Terms of Use

2.1 Minimum Age

You must be at least 18 years old to use the Service. Kramio processes sensitive personal data including financial records and health information. Given the nature of this data, we do not offer the Service to anyone under the age of 18, regardless of parental or guardian consent.

By creating an account, you confirm that you are 18 years of age or older. If we discover that a user is under 18, we will immediately suspend the account and delete all associated data.

2.2 Account Registration

To access Kramio's full Service, you must register for an account. When registering, you agree to:

• Provide accurate, complete, and current information.
• Maintain and promptly update your account information to keep it accurate.
• Keep your login credentials confidential and not share them with any third party.
• Be solely responsible for all activity that occurs under your account.
• Notify us immediately at support@kramio.com if you suspect unauthorised access to your account.

You may not create more than one personal account. Accounts created on behalf of an organisation or business are subject to separate Business Terms available at kramio.com/business-terms.

Kramio's Core Privacy Promise

Your personal data is exclusively yours. Kramio will never use your data to train any shared AI model, improve any third party's AI system, or process your data for any purpose other than delivering your personal Kramio service. This is not a preference setting - it is a fundamental architectural principle of how Kramio is built.

3.1 Your Ownership of Data and Content

As between you and Kramio:

• You retain full ownership of all personal data, inputs, and information you provide to the Service ("Your Data").
• You own all outputs generated by your Personal SLM based on Your Data ("Your Outputs").

"Your Data" includes, without limitation: financial records, bank statements, health information, property records, lifestyle preferences, usage patterns, and any documents or files you upload to the Service.

3.2 How Kramio Uses Your Data

Kramio uses Your Data exclusively for the following purposes:

• To continuously improve your Personal SLM - a Small Language Model that exists solely within your account and serves only you.
• To deliver personalised insights, recommendations, and Agentic Actions (as defined in Section 5) to you.
• To maintain, secure, and operate your account and the Service.
• To comply with applicable law, including UK GDPR obligations.
• To enforce these Terms and protect the security of the platform.

Kramio will not:

• Use Your Data to train any shared, general, or third-party AI model.
• Sell, rent, or commercially exploit Your Data to any third party.
• Share Your Data with advertisers or marketing partners.
• Use Your Data to build profiles for any purpose other than delivering your personal Service.
• Transfer Your Data outside the United Kingdom or European Economic Area without appropriate safeguards.

3.3 Personal SLM - Your Private AI

Kramio's core technology is your Personal Small Language Model ("Personal SLM"). Your Personal SLM:

• Is trained exclusively on Your Data and no one else's.
• Exists within your account only - it is never shared with, visible to, or accessible by any other user.
• Is never used as training data, fine-tuning data, or benchmark data for any shared Kramio model or any third-party AI system.
• Improves in accuracy and personalisation the longer you use the Service.
• Is permanently and irreversibly deleted upon closure of your account, subject to a 30-day grace period described in Section 9.

3.4 UK GDPR & Your Legal Rights

Kramio is a data controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Our lawful bases for processing Your Data are:

• Contract performance: processing necessary to provide the Service you have subscribed to.
• Legitimate interests: processing necessary for security, fraud prevention, and service improvement, where these do not override your rights.
• Legal obligation: processing required to comply with applicable law.
• Consent: where we ask for your consent for specific processing activities, including certain Agentic Actions.

You have rights under UK GDPR, exercisable at any time by contacting legal@kramio.com, including access, rectification, erasure, data portability, restriction, objection, and human review of any AI-generated decision that materially affects you. We will respond to all data rights requests within 30 days.

3.5 Special Category Data

Kramio's Health Tiles may involve the processing of health data, which constitutes special category data under UK GDPR. We process health data only with your explicit consent, for the sole purpose of delivering Health Tile features to you personally, and in compliance with Article 9 UK GDPR and the Data Protection Act 2018.

You may withdraw consent for health data processing at any time by deactivating Health Tiles in your account settings. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

3.6 Data Retention

We retain Your Data for as long as your account is active and for 30 days following account closure to allow data export. Certain data may be retained for longer periods where required by law. Our full data retention schedule is set out in our Privacy Policy at kramio.com/privacy.

4.1 How Kramio Uses Third-Party AI

Kramio's Prompt Orchestrator (our "Nuance Engine") may route certain queries through one or more third-party AI models to generate responses. These third-party models may include, without limitation, models operated by OpenAI, Anthropic, Google, and other AI providers ("Third-Party Models").

Before any query is routed to a Third-Party Model:

• Your query is processed and aggregated by Kramio's own intelligence layer.
• Personally identifiable information is stripped or anonymised to the maximum extent practicable.
• The query is reformulated to be domain-specific and privacy-preserving.

All outputs from Third-Party Models are returned to Kramio's Unique Aggregation Engine, which synthesises, de-biases, and quality-checks responses before delivering them to you. You receive Kramio's processed output, not raw third-party model output.

4.2 Third-Party Model Terms

Third-Party Models are subject to their own terms of service and privacy policies. Kramio is not responsible for the practices of Third-Party Model providers. By using the Service, you acknowledge that queries processed through Third-Party Models are subject to those providers' terms, as supplemented by the data processing agreements Kramio holds with those providers.

Third-Party Model providers may update their models, terms, or practices at any time. Kramio's aggregation and anonymisation layer is designed to minimise data exposure to Third-Party Models, but no technical measure can guarantee absolute privacy in all circumstances.

A current list of Third-Party Model providers used by Kramio is maintained at kramio.com/third-party-models and updated when material changes occur.

4.3 No Endorsement

References to Third-Party Models or their outputs do not constitute endorsement of those providers or their products. Kramio's recommendations and insights are the product of our own Aggregation Engine, not of any individual Third-Party Model.

What Are Agentic Actions?

Kramio can, with your explicit prior approval, take real-world actions on your behalf through our network of vetted service partners. Examples include booking GP appointments, comparing and switching energy tariffs, cancelling unused subscriptions, requesting insurance quotes, or filing documents. We call these "Agentic Actions".

5.1 Consent to Agentic Actions

Kramio will only execute an Agentic Action after receiving your explicit, informed consent. Specifically:

• You must activate Agentic Action permissions for each category of action in your account settings.
• Before executing any individual Agentic Action, Kramio will present a clear summary of the action to be taken, the service partner involved, and any financial or contractual consequence.
• You must affirmatively confirm each individual action before it is executed. Passive inaction does not constitute consent.
• Kramio will provide a confirmation record of every Agentic Action executed, accessible in your account history.

5.2 Your Right to Revoke Agentic Permissions

You may revoke Agentic Action permissions at any time through your account settings. Revocation takes effect immediately for future actions. Revocation does not undo actions already executed with your prior consent.

5.3 Kramio's Liability for Agentic Actions

Kramio acts as your agent in facilitating Agentic Actions, not as a principal. Accordingly:

• Kramio is not a party to any contract entered into between you and a service partner as a result of an Agentic Action.
• Kramio is not liable for the performance, quality, or outcome of any service delivered by a service partner.
• Kramio is not liable for any financial loss, contractual obligation, or consequence arising from an Agentic Action that you have explicitly approved.
• If an Agentic Action is executed without your prior consent due to a technical error on Kramio's part, Kramio will use reasonable endeavours to reverse or mitigate the action and will be liable for direct losses caused by that error, subject to the liability limits in Section 10.

Kramio maintains a vetted marketplace of service partners. A current list of approved partners is available at kramio.com/partners. Kramio reserves the right to add or remove partners at any time.

6.1 Kramio as a Decision-Support Tool

Kramio is designed to support your decision-making - not to replace it. Our AI-generated insights, recommendations, and analyses ("Outputs") are intended to provide you with relevant information and perspective to assist your own informed decisions.

For significant financial decisions, medical decisions, legal matters, and property transactions, you should always seek advice from a qualified professional. Kramio's Outputs are not a substitute for professional financial, medical, legal, or property advice.

6.2 Accuracy Limitations

You acknowledge and agree that AI and machine learning systems, including Kramio's Personal SLM, may produce outputs that are incomplete, inaccurate, or not fully reflective of your specific circumstances. Outputs may be based on outdated data. Kramio does not warrant that any Output is error-free, complete, or fit for any specific purpose.

6.3 No Reliance on Outputs as Sole Source

You must not rely solely on Kramio's Outputs as the basis for any decision that could have a material financial, legal, medical, or personal impact. Kramio's Outputs are one input among many that you should consider, alongside professional advice and your own judgement.

6.4 Outputs About Third Parties

Kramio's Outputs relate to your personal circumstances and data. You must not use any Output relating to a third party in a way that could materially affect their legal rights, financial position, or personal welfare without their knowledge and consent.

7.1 Permitted Use

Subject to your compliance with these Terms, Kramio grants you a personal, non-exclusive, non-transferable, revocable licence to access and use the Service for your own personal, household, and non-commercial purposes.

7.2 Prohibited Use

You may not use the Service for any unlawful purpose, to process or store data relating to third parties without their knowledge and consent, to reverse engineer the Service, to scrape or systematically download data, to interfere with security or rate limits, to misrepresent AI-generated Outputs as human-generated or professional advice, to use Outputs to develop competing AI systems, to upload infringing or malicious content, or to resell, sublicense, or white-label Kramio's outputs without a separate written agreement.

8.1 Subscription Tiers

Kramio offers a Freemium tier and paid subscription tiers. Current subscription pricing and features are set out at kramio.com/pricing. Paid subscriptions are billed monthly in advance.

8.2 Billing

By subscribing to a paid tier, you authorise Kramio to charge your designated payment method on a recurring monthly basis. You are responsible for providing accurate payment information, ensuring your payment method remains valid and has sufficient funds, and all applicable taxes.

If a payment fails, Kramio may downgrade your account to the Freemium tier or suspend access to paid features until payment is received. We will notify you of any payment failure by email.

8.3 Price Changes

Kramio may change subscription prices from time to time. If we increase prices, we will provide at least 30 days' written notice by email. Any price increase will take effect from your next renewal date.

8.4 Cancellation

You may cancel your paid subscription at any time through your account settings or by contacting support@kramio.com. Cancellation takes effect at the end of your current billing period. Subscription fees are non-refundable except where required by applicable law.

8.5 Free Trial

Where Kramio offers a free trial period, your subscription will automatically convert to a paid subscription at the end of the trial unless you cancel before the trial period ends. We will remind you by email before the trial expires.

9.1 Closing Your Account

You may close your account at any time by selecting "Delete Account" in your account settings or by contacting support@kramio.com. Account closure is permanent and irreversible.

9.2 Data Retention Following Closure

Upon account closure, your Personal SLM and associated personal data will be retained for 30 days to allow you to export your data. After 30 days, your Personal SLM and all associated personal data will be permanently and irreversibly deleted. You may request immediate deletion before the 30-day period ends by contacting dpo@kramio.com.

Certain data may be retained beyond the 30-day grace period where required by applicable law. Any such retained data will be held securely and used only for legal compliance purposes.

9.3 Data Export

You may request a copy of Your Data at any time through your account settings or by contacting legal@kramio.com. We will provide your data in a structured, commonly used, machine-readable format within 30 days of your request.

9.4 Kramio's Right to Suspend or Terminate

Kramio reserves the right to suspend or terminate your account if you breach these Terms, if required by law or court order, if your use creates a risk of harm, or if your account has been inactive for more than 24 consecutive months without an active paid subscription. Where possible, we will give advance notice.

10.1 Kramio's IP

All rights, title, and interest in and to the Service - including the platform software, Prompt Orchestrator, Aggregation Engine, Meta SLM architecture, brand, trademarks, design, and associated documentation - are owned by Kramio.AI Ltd or its licensors. Nothing in these Terms grants you any right in Kramio's intellectual property except the limited licence set out in Section 7.1.

10.2 Your IP

You retain all intellectual property rights in Your Data. By using the Service, you grant Kramio a limited, non-exclusive, royalty-free licence to process Your Data solely for the purposes described in Section 3.2. This licence terminates upon account closure.

10.3 Feedback

If you provide feedback, suggestions, or ideas about the Service, you grant Kramio a perpetual, irrevocable, worldwide, royalty-free licence to use that Feedback for any purpose without compensation to you. You waive any moral rights in such Feedback to the fullest extent permitted by law.

11.1 Service Provided 'As Is'

The Service is provided "as is" and "as available". To the fullest extent permitted by law, Kramio disclaims all warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, and non-infringement. Kramio does not warrant that the Service will be uninterrupted, error-free, or free from harmful components.

11.2 Limitation of Liability

To the fullest extent permitted by applicable law, Kramio's total aggregate liability to you for any claim arising out of or in connection with these Terms or the Service shall not exceed the greater of the total subscription fees paid by you to Kramio in the 12 months preceding the claim or £100.

Kramio shall not be liable for any indirect, incidental, special, consequential, or punitive losses, including loss of profit, loss of data, loss of goodwill, or business interruption, even if advised of the possibility of such losses.

13.1 Governing Law

These Terms and any dispute or claim arising out of or in connection with them, including non-contractual disputes, shall be governed by and construed in accordance with the law of United States of America.

13.2 Dispute Resolution

We hope to resolve any concerns informally. If you have a complaint, please contact us first at support@kramio.com. We will endeavour to resolve your concern within 14 days.