Prop Firm Partner concerning your account.
(d) If your Prop Firm Partner instructs us to suspend, restrict, modify, or close your account on the Platform, we will follow that instruction. The reasons for the instruction are between you and the Prop Firm Partner.
(e) If our agreement with your Prop Firm Partner ends, your access to the Platform via that Prop Firm Partner ends with it. Your relationship and remedies remain with your Prop Firm Partner.
7. Subscriptions, payments, and refunds
This Section 7 applies only if you reached Cleo via the direct subscription path described in Section 2(b).
(a) Subscriptions. Some Platform features are available only with a paid subscription. Pricing, billing cycle, and feature scope are shown in the Platform at the point of subscription. Subscriptions renew automatically at the then-current price unless cancelled before the renewal date. We send you a reminder before each renewal, typically seven (7) days in advance.
(b) Payments. Payments are processed by our payment provider (currently Stripe). You are responsible for keeping your payment details current. If a payment fails, we may suspend access to paid features until payment succeeds.
(c) Cooling-off / withdrawal rights. Where applicable consumer protection law in your jurisdiction grants you a right to withdraw from a distance contract for digital services within a cooling-off period (for example, the 14-day right under Directive 2011/83/EU for EU consumers, or the equivalent right under the UK Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 for UK consumers), that right applies.
To exercise this right, contact us at hello@cleo.finance within the applicable statutory period and tell us you wish to withdraw. You do not need to give a reason. We will refund the full amount you paid within 14 days of being informed of your withdrawal, using the same payment method you used to subscribe, unless you ask us to use a different method.
(d) Cancellations outside the cooling-off period. You can cancel your subscription at any time from your account settings. Cancellation stops future renewals; your access to paid features continues until the end of your then-current billing period, and your subscription ends at that point. We do not provide prorated or partial refunds for the unused portion of the current billing period after cancellation. Nothing in this Section 7 affects any non-waivable rights you have under applicable consumer protection law, including for defective service.
(e) Price changes.We may change subscription prices on at least 30 days’ notice before the change takes effect. If you do not accept the new price, you can cancel before it applies.
(f) Taxes.Prices shown on the Platform are exclusive of VAT and other applicable consumption taxes. Where applicable, VAT or an equivalent consumption tax is calculated and added at checkout based on your location, as determined by our payment provider’s tax engine (currently Stripe Tax). You are responsible for any other taxes arising from your use of paid features.
8. Affiliate links
The Platform may include links to third-party services - including Prop Firm Partners, educators, and trading-related tools - where you can obtain a discount on the third party’s offering.
Some of these links are affiliate links. If you purchase through an affiliate link, we may receive a commission from the third party. The commission does not increase the price you pay. Where a link is an affiliate link, we disclose that fact at or near the link.
We do not control the third-party services we link to and are not responsible for their offers, prices, content, security, or accuracy. Your contract for any product or service you obtain through an affiliate link is between you and the third party - not Cleo.
9. Acceptable use
When using the Platform, you agree not to:
(a) use the Platform for any purpose that is unlawful in your country of residence or use, or otherwise in violation of applicable law;
(b) interfere with, disrupt, overload, or attempt to gain unauthorized access to the Platform, its infrastructure, or other users’ accounts;
(c) use automated means (bots, scrapers, crawlers) to access the Platform, except for legitimate search-engine indexing of public pages;
(d) reverse engineer, decompile, disassemble, or otherwise attempt to derive source code or underlying ideas from the Platform, except to the extent applicable law allows this regardless of contract;
(e) frame, mirror, white-label, or commercially redistribute any part of the Platform without our written consent;
(f) submit content that is unlawful, infringing, defamatory, fraudulent, or contains malware;
(g) impersonate any person or misrepresent your affiliation with any person or organization; or
(h) use the Platform to launder money, evade sanctions, or carry out any other activity prohibited by financial-crime laws.
We may investigate suspected violations and take any action we consider appropriate, including suspending or terminating accounts and reporting violations to authorities.
10. Intellectual property
Our IP. All intellectual property in the Platform - including the software, interface, design, text, graphics, logos, trademarks, and other content provided by us - is owned by Cleo or our licensors. We grant you a limited, personal, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Platform for the purposes described in these Terms. No other rights are granted by implication or otherwise.
Your content. You retain ownership of content you submit (such as notes, custom configurations, or any other user-generated content you add). By submitting content to the Platform, you grant Cleo a worldwide, royalty-free, non-exclusive license to host, store, transmit, and display that content as needed to operate the Platform for you. We do not use your content for marketing or share it publicly without your consent.
Reporting infringement or impersonation. If you believe content on the Platform infringes your rights or impersonates you or someone else, contact us at hello@cleo.finance with: (i) a description of the work or identity affected, (ii) the location on the Platform, (iii) your contact details, and (iv) a statement that you have a good-faith belief the use is unauthorized and that the information you provided is accurate. We will review and act on valid notices, which may include removing content and suspending accounts.
11. Your data and privacy
How we collect, use, and share personal data is described in our Privacy Policy, which forms part of these Terms.
Prop Firm Partner users (Section 2(a)). Cleo and your Prop Firm Partner each act in different capacities depending on the data:
- For data relating to your trading activity, evaluation results, and challenge progress, your Prop Firm Partner is the controller and Cleo is the processor, acting under a Data Processing Agreement. Direct queries about that data - including access, correction, or deletion requests - to your Prop Firm Partner.
- For other data, Cleo is an independent controller. This includes (i) account-level data necessary to operate the Platform interface (login credentials, session data, security and audit logs, and information about your use of the Platform); (ii) fraud-prevention and abuse-detection data; and (iii) direct communications between you and Cleo’s team that fall outside the Prop Firm Partner relationship. You may direct queries about that data to us at hello@cleo.finance.
Direct subscribers (Section 2(b)).Cleo is the controller of your personal data and is responsible for it under the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and applicable Estonian data protection law.
12. Disclaimers
The Platform is provided “as is” and “as available.” To the maximum extent permitted by law, Cleo makes no warranties of any kind, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, non-infringement, accuracy, completeness, timeliness, or uninterrupted operation.
Without limiting the above:
(a) Market data is reference only. Prices shown on the Platform are for reference and analysis only and may be delayed, inaccurate, or incomplete. We do not guarantee the accuracy of any price feed.
(b) Simulated and historical results don’t predict the future. Backtesting results, simulated performance, and historical analysis do not predict or guarantee future results in real markets.
(c) Availability is not guaranteed. The Platform may be unavailable from time to time for maintenance, due to issues with our infrastructure or data providers, or for other reasons. To the extent permitted by law, we are not liable for losses caused by unavailability.
(d) Behavioral risk. Trading - even simulated - carries a risk of error, misinterpretation, and behavioral effects, including overconfidence in strategies that performed well in simulation. You are solely responsible for any decisions you make on the Platform and any decisions you make outside the Platform that are informed by your use of it.
(e) Beta features.From time to time we may make new or experimental features available marked “beta,” “preview,” “experimental,” or similar. Beta features are provided as-is, may be modified, suspended, or discontinued at any time without notice, and may have additional terms or limitations disclosed to you when you opt in. Disclaimers and liability limits in these Terms apply to beta features in the same way as to generally-available features.
Nothing on the Platform constitutes investment, financial, tax, legal, or other professional advice. If you need advice, consult a qualified professional.
Nothing in this Section 12 limits or excludes our liability under Section 13 (Liability) or your non-waivable rights under applicable consumer protection law, including under the EU Digital Content Directive (Directive 2019/770) and the EU Consumer Rights Directive (Directive 2011/83/EU) where they apply to you.
13. Liability
Cap.To the maximum extent permitted by law, Cleo’s total aggregate liability arising out of or in connection with these Terms or your use of the Platform is limited to the greater of (i) the fees you paid to Cleo in the 3 months preceding the event giving rise to the claim, or (ii) EUR 1,000. For Prop Firm Partner users who pay no fees directly to Cleo, the cap is EUR 1,000.
Excluded losses. To the maximum extent permitted by law, Cleo is not liable for any indirect, incidental, consequential, special, punitive, or exemplary damages, including lost profits, lost data, lost opportunities, or lost reputation, even if we were advised of the possibility.
Carve-outs (what we do not exclude). Nothing in these Terms limits or excludes our liability for:
(i) death or personal injury caused by our negligence;
(ii) fraud or fraudulent misrepresentation;
(iii) gross negligence or intentional misconduct; or
(iv) any other liability that cannot lawfully be limited or excluded under Estonian or EU law (including under §107 of the Estonian Law of Obligations Act).
Currency. Where amounts in these Terms are stated in EUR and you paid in another currency, conversion for purposes of calculating the cap is at the European Central Bank reference rate on the date of the transaction giving rise to the claim.
Your indemnity. If you use the Platform in the course of a trade, business, or profession (including any legal entity), you agree to indemnify and hold harmless Cleo, its officers, employees, and agents from third-party claims arising out of (a) your breach of these Terms, (b) your violation of applicable law, or (c) content you submit to the Platform. If you are a consumer, you are not subject to this indemnity; you are liable to Cleo only for loss caused by your intentional misconduct, your negligence, your breach of these Terms, or your infringement of third-party rights, and only to the extent permitted by applicable law - and nothing here limits your non-waivable statutory rights. We will reasonably notify you of any claim and may, at our option, assume its defense at our expense.
14. Suspension, termination, and changes
By you. You may stop using the Platform at any time and delete your account from your account settings (Section 5).
By us, for cause. We may suspend or terminate your access immediately and without notice if (a) you breach these Terms in a material way, (b) we are required to do so by law or by a regulator, (c) we are instructed to do so by your Prop Firm Partner (where you are a Prop Firm Partner user), or (d) we reasonably believe your account is being used for fraud, money laundering, or to evade sanctions.
By us, for convenience.We may also terminate access for any other reason on 30 days’ written notice. For direct subscribers (Section 2(b)), we will refund the prorated unused portion of any prepaid subscription period.
Compliance with law. We may disclose information about you and take any other action we are required to take by law, court order, or a binding request from a competent authority. Where we are legally permitted to do so, we will notify you of such requests so you have an opportunity to object or seek protective relief.
Complaints handling. If you have a complaint about the Platform or our service, contact us at hello@cleo.finance. We aim to acknowledge complaints within five (5) business days and resolve them within thirty (30) days, although complex matters may take longer; in that case we will let you know and provide an updated timeline. Nothing in this paragraph affects your right to use the consumer ADR mechanisms or court remedies described in Section 15.
Effect of termination. On termination, your right to use the Platform ends. Your data is retained for the periods described in our Privacy Policy. Sections 8 (in respect of completed transactions), 10 (IP), 11 (Data and Privacy, in respect of any data still held), 12 (Disclaimers), 13 (Liability), and 15 (Governing Law and Disputes), and any other provision that by its nature should survive, continue to apply.
Changes to the Platform. We may add, change, or remove Platform features at any time. For material changes that significantly affect your use, we will provide reasonable advance notice in the Platform.
Changes to these Terms.We may update these Terms from time to time. We will post the updated version with a new effective date and, for material changes, give at least 30 days’ notice in the Platform before they take effect. If you continue using the Platform after the effective date, you accept the updated Terms. If you do not accept them, stop using the Platform and (for direct subscribers) cancel your subscription before the effective date.
15. Governing law, disputes, and general
Governing law. These Terms are governed by Estonian law, without regard to its conflict-of-law rules. The United Nations Convention on Contracts for the International Sale of Goods does not apply. If you are a consumer, this choice of Estonian law does not deprive you of the protection of any provisions that cannot be derogated from by agreement under the law of the country where you have your habitual residence (Article 6 of Regulation (EU) No 593/2008).
Jurisdiction (default).Except where the “US users” provisions below apply, disputes arising out of or in connection with these Terms will be resolved exclusively by the courts of Estonia. If you are an EU consumer, this does not deprive you of any non-waivable rights you have under the law of your country of residence, including the right to bring proceedings in the courts of your country of residence.
Consumer ADR (EU). If you are an EU consumer, you may submit disputes to a competent alternative dispute resolution (ADR) body in your country of residence. You can find the relevant body through your national consumer authority. We are not obliged to use, and do not commit to using, any particular ADR scheme.
Informal resolution (recommended). Whatever your jurisdiction, we encourage you to contact us at hello@cleo.finance before pursuing formal dispute resolution, so we have a chance to address your concern. This step is voluntary for EU and UK consumers and does not condition or limit any of your statutory consumer rights, your right to bring proceedings in your country of residence, or your right to use the consumer ADR mechanisms above.
US users - binding arbitration and class-action waiver. This section applies if you are a resident of, or located in, the United States at the time the dispute arises.
Informal dispute resolution first. Before initiating arbitration, you and Cleo agree to attempt informal resolution by contacting hello@cleo.finance in writing - describing the dispute, the relief you are seeking, and your contact information - and giving us 30 days to respond. If we cannot resolve the dispute within those 30 days, either party may proceed to arbitration as set out below. The 30-day informal-resolution period does not toll any statute of limitations applicable to your claim.
(a) Agreement to arbitrate. You and Cleo agree that any dispute, claim, or controversy arising out of or relating to these Terms or your use of the Platform will be resolved exclusively by binding individual arbitration administered by JAMS under its Comprehensive Arbitration Rules (or, for claims under USD 25,000, JAMS Streamlined Arbitration Rules), rather than in court. The Federal Arbitration Act (9 U.S.C. § 1 et seq.) governs the interpretation and enforcement of this arbitration agreement.
(b) Seat and procedure.The seat of arbitration is Wilmington, Delaware, USA. Arbitration may be conducted in person, by video, or on documents at the arbitrator’s discretion. The arbitrator’s award is final and enforceable in any court of competent jurisdiction.
(c) Class action waiver. You and Cleo each agree to bring claims only in your individual capacity, and not as a plaintiff or class member in any class, collective, consolidated, mass, or representative proceeding. The arbitrator has no authority to consolidate claims or to preside over any class or representative proceeding. If a court or arbitrator determines this class-action waiver is unenforceable as to any claim, that claim must be brought in court (not arbitration) and severed from any claims that remain in arbitration.
(d) Carve-outs.Either party may bring (i) an individual claim in small-claims court for any matter within that court’s jurisdiction, and (ii) a claim seeking injunctive or equitable relief to protect intellectual property rights or to address a violation of the Acceptable Use section. Nothing in this clause waives any non-waivable statutory right.
(e) 30-day opt-out. You may opt out of this arbitration agreement by sending written notice to hello@cleo.finance within 30 days of first accepting these Terms, including your name, account email, and a clear statement that you are opting out of arbitration. If you opt out, the default Jurisdiction provision above applies to you.
(f) Batch arbitration protocol.If 25 or more individual arbitration demands of a substantially similar nature are filed against Cleo by the same or coordinated counsel within any 60-day period, all such demands shall be administered as a single batch proceeding. Demands shall be grouped into batches of up to 50 cases, with each batch assigned to a single arbitrator. The arbitrator shall first hear and decide a representative subset of cases (“bellwether cases”) within each batch; the parties shall use the bellwether outcomes to inform global resolution of the remaining cases in the batch. Filing fees and arbitrator compensation for batched cases shall be allocated as JAMS determines under its Mass Arbitration Procedures, or as the parties otherwise agree. This batch protocol does not waive any party’s right to individual arbitration of their claim on the merits; it only governs the procedural sequencing of how claims are heard.
(g) Arbitration costs (consumers). If you are a consumer, Cleo will pay all JAMS filing, administrative, and arbitrator fees for your individual arbitration to the extent required by the JAMS Consumer Minimum Standards of Procedural Fairness, and in no event will you be required to pay fees or costs greater than you would pay to file the same claim in a court where you reside. Each party otherwise bears its own attorneys’ fees, except where a statute or the arbitrator provides otherwise.
Notices. We may give you notice by email to your registered email address, by in-Platform message, or by posting on cleo.finance. Email and in-Platform notices are deemed received on the day they are sent to your registered address or made available to you, unless you did not in fact receive them and could not reasonably have accessed them; website notices are deemed received when posted. It is your responsibility to keep your registered email address current. Notices to Cleo must be sent to hello@cleo.finance and are deemed received when we acknowledge them or, if earlier, on the fifth business day after sending.
Assignment. You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign these Terms in connection with a merger, acquisition, sale of assets, reorganization, or by operation of law, on notice to you.
No third-party beneficiaries. These Terms do not create rights for any third party except as expressly stated.
Force majeure. Neither party is responsible for failure to perform if the failure is due to causes beyond reasonable control, including natural disasters, war, civil unrest, government action, regulatory changes, cyberattacks, internet or cloud-provider outages, or third-party data-feed, exchange, or liquidity-provider outages. The affected party must promptly notify the other.
Severability. If any part of these Terms is found unenforceable, the rest continues in effect, and the unenforceable part is replaced with one that comes closest to its original intent within what is enforceable.
Entire agreement. These Terms, together with our Privacy Policy, are the entire agreement between you and Cleo about the Platform and replace any earlier agreements between us on the same subject. For Prop Firm Partner users, your separate agreement with your Prop Firm Partner remains in force and governs the matters described in Section 6.
Version. These Terms apply in the version posted on cleo.finance at the time you accept them, except where they have been amended in accordance with Section 14.
Language. These Terms are written in English. Any translation we provide is for convenience only; the English version prevails in case of conflict.
Contact. Questions about these Terms? Email us at hello@cleo.finance.