Responsible Use
This policy captures the deliberate boundaries around how the Company's Platform may be used by lending institutions. It exists so the choices made in the product are visibly matched by the choices asked of the people using it.
1. The Service is decision support
The Company's Platform composes a score and a recommendation tier. It does not make lending decisions. Every lending decision made against a Company-produced recommendation must involve the lending institution's own credit policy and human review.
2. Consent is a requirement, not a courtesy
The Service must not be used to score an applicant without an explicit, source-scoped, revocable consent for each signal source read. The Company reserves the right to suspend the Service for any deployment where valid consent is not maintained.
3. Protected attributes are off limits
Identity characteristics and demographic categories are not scoring inputs to the engine and must not be introduced as such by the lending institution through rule configuration. Decisioning rules layered on top of the composite score must not use protected attributes to route, weight or deny an application.
4. Missing signals are not risk signals
The absence of a signal source is data about coverage, not a proxy for risk. Rule configurations that treat missing sources as inherently high risk defeat the purpose of an alternative-data engine and are not a supported use of the Service.
5. No universal creditworthiness claims
The composite score is calibrated to rank order applicants within a comparable segment and a specific lending institution's book. It must not be represented externally as a universal creditworthiness rating, a portable credit score or a substitute for a regulated bureau file.
6. Explainability must reach the applicant where required
Where local regulation entitles an applicant to an explanation for a lending decision, the lending institution is expected to use the per-signal attribution retained by the Service to construct that explanation - not to obscure it. Reason codes and plain-language narratives are provided by the Service to support this.
7. Aggregate use is subject to the same discipline
Portfolio monitoring surfaces are for internal review by the lending institution and its regulator, not for external publication or third-party sharing. Aggregate metrics remain covered by the confidentiality obligations in the Terms of Service.
8. What triggers a review
The Company may review, and where necessary suspend, any deployment where:
- Applications are being auto-approved or auto-declined without human review.
- Applicant consent is not being maintained per source, per applicant, per lending institution.
- Rule configurations rely on protected attributes to route or deny applications.
- The Service is being used outside the regulated lending purposes agreed at deployment.
Review is a conversation before it is an action. Suspension is a last resort - the Company's default is to work with the institution to bring the deployment back into responsible use.