1. Acceptance of Terms

By accessing or using the 47FUNDS platform (the "Platform"), owned and operated by SC TESTGATE SRL, registered in Romania under CUI 47003208, with registered office in Târgoviște, Dâmbovița, you agree to be bound by these Terms of Service ("Terms").

If you use the Platform on behalf of a consultancy, enterprise, or other legal entity, you represent that you have authority to bind that entity, and references to "you" mean that entity. If you do not agree to these Terms, you must not use the Platform.

2. Description of Services

47FUNDS provides two interconnected service tiers:

Consultant Copilot (B2B Enterprise):An institutional-grade platform for professional EU-funds consultants (COR 242213). Features include: Eligibility Batch Scanner, Ghid Oracle Q&A, SF/DALI Drafting Engine, Portfolio Monitor, Partner Matchmaking, Post-Award AI, and Clarificări Indexer.
Grant-Bot SaaS (B2C): A guided application tool for Romanian SMEs, featuring: CUI Matchmaker, 72-Hour Application Wizard, STEP Seal Detection, compliance checklists, and deadline alert notifications.

Both tiers connect to Romanian national registries (ANAF, ONRC, RegAS) and the MySMIS2021 portal via secure read-only bridges for data verification purposes only.

3. AI-Assisted Features — Important Disclaimer

The Platform uses artificial intelligence and machine learning, including Retrieval-Augmented Generation (RAG), to produce grant-eligibility assessments, SF/DALI document drafts, compliance suggestions, and scoring outputs (collectively, "AI Outputs").

AI Outputs are drafts and suggestions only. They do NOT constitute legal advice, financial advice, or professional consulting services. AI Outputs must be reviewed, verified, and certified by a qualified human professional before any official submission to MySMIS2021, ANAF, or any other state authority.

The automated eligibility scoring produced by the CUI Matchmaker and Scoring Engine constitutes automated decision-making within the meaning of GDPR Article 22. You have the right to request human review of any automated assessment. See our GDPR Compliance page for details.

SC TESTGATE SRL accepts no liability for rejected applications, financial corrections, or any adverse outcome arising from reliance on AI Outputs without independent professional verification.

4. Registry Connectivity

The Platform connects in read-only mode to ANAF V.6, ONRC, RegAS 2, and MySMIS2021. While we target 99.9% Platform uptime, we are not responsible for outages, incorrect data, or refusals originating from government-maintained infrastructure. The Platform employs a Dead-Man's Switch mechanism (BullMQ) to timestamp and log submission attempts during state portal downtime; this log constitutes best-effort evidence of attempted compliance but carries no legal guarantee of acceptance by the relevant authority.

5. WORM Archiving & Law 201/2024

The Document Archive module uses Write-Once-Read-Many (WORM) storage designed to satisfy the integrity requirements of Law 201/2024 on digital archiving. Documents are SHA-256 hashed and immutably stored for the legally required retention period (minimum 10 years for EU-funded project documentation). Users are responsible for ensuring that metadata supplied during ingestion is accurate and complete. SC TESTGATE SRL is not responsible for archival failures arising from inaccurate or incomplete metadata provided by the user.

6. Intellectual Property

SC TESTGATE SRL retains all rights to the Platform, the sven.systems AI engine, prompt templates, compliance algorithms, and all underlying software (collectively, "Platform IP"). You receive a limited, non-exclusive, non-transferable licence to use the Platform for your internal business purposes under the applicable subscription tier.

Documents you create using the Platform's drafting tools ("User Outputs") are your property. You grant SC TESTGATE SRL a limited licence to process User Outputs solely for the purpose of providing the Service (storage, AI refinement, export) and — in anonymised, aggregated form only — for improving the Platform's AI models. We do not use identifiable SF/DALI text to train shared models. See our Privacy Policy for full details.

7. Acceptable Use & Restrictions

You must not use the Platform to:

Submit knowingly false, misleading, or fraudulent grant applications to any Romanian or EU authority. Such conduct may constitute fraud under the Romanian Penal Code and EU Regulation No 2988/95 and will be reported to the Anti-Fraud Department (DLAF) and the European Anti-Fraud Office (OLAF).
Circumvent the subscription-tier limits by automated scripting, API abuse, or high-frequency registry lookups exceeding your agreed thresholds.
Reverse-engineer, copy, or redistribute the Platform's compliance algorithms, prompt libraries, or AI model outputs for commercial use outside the Platform.
Process personal data in violation of GDPR or Romanian Law 190/2018 — including uploading data of individuals who have not consented to processing by the Platform.

Violation of this section will result in immediate account suspension and, where legally required, reporting to competent authorities.

8. Data Processing & GDPR

SC TESTGATE SRL acts as Data Controller for your account data and as Data Processor for client company data you upload as a consultant. Enterprise (B2B) subscribers must execute a Data Processing Agreement ("DPA") as Annex A to these Terms before uploading any client personal data. The DPA is available at /legal/dpa. Processing without an executed DPA is not permitted.

For full information on how we process personal data, lawful bases, data subject rights, and retention periods, see our Privacy Policy.

9. Limitation of Liability

To the maximum extent permitted by Romanian law, SC TESTGATE SRL's total aggregate liability to you for any claim arising under or in connection with these Terms shall not exceed the total subscription fees paid by you in the twelve (12) months preceding the event giving rise to the claim.

SC TESTGATE SRL shall not be liable for: (a) any indirect, consequential, or special loss; (b) loss of profits, loss of contracts, or loss of anticipated savings; (c) grant application rejections, financial corrections, or reimbursement clawbacks arising from AI Outputs; (d) outages or incorrect data from government registries (ANAF, ONRC, MySMIS2021, RegAS); or (e) force majeure events including government infrastructure failures, cyber incidents affecting state portals, or regulatory changes to programme eligibility rules.

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

10. Subscription & Payment

Subscription fees are set out on the Pricing page. B2C (Grant-Bot) consumers have a 14-day statutory cancellation right from the date of subscription under OG 21/1992. B2B (Consultant Copilot) annual licences are non-refundable after the 14-day onboarding period. Monthly plans may be cancelled with 30 days' written notice. No refund is issued for partial months unless SC TESTGATE SRL terminates the agreement for reasons within its control.

11. Termination

Either party may terminate these Terms with 30 days' written notice. SC TESTGATE SRL may suspend or terminate immediately for material breach (including violation of §7) or non-payment. Upon termination, you have 60 days to export your data via the Settings > Data Export hub. After 60 days, your account data will be anonymised per our data retention schedule and the GDPR purge protocol.

Sections 3, 6, 9, 12, and 13 survive termination.

12. Governing Law & Jurisdiction

These Terms are governed by Romanian law. Any dispute arising under or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of Târgoviște, Dâmbovița, Romania (the registered seat of SC TESTGATE SRL), without prejudice to mandatory consumer-protection provisions applicable to B2C subscribers in their country of residence.

For EU consumers, the European Commission's Online Dispute Resolution platform is available at ec.europa.eu/consumers/odr.

13. Changes to These Terms

We will notify you of material changes to these Terms by email and in-platform notice at least 30 days before the changes take effect. Continued use of the Platform after the effective date constitutes acceptance. If you do not agree, you may terminate your subscription within the notice period without penalty.

14. Contact

SC TESTGATE SRL · CUI 47003208 · Târgoviște, Dâmbovița, România
Legal enquiries: legal@47funds.ro
Data Protection: dpo@47funds.ro