Terms of Service

1. Introduction and Acceptance

1.1. These Terms of Service ("Terms") constitute a legally binding agreement between you ("Customer", "you", or "your") and Propel Group International Ltd (trading as FullFathom AI) ("FullFathom", "we", "us", or "our"), a company registered in England and Wales under company number 16943846, with its registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

1.2. By accessing or using the FullFathom AI platform, including the cloud-based document processing service and the on-vessel AI runtime software (collectively, the "Service"), you agree to be bound by these Terms.

1.3. If you are entering into these Terms on behalf of a company or other legal entity, you represent that you have the authority to bind that entity to these Terms. If you do not have such authority, or if you do not agree with these Terms, you must not use the Service.

1.4. We may update these Terms from time to time. We will provide at least thirty (30) days' notice of material changes via email to the address associated with your account. Your continued use of the Service after such notice constitutes acceptance of the updated Terms.

2. Service Description

2.1. Cloud Platform.FullFathom provides a cloud-based software-as-a-service ("SaaS") platform that enables Customers to upload, process, and manage maritime operational documents including, but not limited to, Safety Management System manuals, ISM Code procedures, MARPOL annexes, SOLAS procedures, equipment manuals, and company circulars. The platform processes these documents through automated parsing, structuring, embedding, and packaging into deployable software bundles ("Bundles").

2.2. On-Vessel Runtime.FullFathom provides an on-vessel AI runtime application ("Ship Runtime") that operates offline in normal use on vessel hardware connected to the vessel's local area network. The Ship Runtime enables crew members to query the Customer's own operational documentation using natural language and receive AI-generated answers grounded in and citing that documentation. Updates to the Ship Runtime are applied via Bundle delivery as described in §8.5 and do not require continuous internet connectivity on the vessel.

2.3. Bundles. A Bundle is a self-contained software package comprising the AI inference model, document embeddings, vector search index, metadata database, runtime application, and user interface. Bundles are generated by the Cloud Platform and deployed to designated vessels. Bundles are specific to each Customer and each vessel.

2.4. Document Processing. The Cloud Platform offers two document parsing methods:

1. A built-in parsing pipeline included in the base subscription; and
2. An optional premium parsing service powered by a third-party provider, available at additional cost, for improved accuracy on scanned documents and complex document layouts. The current third-party provider is identified in Annex A of the Data Processing Agreement.

3. Pricing, Free Trial, and Design-Partner Program

3.1. Published Pricing. Current published pricing — including fleet-band pricing, annual-commit discount structure, free-trial terms, premium per-fleet features, and optional operational add-ons — is published at fullfathom.ai/pricing. The pricing in force for a given Customer is the pricing stated on the Customer's Order Form or equivalent commercial document signed by both parties; in the absence of a signed Order Form, the pricing published at fullfathom.ai/pricing on the Activation Date applies.

3.2. Vessel.A "vessel" means a single ship identified by its IMO number that is designated in the Customer's account to receive a Bundle and operate the Ship Runtime.

3.3. Pricing Changes.FullFathom may revise published pricing from time to time. Revised pricing applies to new subscriptions immediately and to renewals of existing subscriptions with at least ninety (90) days' written notice to existing customers prior to the start of the next renewal period.

3.4. Free Trial.

1. Eligibility. FullFathom offers a two-month free trial of the Service to one (1) designated legal entity per Customer group, excluding prospects managing fleets of one hundred (100) or more vessels, who are instead directed to the Design-Partner Program (§3.5) or a separately scoped paid pilot.
2. Included. The free trial includes use of the core Service on up to two (2) designated trial vessels, ingestion of up to one thousand (1,000) pages of Customer documentation, and standard technical support with next-business-day response targets.
3. Excluded. Premium per-fleet features (including but not limited to Conflict Detection, Onshore Analytics, and Audit Evidence Pack), operational add-ons (including but not limited to SSO, EU/UK data residency, priority SLA, AMS integration sync, private bundle mirrors, and white-label branding), and specialist professional services are not included in the free trial and may be purchased separately.
4. Duration. The free trial runs for two (2) calendar months commencing on the Activation Date of the first trial vessel.
5. SLA. The availability commitment in §8.1 does not apply during the free trial. FullFathom will use commercially reasonable efforts to maintain availability during the trial period but does not offer service credits.
6. Liability During Trial. Notwithstanding §10.1, the total aggregate liability of FullFathom arising out of or in connection with the free trial, whether in contract, tort, or otherwise, shall not exceed one hundred pounds sterling (GBP 100), given that no fees are paid during the trial period. The exceptions in §10.4 (death or personal injury, fraud, non-excludable liability) continue to apply.
7. Conversion. If the Customer converts to a paid annual subscription within fourteen (14) days after the end of the trial period, FullFathom shall waive the Band A setup fee in respect of the trial vessels. Other setup fees applicable at other bands continue to apply.
8. End of Trial.If the Customer does not convert to a paid subscription within fourteen (14) days after the end of the trial period, (i) access to the Cloud Platform for the Customer's trial account will cease, (ii) Bundles deployed to trial vessels will continue to function with existing content but will not receive further updates, and (iii) Customer documentation and trial-vessel Bundles will be deleted from the Cloud Platform within thirty (30) days, subject to standard export on request.

3.5. Design-Partner Program.

1. Slots. FullFathom offers a Design-Partner Program with a limited number of slots (currently four (4)) for fleet operators willing to launch the Service alongside FullFathom.
2. Benefits. Design partners receive: (i) no setup fee; (ii) the design-partner per-vessel rate grandfathered for twenty-four (24) months from Activation Date, including across renewals within that window; (iii) premium per-fleet features (Conflict Detection, Onshore Analytics, Audit Evidence Pack, or their successor equivalents) included at no additional charge for the same twenty-four (24) month period; (iv) direct access to the founding team for the first eight (8) weeks, and a named contact thereafter.
3. Customer Commitments.In consideration of the benefits, the design partner agrees to: (i) be named as a design partner on FullFathom marketing materials (including the website design-partner strip), with the specific wording subject to the design partner's written approval; (ii) participate in at least one published case study once eight (8) weeks of live use have been completed; (iii) take part in structured feedback sessions of approximately one (1) hour per month for the first six (6) months.
4. Scope of Rate Lock.The rate lock in (b)(ii) guarantees the per-vessel rate and the inclusion of the premium per-fleet features listed in (b)(iii) (or their successor equivalents) for the twenty-four (24) month period. FullFathom retains the right, acting reasonably, to evolve the Service, introduce new features at additional cost, refactor existing features, or deprecate features no longer aligned with the product roadmap, provided that any such change does not materially degrade the design partner's use of the core Service during the locked-rate period.
5. Incorporation. Specific design-partner terms may be set out in an Order Form or a short-form design-partner agreement that incorporates these Terms by reference. In the event of conflict between the Order Form and these Terms on design-partner-specific matters, the Order Form prevails.

4. Billing and Payment

4.1. Billing Cycle.Subscriptions are billed annually in advance, unless otherwise stated on the Customer's Order Form. The billing cycle begins on the Activation Date, being the earlier of (a) the date the first Bundle is deployed to the Customer's first designated vessel, or (b) the date ninety (90) days after the Order Form Effective Date.

4.2. Annual Commitment. Customers may elect annual-commit pricing at the rate published at fullfathom.ai/pricing on the Activation Date (or as stated on the signed Order Form). The annual-commit rate is payable in advance for the full annual period.

4.3. Payment Terms. All invoices are due within thirty (30) days of the invoice date. Payments shall be made by bank transfer or such other method as we may make available.

4.4. Late Payment. Overdue amounts shall accrue interest at the rate of four percent (4%) above the Bank of England base rate per annum, calculated daily from the due date until payment is received in full.

4.5. Taxes.All fees are exclusive of applicable taxes. The Customer is responsible for all taxes, duties, and levies imposed by any governmental authority in connection with the Service, excluding taxes based on FullFathom's net income.

4.6. Suspension for Non-Payment.If payment is not received within sixty (60) days of the invoice date, we may suspend access to the Cloud Platform. Suspension of the Cloud Platform does not affect the operation of Ship Runtimes already deployed on vessels, which will continue to function with their existing Bundles. We will provide at least fourteen (14) days' written notice before any suspension.

5. AI Advisory Disclaimer

6. No Warranty on AI Accuracy

6.1. While FullFathom strives for high accuracy in document parsing, information retrieval, and AI-generated answers, AI-generated answers may contain errors, omissions, or inaccuracies and should always be verified against the original source documentation.

6.2. Specifically, FullFathom does not warrant that:

1. Document parsing will be free from errors, particularly for scanned, poorly formatted, or handwritten documents;
2. The AI will retrieve the most relevant information for every query;
3. AI-generated answers will be complete, accurate, or current;
4. Citations to document names, sections, and page numbers will be correct in all cases;
5. The AI will refuse to answer in all cases where relevant information is not present in the documentation.

6.3. The Ship Runtime includes a citation system that identifies the source document, section, and page number for each answer. These citations are provided to assist verification but are not guaranteed to be accurate.

6.4. The Ship Runtime includes a refusal mechanism that is designed to decline to answer when relevant information is not found in the loaded documentation. This mechanism is not infallible and should not be relied upon as a guarantee that the absence of an answer means the absence of a relevant procedure.

7. Customer Responsibilities

7.1. Documentation. The Customer is responsible for:

1. Uploading accurate, current, and approved versions of all operational documents to be included in vessel Bundles;
2. Ensuring that uploaded documents reflect the latest approved revisions of the Customer's Safety Management System and other operational procedures;
3. Promptly uploading updated documents when procedures are revised, and requesting new Bundle generation for affected vessels;
4. Reviewing the quality of parsed documents and AI-generated answers during the onboarding process and on an ongoing basis.

7.2. Vessel Hardware. The Customer is responsible for:

1. Providing and maintaining vessel hardware that meets or exceeds the minimum specifications published by FullFathom (currently: x86_64 processor with at least 4 cores, 16 GB RAM, 100 GB SSD storage);
2. Ensuring the Ship Runtime is accessible to crew devices via the vessel's local area network;
3. Maintaining the vessel hardware in good working order, including ensuring adequate power supply and environmental conditions.

7.3. Crew Training and Awareness. The Customer is responsible for:

1. Ensuring that all crew members who may use the Ship Runtime understand that it is an advisory tool only and does not replace the need to consult original approved documentation for safety-critical procedures;
2. Incorporating appropriate guidance about the use of the Ship Runtime into the vessel's familiarisation procedures;
3. Ensuring that the Master and senior officers are aware of the limitations of the Service as described in Sections 5 and 6 of these Terms.

7.4. Bundle Updates. The Customer is responsible for:

1. Applying Bundle updates to vessels in a timely manner, whether via satellite connectivity, port download, or USB transfer;
2. Ensuring that vessels operate with reasonably current Bundles that reflect the latest uploaded documentation.

7.5. Compliance. The Customer is responsible for ensuring that its use of the Service complies with all applicable laws, regulations, and industry standards, including but not limited to the ISM Code, SOLAS, MARPOL, STCW, and any applicable flag state requirements.

8. FullFathom Responsibilities

8.1. Platform Availability. FullFathom shall use commercially reasonable efforts to maintain Cloud Platform availability of at least ninety-nine point five percent (99.5%) measured monthly, excluding:

1. Scheduled maintenance windows, for which we will provide at least forty-eight (48) hours' advance notice;
2. Force majeure events as described in Section 16;
3. Failures caused by the Customer's systems, networks, or equipment;
4. Failures of third-party services beyond FullFathom's reasonable control.

8.2. Document Processing. FullFathom shall process uploaded documents using its automated pipeline and make Bundles available for download within a reasonable timeframe, typically within twenty-four (24) hours of upload for standard document volumes.

8.3. Support.FullFathom shall provide technical support in accordance with the Customer's subscription tier:

1. Starter: email support during business hours (Monday to Friday, 09:00-17:00 GMT), response within two (2) business days;
2. Professional: email and video call support during extended business hours (Monday to Friday, 08:00-20:00 GMT), response within one (1) business day;
3. Enterprise: as defined in the applicable Enterprise agreement.

8.4. Security. FullFathom shall implement and maintain appropriate technical and organisational security measures to protect Customer data processed through the Cloud Platform, as further described in the Data Processing Agreement.

8.5. Updates. FullFathom shall provide software updates to the Ship Runtime and Cloud Platform during the subscription term. Updates may include improvements to AI models, parsing quality, user interface, and security patches.

9. Data Ownership and Intellectual Property

9.1. Customer Data Ownership. The Customer retains all right, title, and interest in and to:

1. All documents uploaded to the Cloud Platform;
2. All Bundles generated from the Customer's documents (excluding the underlying FullFathom software and AI models contained therein);
3. All query logs and analytics data generated by the Customer's use of the Service;
4. All data exported from the Service.

9.2. Licence to Process. The Customer grants FullFathom a non-exclusive, worldwide licence to process, store, and transform Customer documents solely for the purpose of providing the Service, including parsing, chunking, embedding, indexing, and packaging into Bundles. This licence terminates upon termination of the subscription.

9.3. FullFathom Intellectual Property. FullFathom retains all right, title, and interest in and to:

1. The Cloud Platform software and all related code, interfaces, and documentation;
2. The Ship Runtime software, including the AI inference engine, RAG orchestrator, query processing pipeline, and user interface;
3. The AI models, algorithms, and machine learning techniques used in the Service;
4. All improvements, modifications, and derivative works of the foregoing, regardless of whether informed by Customer feedback or usage data.

Certain components of the Service incorporate open-source software licensed under permissive open-source licences. A notices file listing such components and their respective licences is published at fullfathom.ai/oss-notices and is incorporated by reference.

9.4. Aggregated and Anonymised Data.FullFathom may use aggregated and anonymised data derived from the Customer's use of the Service (such as aggregate query volumes, common question categories, and system performance metrics) for the purpose of improving the Service, provided that: (a) such data has been anonymised using industry-standard techniques such that it cannot reasonably be used to identify the Customer, any vessel, or any individual crew member; (b) FullFathom shall not attempt to re-identify any anonymised data; (c) such use is limited to improving the Service, benchmarking, and developing new features; and (d) any use in public marketing materials is further restricted as follows: FullFathom may publish aggregated statistics in marketing materials only where such statistics have been aggregated across a minimum of ten (10) Customers and cannot reasonably be used to identify any individual Customer, vessel, or crew member, and FullFathom shall not use the Customer's name, logo, or vessel names in marketing materials without the Customer's prior written consent. This right shall survive termination of these Terms, but only in respect of data that has been irreversibly anonymised prior to termination.

9.5. No Other Rights. Except as expressly stated in these Terms, neither party grants the other any rights in or to its intellectual property.

10. Limitation of Liability

10.4. Exceptions.Nothing in these Terms shall exclude or limit either party's liability for:

1. Death or personal injury caused by its negligence;
2. Fraud or fraudulent misrepresentation;
3. Any liability which cannot be excluded or limited by applicable law.

10.5. Essential Basis. The Customer acknowledges that the limitations and exclusions in this Section 10 reflect the allocation of risk between the parties, are essential to the basis of the bargain between the parties, and that FullFathom would not have entered into these Terms without such limitations and exclusions. The fees charged by FullFathom reflect this allocation of risk.

11. Indemnification

11.1. Customer Indemnification. The Customer shall indemnify, defend, and hold harmless FullFathom, its officers, directors, employees, and agents from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or in connection with:

1. The Customer's use of the Service in breach of these Terms;
2. Any decision made or action taken by the Customer, its crew, or any third party based on AI-generated outputs of the Service, in circumstances where the Customer has failed to comply with §7.3 (Crew Training and Awareness) or where the Customer has held out the Service to crew or third parties as a replacement for approved procedures;
3. The Customer's failure to fulfil its responsibilities under Section 7, including the failure to ensure crew awareness that the Service is an advisory tool only;
4. Any claim that documents uploaded by the Customer infringe the intellectual property rights of a third party;
5. The Customer's breach of applicable laws or regulations in connection with its use of the Service.

11.2. FullFathom Indemnification. FullFathom shall indemnify, defend, and hold harmless the Customer from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or in connection with any claim that the Service (excluding Customer-uploaded documents) infringes the intellectual property rights of a third party, provided that:

1. The Customer promptly notifies FullFathom in writing of any such claim;
2. The Customer grants FullFathom sole control of the defence and settlement of such claim;
3. The Customer provides reasonable assistance in the defence of such claim at FullFathom's expense.

11.3. IP Infringement Remedy.If the Service becomes, or in FullFathom's reasonable opinion is likely to become, the subject of an intellectual property infringement claim, FullFathom may, at its sole option and expense:

1. Obtain for the Customer the right to continue using the Service;
2. Replace or modify the Service so that it is no longer infringing; or
3. If neither (a) nor (b) is commercially practicable, terminate the affected subscription and refund the Customer a pro-rata portion of any pre-paid fees for the unexpired subscription term.

11.4. IP Indemnity Carveouts.FullFathom's indemnification obligation under §11.2 does not apply to the extent any infringement claim arises from: (a) the Customer's modification or unauthorised use of the Service; (b) combination of the Service with products or data not supplied or approved by FullFathom; (c) the Customer's continued use of a version of the Service after FullFathom has made a non-infringing version available under §11.3; or (d) Customer-uploaded documents.

11.5. Cap on IP Indemnity.FullFathom's total liability under §11.2 shall be subject to the limitations in §10 (Limitation of Liability).

12. Confidentiality

12.1. Definition."Confidential Information" means any information disclosed by one party ("Discloser") to the other party ("Recipient") that is designated as confidential or that reasonably should be understood to be confidential given the nature of the information and the circumstances of disclosure. Confidential Information includes, but is not limited to: business plans, pricing, technical data, product plans, customer lists, vessel operational data, and uploaded documents.

12.2. Obligations. The Recipient shall: (a) use Confidential Information solely for the purpose of performing its obligations or exercising its rights under these Terms; (b) protect Confidential Information with at least the same degree of care it uses to protect its own confidential information, but no less than reasonable care; and (c) not disclose Confidential Information to any third party except as permitted under these Terms.

12.3. Exceptions.Confidential Information does not include information that: (a) is or becomes publicly available through no fault of the Recipient; (b) was known to the Recipient prior to disclosure; (c) is independently developed by the Recipient without reference to the Discloser's Confidential Information; or (d) is rightfully received from a third party without restriction on disclosure.

12.4. Compelled Disclosure. The Recipient may disclose Confidential Information to the extent required by law, regulation, or court order, provided that the Recipient gives the Discloser prompt written notice (to the extent legally permitted) and reasonable assistance in seeking a protective order.

12.5. Duration. Confidentiality obligations under this Section shall survive termination of these Terms for a period of three (3) years.

13. Term and Termination

13.1. Term. These Terms are effective from the date the Customer first accesses the Service and continue until terminated in accordance with this Section.

13.2. Subscription Term. Each subscription has an initial term of twelve (12) months, commencing on the Activation Date. Subscriptions automatically renew for successive twelve (12) month periods unless either party provides written notice of non-renewal at least sixty (60) days prior to the end of the then-current term.

13.3. Termination for Convenience.Either party may terminate these Terms by providing the other party with at least thirty (30) days' written notice. If the Customer terminates during an annual billing period, no refund shall be provided for the remainder of the pre-paid term unless otherwise agreed in writing.

13.4. Termination for Cause. Either party may terminate these Terms immediately upon written notice if:

1. The other party commits a material breach of these Terms and fails to cure such breach within thirty (30) days of receiving written notice of the breach;
2. The other party becomes insolvent, enters administration, liquidation, or any analogous proceeding, or ceases or threatens to cease to carry on business;
3. Where the Customer terminates under this §13.4 for FullFathom's uncured material breach, FullFathom shall refund to the Customer a pro-rata portion of any pre-paid fees for the unexpired subscription term, calculated from the effective date of termination. Where FullFathom terminates under this §13.4 for the Customer's uncured material breach, no refund shall be payable.

13.5. Effect of Termination.

1. Upon termination, the Customer's access to the Cloud Platform shall cease.
2. Ship Runtimes already deployed on vessels at the effective date of termination will continue to function with their existing Bundles for the remainder of the then-current annual subscription period for which fees have been paid, and will not receive further updates thereafter.
3. FullFathom shall make the Customer's uploaded documents and data available for export for a period of thirty (30) days following the effective date of termination. After this period, FullFathom shall delete the Customer's data in accordance with the Data Processing Agreement.
4. The Customer shall, upon request by FullFathom and no earlier than the end of the paid-for subscription period described in (b), delete or uninstall all copies of the Ship Runtime software and Bundles within thirty (30) days, and certify such deletion in writing upon request. This obligation does not apply where the Customer terminates these Terms for FullFathom's uncured material breach under §13.4.

13.6. Survival. Sections 5 (AI Advisory Disclaimer), 6 (No Warranty on AI Accuracy), 9 (Data Ownership and Intellectual Property), 10 (Limitation of Liability), 11 (Indemnification), 12 (Confidentiality), and 15 (Governing Law and Dispute Resolution) shall survive termination of these Terms.

14. Warranty Disclaimer

15. Governing Law and Dispute Resolution

15.1. Governing Law. These Terms and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales.

15.2. Negotiation. Any dispute arising out of or in connection with these Terms, including any question regarding their existence, validity, or termination, shall first be referred to the designated contacts of each Party for resolution through good-faith negotiation for a period of thirty (30) days from written notice of the dispute.

15.3. Disputes Under GBP 50,000. If a dispute is not resolved by negotiation under Section 15.2, and the amount in dispute (or, where the dispute is non-monetary, its reasonable estimated value) is less than fifty thousand pounds sterling (GBP 50,000), the dispute shall be submitted to the exclusive jurisdiction of the courts of England and Wales.

15.4. Disputes of GBP 50,000 or Above.If a dispute is not resolved by negotiation under Section 15.2, and the amount in dispute (or, where the dispute is non-monetary, its reasonable estimated value) is fifty thousand pounds sterling (GBP 50,000) or above, the dispute shall be referred to and finally resolved by arbitration under the terms of the London Maritime Arbitrators Association ("LMAA") then in force, which terms are deemed to be incorporated by reference into this clause. The tribunal shall consist of a sole arbitrator agreed by the Parties, or failing agreement within fourteen (14) days, appointed by the President of the LMAA. The seat of arbitration shall be London, England. The language of the arbitration shall be English.

15.5. Interim Relief. Nothing in this Section shall prevent either party from seeking interim or injunctive relief from any court of competent jurisdiction.

16. Force Majeure

16.1. Neither party shall be liable for any failure or delay in the performance of its obligations under these Terms to the extent that such failure or delay is caused by a Force Majeure Event, provided that the affected party: (a) promptly notifies the other party of the Force Majeure Event; and (b) uses commercially reasonable efforts to mitigate its effects.

16.2. "Force Majeure Event" means any event beyond a party's reasonable control, including but not limited to: acts of God, natural disasters, war, terrorism, civil unrest, pandemic, epidemic, government sanctions, embargoes, strikes, power failures, and public internet outages. For the avoidance of doubt, failures of third-party service providers or infrastructure providers that FullFathom has engaged to deliver the Service (including without limitation cloud hosting, authentication, or document-processing vendors) are not Force Majeure Events. Where applicable, service credits under FullFathom's Service Level Terms published at fullfathom.ai/slashall be the Customer's sole and exclusive remedy for such failures.

16.3. If a Force Majeure Event continues for more than ninety (90) days, either party may terminate these Terms upon written notice to the other party.

17. General Provisions

17.1. Entire Agreement. These Terms, together with the Data Processing Agreement, the Privacy Policy, the End User Licence Agreement, the Service Level Terms, and the OSS Notices, constitute the entire agreement between the parties with respect to the subject matter hereof and supersede all prior or contemporaneous agreements, representations, and understandings.

17.2. Severability. If any provision of these Terms is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect.

17.3. Waiver. The failure of either party to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision.

17.4. Assignment. Neither party may assign or transfer these Terms without the prior written consent of the other party, which consent shall not be unreasonably withheld, conditioned, or delayed, except that (a) either party may assign these Terms in connection with a merger, acquisition, or sale of all or substantially all of its assets, and (b) the Customer may assign these Terms to an affiliate under common control with the Customer upon written notice to FullFathom, provided the assignee has financial standing no worse than the Customer and assumes all obligations under these Terms.

17.5. Notices. All notices under these Terms shall be in writing and delivered by email to the addresses provided during registration (for the Customer) and to legal@fullfathom.ai (for FullFathom), or to such other address as either party may designate in writing.

17.6. Third-Party Rights. A person who is not a party to these Terms has no rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of these Terms.

17.7. Export Compliance. The Customer shall comply with all applicable export control and sanctions laws and regulations in connection with its use of the Service.

17.8. Anti-Corruption. Each party shall comply with all applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010.

17.9. Sanctions and Trade Controls.The Customer represents and warrants that neither it, nor any entity controlling, controlled by, or under common control with it, nor any vessel for which it requests a Bundle, is (a) listed on any applicable sanctions list (including the US Office of Foreign Assets Control (OFAC) Specially Designated Nationals list, the UK Office of Financial Sanctions Implementation (OFSI) Consolidated List, the European Union Consolidated List, or any United Nations Security Council sanctions list), (b) owned or controlled by a person on any such list, or (c) located in or organised under the laws of a comprehensively sanctioned jurisdiction. The Customer shall not use the Service to process documents for, or generate Bundles for, any such vessel, person, or jurisdiction. The Customer shall notify FullFathom promptly if any representation in this §17.9 ceases to be accurate, and FullFathom may suspend the Service and, after a reasonable cure period, terminate these Terms for cause under §13.4 if the representation becomes or was inaccurate. FullFathom's suspension or termination under this §17.9 shall not give rise to any refund or other liability.

17.10. Acceptable Use. The Customer shall not, and shall not permit any third party to:

1. Resell, sublicense, lease, or otherwise make the Service available to any third party except as expressly permitted under these Terms;
2. Reverse engineer, decompile, or disassemble the Service, except to the extent such restriction is prohibited by applicable law;
3. Use the Service to build, train, or improve a competing product or service, including any artificial intelligence model intended for competitive offering;
4. Publish benchmarks, performance tests, or comparative analyses of the Service without FullFathom's prior written consent;
5. Use the Service to process documentation for weapons systems, munitions, or other dual-use goods subject to heightened export control;
6. Interfere with or disrupt the integrity, security, or performance of the Service;
7. Upload documents that infringe the intellectual property rights of any third party, contain malware or malicious code, or violate applicable law;
8. Use the Service in a manner inconsistent with §7 (Customer Responsibilities), §17.7 (Export Compliance), §17.8 (Anti-Corruption), or §17.9 (Sanctions and Trade Controls).

18. Definitions

For the purposes of these Terms, the following definitions apply in addition to definitions provided elsewhere in these Terms:

• "Activation Date"means the date on which the first Bundle is deployed to the Customer's first designated vessel.
• "Bundle" means a self-contained software package generated by the Cloud Platform comprising the AI inference model, document embeddings, vector search index, metadata database, runtime application, and user interface, specific to a Customer and vessel.
• "Cloud Platform" means the FullFathom cloud-based SaaS platform for document processing, fleet management, and Bundle generation.
• "Customer Data" means all documents, data, and other materials uploaded to or generated through the Service by or on behalf of the Customer.
• "Ship Runtime" means the on-vessel AI runtime application that operates offline on vessel hardware.
• "Service" means the Cloud Platform and Ship Runtime collectively.

Contact Information

Propel Group International Ltd (trading as FullFathom AI)
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
Company Number: 16943846

Email: legal@fullfathom.ai

Website: https://fullfathom.ai