Terms of Use

Version 1.0 · October 2026

These Terms of Use are an agreement between you and Loyalty Digital Pty Ltd (ACN 700 489 916), which operates Accrue - CPD (“Accrue”, “we”, “our”, “us”). They govern your access to and use of the Accrue platform, our websites, and any related services we provide.

By registering for an Accrue account, or by using Accrue, you agree to these Terms. If you do not agree to these Terms, do not register for, or use, Accrue.

1. About these Terms

Accrue - CPD is a continuing professional development platform for Australian financial advisers and the licensees that oversee them, and for registered tax and BAS agents and the professional associations that support them. It is designed to capture, classify, and evidence CPD activity in a way that supports regulatory record-keeping under the Corporations Act 2001 (Cth) and the Corporations (Relevant Providers Continuing Professional Development Standard) Determination 2018 and, for tax and BAS agents, the continuing professional education requirements of the Tax Practitioners Board.

These Terms apply to every person who accesses Accrue, whether you are using the product because your licensee has subscribed (an Authorised User accessing under a Client Agreement), because you have subscribed directly (a Direct User), or because we have granted you access for evaluation, support, or administrative purposes. "Authorised User" has the same meaning as in the relevant Client Agreement.

2. How this works with your licensee

If you use Accrue because your licensee has subscribed to it on behalf of its advisers, your licensee has entered into a separate commercial agreement with us (the Client Agreement) that sets out fees, term, scope of access, and the licensee's obligations as the subscriber.

These Terms govern your individual access to Accrue. The Client Agreement governs the licensee's commercial relationship with us. Where the two documents address the same matter and a conflict arises, the Client Agreement governs as between us and the licensee, and these Terms govern as between us and you.

Where you are a Direct User, there is no Client Agreement, and these Terms, including Schedule A, set out the entire relationship between you and us.

3. Definitions

Capitalised terms used in these Terms have the meanings given below.

• Accrue, we, our, us means Loyalty Digital Pty Ltd (ACN 700 489 916), which operates Accrue - CPD.

• Account means your individual user account on Accrue.

• Client Agreement means the commercial agreement (if any) between your licensee and Accrue under which you have been granted access.

• CPD Record means the record of your continuing professional development activity held within Accrue, including each captured activity, its classification, and the evidence-of-learning associated with it.

• Licensee means the Australian Financial Services Licensee (AFSL) under whose authorisation you operate as a financial adviser or, for people who are not financial advisers, the organisation (such as a tax or BAS practice) that subscribes to Accrue for its people, in each case where it is a subscriber to Accrue.

• Platform means the Accrue - CPD web application, our websites, and any related services we make available to you.

• Privacy Policy means our Privacy Policy as updated from time to time, available at https://accrue-cpd.com.au/privacy.

• Retention Period means the period for which we retain CPD records, as set out in section 14 of the Privacy Policy.

• Uploaded Content means any document, file, certificate, article, or other material you upload to Accrue.

• You, your means the individual using the Platform under these Terms.

4. Your account

4.1 Registration

To use Accrue you need an Account. You may register an Account directly, or your licensee may register one on your behalf. When you first sign in, you confirm that the information held about you on the Account is accurate, and that you accept these Terms. We record the version of these Terms you accepted and when you accepted it.

4.2 Account responsibility

Your Account is personal to you. You are responsible for:

• keeping your login credentials confidential and secure;

• all activity that occurs under your Account, whether or not authorised by you;

• notifying us promptly if you suspect any unauthorised access to your Account; and

• keeping your contact details (including your work email address) up to date.

4.3 No shared accounts

You may not share your login credentials with any other person, allow any other person to use your Account, or use another person's Account in place of your own. Each user must have their own Account. This applies whether or not the other person also has access to Accrue under a separate Account.

4.4 ASIC FAR validation

If you register as a financial adviser, you authorise us to validate your registration on the public ASIC Financial Advisers Register (FAR) at the time you register and periodically thereafter. If your FAR record indicates that you are no longer an authorised representative, we will not suspend or terminate your Account on that basis alone. Instead, we will offer you the option of continuing on the Non-Adviser tier of the Platform, which is designed for paraplanners, BDMs, retired advisers, and other professionals who wish to maintain their CPD records outside the FAR. If you decline the tier change and do not return to authorised status within ninety (90) days, your subscription will close in accordance with clause 11.3.

4.5 Joining a Licensee

If you hold a Direct User Account and a Licensee that subscribes to Accrue invites you to join it, your Account moves to that Licensee only if you accept the invitation while signed in to your Account. If you do not accept, nothing changes.

When you accept:

• your whole CPD Record, including activity recorded before you joined, moves with you and becomes visible to the Licensee on the terms set out in clause 8;

• CPD years that ended before the move stay exactly as they were recorded, and the CPD year in progress follows the Licensee's CPD year;

• your Direct User subscription is cancelled with effect from the end of its current billing period, without a refund for that period; and

• from the date of the move, fees for your access are payable by the Licensee under its Client Agreement.

5. Acceptable use

You agree that you will not, and will not attempt to:

• use Accrue for any unlawful purpose, or in a way that breaches any applicable law, regulation, or your professional obligations as a financial adviser;

• use Accrue to record CPD activity that you did not actually undertake, or to falsify, backdate, or otherwise misrepresent your CPD activity;

• upload to Accrue any document or content you do not have the right to upload, or that infringes the intellectual property or other rights of any third party;

• upload to Accrue any content that is malicious, offensive, defamatory, or otherwise inappropriate;

• copy, reproduce, distribute, sell, resell, or sublicense any part of the Platform or the content within it, other than your own CPD Record and Uploaded Content;

• reverse-engineer, decompile, or attempt to derive the source code of the Platform, or any algorithm or classification model used within it;

• use any automated means (including bots, scrapers, or crawlers) to access, monitor, or copy material from the Platform, other than where we have expressly granted you API access;

• interfere with or attempt to circumvent any security feature of the Platform; or

• use the Platform in a manner that imposes an unreasonable or disproportionately large load on our infrastructure.

6. Intellectual property

6.1 Accrue's intellectual property

We own all existing and future intellectual property rights in the Platform, including the software, the user interface, the design, the documentation, the classification taxonomy we apply to CPD activity (across the regulated CPD areas and the underlying knowledge areas), the quiz pool content we author, and any aggregated or de-identified data derived from use of the Platform. Nothing in these Terms transfers any of these rights to you.

We grant you a non-exclusive, non-transferable, revocable licence to access and use the Platform for the purpose of managing your own CPD activity, for the duration of your Account, on the terms set out in these Terms.

6.2 Your CPD Record and Uploaded Content

You retain ownership of your CPD Record and any Uploaded Content. This is a deliberate position: your CPD Record is yours, not ours. We hold it for you and process it on your behalf, on the terms set out in these Terms and in the Privacy Policy.

You grant us a non-exclusive, royalty-free licence to host, store, process, display, classify, and (where appropriate) share your CPD Record and Uploaded Content with your Licensee, in each case to the extent necessary to provide the Platform to you and to your Licensee.

On termination of your Account, you may request an export of your CPD Record. We will provide the export in a structured, commonly used machine-readable format within fourteen (14) business days after the request, at no cost, and in any event before we delete the underlying data in accordance with our retention policy.

Where you have claimed CPD against a scoped library entry uploaded by your Licensee or another licensee, your CPD activity record relating to that claim (provider, date, hours, classification, summary, assessment outcome, and attestation) is retained for the Retention Period. Where you have held a paid Account at any point (whether directly through a Direct User subscription, or as an Authorised User accessing under a Client Agreement that was current at the time), you retain free read-only access to your CPD records and to any scoped library entries you have claimed against for the Retention Period, including after your paid access has ended. Read-only access means you may view your records, generate compliance reports from them, and export them; it does not include the ability to add new CPD activity. To continue adding new CPD activity after your paid access has ended, a paid Direct User plan applies (see Schedule A).

Where you transfer from one Licensee to another, the underlying scoped content artefact uploaded by your former Licensee ceases to be downloadable by you on the date the transfer takes effect. Your CPD activity record relating to that content, including the provider, date, hours, and classification, remains visible to you for audit-trail purposes.

6.3 Third-party content in the library

Accrue's library lists articles and other material published by third parties. For each entry we hold the title, the source, a link, our classification and any comprehension questions. We do not reproduce the material itself: you read it at the publisher's site.

Each entry carries a label showing how it came to be in the library: Curated (we selected it from a public source), Provider (an approved provider published it with their agreement and is named), or Sponsored (the provider pays to have it in the library and is named). A label shows where an entry came from. It is not our endorsement of the material or its provider, and it does not change how the entry is classified or credited.

The intellectual property in third-party material remains with its owner. You must not reproduce, redistribute, or commercially exploit it beyond what the Copyright Act 1968 (Cth) and the publisher's own terms permit.

6.4 Feedback

If you provide us with feedback, comments, suggestions, or ideas about the Platform, you grant us a non-exclusive, royalty-free, perpetual licence to use that feedback to improve or develop the Platform. We will not identify you publicly as the source of any feedback without your consent.

7. CPD compliance is your responsibility

This is the most important clause in these Terms. Read it carefully.

Accrue is a CPD record-keeping tool. It is designed to help you capture, classify, and evidence CPD activity efficiently, and to give your Licensee visibility of your CPD position. It is not a regulator, a certifying body, or a substitute for the professional judgement that you and your Licensee are required to exercise in meeting your CPD obligations under Australian law.

Specifically, and despite anything else in these Terms or in any communication from us:

• we do not warrant or represent that the use of Accrue, or the records held in Accrue, will satisfy your CPD obligations or those of your Licensee under the Corporations Act 2001 (Cth), the CPD Determination, or any other law;

• responsibility for meeting your CPD obligations remains with you and your Licensee at all times. For financial advisers this includes the 40-hour annual minimum, the minimums applicable to each of the regulated CPD areas and, if you provide tax (financial) advice services, the Tax (Financial) Advice category in addition. For tax and BAS agents it includes the continuing professional education requirements of the Tax Practitioners Board;

• where Accrue automatically classifies a CPD activity (for example, by using AI-assisted tools to read a certificate you upload, to analyse an article from a link, or to generate comprehension questions), the classification is a best-effort guide intended to reduce friction. It is not a determination of whether the activity meets the regulatory requirements of any particular CPD area. You are responsible for reviewing, correcting, and confirming classifications before you rely on them; and

• the compliance reports Accrue generates are produced from the data held in your Account at the time the report is generated. We do not warrant that those reports are complete, accurate, or sufficient for the purposes of any regulatory submission, audit, or proceeding. You and your Licensee remain responsible for verifying the contents of any report before relying on it.

8. Privacy

Our handling of personal information is set out in our Privacy Policy. By using Accrue you acknowledge that we may collect, hold, use, and disclose personal information about you as described in the Privacy Policy.

Where you are an Authorised User accessing under a Client Agreement, you also acknowledge that your Licensee will have visibility of your CPD Record for the purposes set out in the Privacy Policy, including compliance oversight, audit, and regulatory reporting. If you join a Licensee under clause 4.5, this includes the CPD Record you built before joining.

You also acknowledge that our platform admin staff retain visibility of scoped content (including content scoped to a specific licensee tenant) where reasonably necessary for debugging, support, security investigation, or removal. Every such access is recorded in an audit log. The access and audit-logging arrangements are set out in more detail in the Privacy Policy. This is an express exception to the scope-isolation framework that otherwise prevents users in one tenant from accessing content scoped to another.

9. Service availability and changes

We aim to keep Accrue available at all times but we do not guarantee uninterrupted access. From time to time the Platform may be unavailable for scheduled maintenance, for emergency repair, or for reasons beyond our reasonable control.

We may add, change, or remove features of the Platform at any time. Where a change materially reduces the functionality available to you, we will give you reasonable notice before the change takes effect.

10. Fees and billing

If you are an Authorised User accessing under a Client Agreement, fees for your access to Accrue are payable by your Licensee under the Client Agreement. You personally are not required to pay fees to us for that access.

If you are a Direct User, fees and payment terms are set out in Schedule A (Direct User subscription) and in the plan you select on registration. Direct User fees are payable in advance and are non-refundable except where required by law.

All fees are quoted in Australian dollars and exclusive of GST unless stated otherwise. We may change our fees from time to time. Where a fee change affects an active subscription, we will give you advance notice and the change will take effect at the start of your next billing period.

11. Suspension and termination

11.1 Termination by you

You may stop using Accrue at any time. If you are a Direct User, you may cancel your subscription through the Stripe customer portal or by contacting us; cancellation takes effect at the end of your current billing period. If you are an Authorised User accessing under a Client Agreement, your access generally continues for as long as the Client Agreement is in effect and you remain authorised by your Licensee.

11.2 Termination by us

We may suspend or terminate your Account, in whole or in part, where:

• you breach these Terms, and (where the breach is capable of remedy) you do not remedy the breach within a reasonable period after we notify you;

• your continued use of the Platform poses a security, legal, or operational risk to us, your Licensee, or other users;

• you remain off the ASIC FAR for more than ninety (90) days following the offer of a Non-Adviser tier under clause 4.4, and you have not accepted the tier change;

• your Licensee notifies us that you are no longer entitled to use Accrue under their Client Agreement; or

• the Client Agreement (where applicable) is terminated or expires.

11.3 Effect of termination

On termination of your paid Account, your paid access to the Platform ends. Where you held a paid Account at any point, the free read-only access described in clause 6.2 applies for the Retention Period, without further charge and without further action required from you. Before your paid access ends, we will (a) provide you with a complete export of your CPD Record in accordance with clause 6.2, at no cost, and (b) offer you the option to migrate to the Non-Adviser tier on the prevailing self-serve pricing terms, which provides continuing read-only access plus the ability to add new CPD activity outside the FAR. The free read-only access continues to be available even if you decline the paid migration. After the Retention Period, records are subject to the retention policy described in our Privacy Policy. Provisions of these Terms that by their nature are intended to survive termination (including intellectual property, disclaimers, limitations of liability, confidentiality, and governing law) survive termination.

12. Disclaimers and limitation of liability

12.1 Statutory rights

Nothing in these Terms excludes, restricts, or modifies any right or guarantee you have under the Australian Consumer Law or any other law that cannot lawfully be excluded, restricted, or modified by agreement. Where a guarantee under the Australian Consumer Law cannot lawfully be excluded but can be limited, our liability for breach of that guarantee is limited (at our election) to resupplying the Platform or paying the cost of resupply.

12.2 No other warranties

Subject to clause 12.1, the Platform is provided on an “as is” and “as available” basis. We do not warrant that the Platform will be uninterrupted, error-free, secure against every possible threat, or fit for any particular purpose. In particular, and without limiting clause 7, we do not warrant that the use of Accrue, or the records held in Accrue, will satisfy any regulatory CPD obligation that applies to you or your Licensee.

12.3 Limitation of liability

Subject to clause 12.1, and to the maximum extent permitted by law, our total aggregate liability to you under or in connection with these Terms, whether in contract, tort (including negligence), under statute, or otherwise, is limited to the greater of (a) the fees you have paid to us for the Platform in the twelve months preceding the event giving rise to the liability, or (b) AUD one thousand dollars ($1,000).

Neither party is liable to the other for any indirect, consequential, special, or punitive loss, or for any loss of profit, revenue, business opportunity, goodwill, or data, even if that loss was foreseeable.

13. Confidentiality

You may, in the course of using Accrue, become aware of information that is confidential to us or to other users (including features of the Platform that are not yet publicly released, pricing information communicated to you for the purpose of a commercial discussion, and information about other advisers' CPD performance where you are a licensee administrator). You agree to keep that information confidential, to use it only for the purpose for which it was disclosed to you, and not to disclose it to any third party except as required by law.

14. Notices

We will give you notices under these Terms by email (to the address on your Account), by a notice within the Platform, or by posting on our website at https://accrue-cpd.com.au. Notices take effect when sent or, in the case of a notice on the website, when posted.

You may give us notices under these Terms by emailing hello@accrue-cpd.com.au or, for privacy matters, privacy-team@accrue-cpd.com.au, or by writing to us at PO Box 1766, Sydney NSW 2001.

15. Changes to these Terms

We may update these Terms from time to time. Where we make a material change, we will notify you in advance (typically by email and through a notice in the Platform) and we will ask you to accept the updated Terms on your next sign-in. Non-material changes (such as clarifications, corrections, or formatting changes) may be posted without separate notice.

If you do not accept a material change to these Terms, you may close your Account. Continued use of the Platform after the change takes effect constitutes your acceptance of the updated Terms.

16. Governing law and jurisdiction

These Terms are governed by the laws of New South Wales, Australia. Each party submits to the exclusive jurisdiction of the courts of New South Wales and the courts of appeal from them in respect of any dispute arising under or in connection with these Terms.

17. General

17.1 Entire agreement

These Terms, together with the Privacy Policy and any Client Agreement (where applicable), set out the entire agreement between us in relation to your use of the Platform, and supersede all prior agreements, representations, and understandings on that subject.

17.2 Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable, the remaining provisions continue in full force and effect, and the invalid provision is to be read down to the minimum extent necessary to make it valid and enforceable, or, if that is not possible, severed.

17.3 Waiver

A failure or delay by us to exercise a right under these Terms does not operate as a waiver of that right. A waiver of any right under these Terms is effective only if given in writing.

17.4 Assignment

You may not assign or otherwise transfer your rights or obligations under these Terms without our prior written consent. We may assign or transfer our rights and obligations under these Terms (including to a related body corporate, or to a purchaser of the Accrue business) on notice to you.

17.5 No partnership

Nothing in these Terms creates a partnership, agency, joint venture, or employment relationship between you and us.

17.6 Contact

If you have any questions about these Terms, please contact us at hello@accrue-cpd.com.au or write to us at PO Box 1766, Sydney NSW 2001. For privacy matters, please contact privacy-team@accrue-cpd.com.au.

Schedule A - Direct User Subscription

This Schedule sets out the subscription terms that apply where you access Accrue as a Direct User. It is to be read with the body of these Terms.

A.1 Plans and fees

Two Direct User plans are offered on a self-serve basis through our website. The Adviser plan, designed for FAR-registered relevant providers, is AUD thirty dollars ($30) per month, exclusive of GST. The Non-Adviser plan, designed for paraplanners, BDMs, retired advisers, and other professionals who maintain CPD records outside the FAR, is AUD twenty dollars ($20) per month, exclusive of GST. Plan details, exact fees, and any updates to either are published on our website at accrue-cpd.com.au at the point of sign-up; the published terms at the point you complete sign-up are the terms that apply to you. Where you subscribe at a rate agreed between us and a professional association you belong to, that rate applies to you in place of the published fee.

A.2 Trial period

Both Direct User plans include a fourteen (14) day free trial. You may be able to start a trial without giving us a payment method. If you register a payment method when you start a trial, it is held by Stripe under its standard arrangements and is used to bill the first month at the end of the trial unless you cancel before the trial ends; you may cancel at any time during the trial through the Stripe customer portal. If you start a trial without a payment method, nothing is billed, and to continue after the trial you subscribe and register a payment method, with billing starting from the date you subscribe.

A.3 Billing cycle and cancellation

Subscription fees are billed monthly in advance to your registered payment method. You may cancel your subscription at any time through the Stripe customer portal or by contacting us. Cancellation takes effect at the end of the billing period in which the cancellation is received; fees already paid for that period are not refunded except where required by law. On cancellation of a paid Direct User subscription, the free read-only access described in clause 6.2 applies for the Retention Period.

A.4 Fee changes

We may change Direct User plan fees on at least sixty (60) days' written notice to you, with the new fees taking effect from the next renewal of your billing cycle after the notice period. You may cancel within the notice period without further fee obligation if you do not accept the change.

A.5 Consent and communications

When you sign up as a Direct User, you authorise us to send you service-related communications (account, security, billing, and product-change messages). Marketing communications are only sent in line with the inferred-consent treatment described in section 17 of our Privacy Policy. You can opt out of marketing communications at any time.

A.6 Eligibility and FAR validation

The Adviser plan is offered to individuals who are registered as relevant providers on the ASIC Financial Advisers Register at the time of sign-up. We may validate your FAR registration in accordance with clause 4.4 of these Terms. If your FAR status changes during your subscription, the tier-change pathway described in clause 4.4 applies.

A.7 Termination

We may terminate your Direct User subscription in accordance with clause 11.2 of these Terms. On termination, the export and access provisions in clause 11.3 apply. The clause 4.4 tier-change pathway is the preferred route for FAR-departure cases.