Adviser Terms

earmarkIQ

Version 2026-10 · Last updated: 10 November 2026

These Adviser Terms ("Terms") govern the use of the earmarkIQ adviser account and dashboard ("the Adviser Service") by financial advisers, planners, mortgage brokers, accountants and their firms. They are an agreement between earmarkIQ Ltd, a company registered in England and Wales (Companies House number 17056081) ("earmarkIQ", "we", "us"), and the firm named in your application ("the Firm", "you"). The person who applies accepts these Terms for the Firm and confirms they have authority to do so.

These Terms sit alongside our Terms of Service and Privacy Policy, which continue to apply to the earmarkIQ account you sign in with, and the Adviser Data Processing and Sharing Agreement, which forms part of these Terms. Where they conflict on the Adviser Service, these Terms take priority.

1. Who we are

earmarkIQ is acting as an agent of Finexer Ltd, which is authorised by the Financial Conduct Authority under the Payment Services Regulations 2017 (firm reference number 925695) as an Authorised Payment Institution to provide account information services.

The authorisation described above is held by Finexer Ltd, not by earmarkIQ. earmarkIQ is not itself authorised by the Financial Conduct Authority and does not give financial, investment, mortgage, tax or legal advice.

2. The Adviser Service

The Adviser Service lets an approved adviser:

• invite clients to connect to them on earmarkIQ;
• view the information each connected client has chosen to share, such as categorised spending totals and, where the client has switched them on, balances and assets, income and pay dates, and individual transactions;
• review flagged items and changes in a client's spending over time; and
• export that information for use in the Firm's own planning and record-keeping.

The information comes from the client's bank connections made through Open Banking and from details the client has entered. It is categorised automatically and may be incomplete, delayed or wrongly categorised. It is not a verified statement of a client's finances and you should confirm anything you rely on with the client.

3. Applying and approval

• You apply using an ordinary earmarkIQ account. The email address on that account is treated as your work email.
• You must give accurate details about yourself and the Firm, including the Firm's FCA firm reference number and your individual reference number where the Firm is FCA-regulated, and the Firm's ICO registration number.
• We check applications by hand, including against the FCA Register, and may ask for more information. We may approve or decline an application at our discretion.
• You must tell us promptly if any of those details change, including any change to the Firm's or your own regulatory status.

4. Your account and security

• Each adviser account is for one named individual. Do not share sign-in details or allow anyone else to use your account.
• Two-factor authentication is mandatory. Client information stays locked until it is set up, and you will be asked for a code each time you sign in.
• Keep your recovery codes somewhere safe. You are responsible for activity under your account.
• Tell us without delay at support@earmarkiq.app if you suspect unauthorised access to your account or to client information.

5. Inviting clients and their consent

• You may only invite people who are your clients or prospective clients, who know about earmarkIQ, and who have agreed to receive an invitation from you. If you give us a client's email address, you confirm you are entitled to do so.
• An invitation is a single-use code. The client redeems it signed in to their own earmarkIQ account and then decides what you may see. Nothing is shared until they accept.
• The client controls the scope of what is shared and can change it or withdraw access at any time. When they do, your access ends immediately. You can also remove a client yourself.
• Clients can see a log of when their adviser has viewed or exported their information.
• You must not pressure a client to share more than they wish, make sharing a condition of something unrelated, or try to obtain access to a client's earmarkIQ account by any other route.

6. Client seats and earmarkIQ Pro for clients

Your account carries an allowance of connected clients ("seats"), shown in the dashboard. Each connected client uses a seat, and an open invitation holds one until it is used, withdrawn or expires. While a client is connected to you, earmarkIQ Pro is included for that client at no cost to them. It ends when the connection ends, and we tell the client when it does.

7. How you may use client information

You may use information obtained through the Adviser Service only to provide your professional services to the client it relates to, and to keep the records your regulatory obligations require. You must not:

• sell it, or use it for marketing by or for third parties;
• use it for any purpose the client would not reasonably expect from their relationship with you;
• combine it into datasets for resale, benchmarking for third parties, or training of machine-learning models;
• attempt to re-identify, scrape, or access information beyond what a client has shared; or
• use the Adviser Service in a way that breaches the law or your regulator's rules.

8. Your regulatory responsibilities

You remain solely responsible for the advice and services you give your clients and for meeting your own legal and regulatory obligations, including those of the FCA, HM Revenue and Customs, your professional body and the ICO, as they apply to you. Nothing in the Adviser Service is a personal recommendation, a suitability assessment or a substitute for your own fact-finding and judgement.

9. Fees

Unless we have agreed fees with the Firm in writing, the Adviser Service is provided to the Firm without charge. If we introduce charges for the Adviser Service or for additional seats, we will give you at least 30 days' written notice, and you may stop using the Adviser Service before they take effect.

10. Suspension and ending

• You may close your adviser account at any time by contacting us.
• We may suspend or close an adviser account, or a Firm's access, immediately where we reasonably believe these Terms have been breached, where the Firm's or adviser's regulatory status has changed, where there is a security risk, or where the law requires it. Otherwise we may end the Adviser Service on 30 days' notice.
• When an adviser account is suspended or closed, connections to its clients end, your access to their information stops, and the earmarkIQ Pro included for those clients ends.
• Information you have already exported remains your responsibility under the Adviser Data Processing and Sharing Agreement.

11. Availability and changes

We aim to keep the Adviser Service available but do not guarantee uninterrupted access. Bank connections depend on third parties and can fail or lapse. We may change or withdraw features, and will give reasonable notice of changes that materially reduce what you can do.

12. Intellectual property

The Adviser Service, its software and branding belong to earmarkIQ Ltd or its licensors. You receive a limited, non-exclusive, non-transferable right to use it for your own professional practice while your account is active. You must not copy, resell, reverse-engineer or build a competing product from it.

13. Liability

To the maximum extent permitted by law:

• we are not liable for advice you give, decisions you or your clients make, or losses arising from reliance on information shown in the Adviser Service;
• we are not liable for indirect or consequential loss, or for loss of profit, business or goodwill; and
• our total aggregate liability to the Firm in any 12-month period is limited to the greater of (a) the fees the Firm paid us for the Adviser Service in that period, or (b) £1,000.

Nothing in these Terms limits liability for death or personal injury caused by negligence, for fraud, or for any other liability that cannot be limited by law.

You will compensate us for losses we suffer because you invited or accessed the information of a person without the authority these Terms require, or used client information in breach of section 7.

14. Confidentiality

Each of us will keep confidential the non-public information we learn about the other's business through the Adviser Service and use it only for the purposes of these Terms, except where disclosure is required by law or a regulator.

15. Changes to these Terms

We may update these Terms. The version and date at the top show the current one. For material changes we will give reasonable notice by email or in the dashboard, and may ask you to accept the new version to continue.

16. Governing law

These Terms are governed by the laws of England and Wales. Any dispute will be subject to the exclusive jurisdiction of the courts of England and Wales.

17. Contact

Questions about these Terms: support@earmarkiq.app

earmarkIQ Ltd
Company number: 17056081
Registered office: Flat 3, Ash Lodge, Northbourne Road, London, SW4 7DS, United Kingdom