Last updated: October 2026
Additional Legal Documents
Short documents that apply in specific situations. Each forms part of the Terms where it applies.
Electronic Communications and E-Signature Consent
1. You agree to receive notices, disclosures, statements, invoices, agreements and other communications from the Emanay Group electronically, through the Emanay Products or by email, and agree that they satisfy any requirement that they be in writing.
2. You agree to sign agreements electronically, and that your electronic signature has the same legal effect as a handwritten one, under the federal Electronic Signatures in Global and National Commerce Act (E-SIGN) and the Florida Uniform Electronic Transaction Act.
3. To receive and keep electronic records you need a current web browser, an email account and the ability to download or print PDFs.
4. You may withdraw this consent, or ask for a paper copy of any document, by writing to legal@emanay.io. Withdrawing consent may end your access to the Emanay Products. Keep your email address up to date.
SMS and WhatsApp Messaging Disclosure
1. Opt-in. We send text or WhatsApp messages only to people who have given us their number and agreed to receive them, for example for call reminders, account security codes, engagement updates or program information.
2. Opting out. Reply STOP to any text message to opt out, or tell us in WhatsApp. Reply HELP for help. We may send one message confirming your opt-out.
3. Frequency and costs. Message frequency varies. Message and data rates may apply.
4. Your number. We never sell your phone number or share it with third parties for their own marketing. It is shared only with the messaging providers that deliver our messages.
5. Compliance. We follow the Telephone Consumer Protection Act and applicable messaging rules. Consent to marketing messages is not a condition of any purchase or engagement.
ACH Debit and Payment Authorization
1. When you pay Emanay Inc. by ACH debit, card or another method through our payment processor (for example Stripe), you authorise Emanay Inc. and its processor to debit your account for the amount shown on the invoice or statement, and, if you choose recurring or automatic payment, for each later amount due under your Engagement.
2. You confirm you are authorised to use the account. You may revoke a recurring authorisation by writing to payments@emanay.io at least 3 business days before the next debit.
3. Returned or failed payments may incur fees as set out in your Engagement and may suspend services until paid.
4. Payment processing is subject to the processor’s own terms and to the rules of the payment networks.
Invoice Payer Terms
1. Invoices and statements are issued by Emanay Inc. (or, for brokerage commissions, the licensed brokerage) under your Engagement. Pay the issuing company only, using the payment details on the invoice or the payment link in the Emanay Products.
2. We will never change payment instructions by email alone. If you receive new payment details, confirm them with your Emanay contact by phone before paying.
3. Dispute any invoice line in writing within 30 days of the invoice date, with the reason; undisputed amounts remain due on the due date.
4. Late payment, interest and collection terms are set out in your Engagement.
Subscription Services Addendum
Applies only if and when the Emanay Group offers paid subscriptions to the Emanay OS or other Emanay Products.
1. Subscription plans, prices, billing periods and included features are shown at sign-up or in your order.
2. Subscriptions renew automatically for the same period unless cancelled before renewal; you can cancel in your account settings or by writing to us.
3. We may change subscription prices with at least 30 days’ notice before your next renewal.
4. Fees already paid are non-refundable except where the law requires or we state otherwise.
Data Processing Addendum
1. Roles. When the Emanay Group keeps books, runs systems, manages records or operates a client office for a client’s companies or family office, the client is the controller (or business) and the Emanay Group is the processor (or service provider) of personal information in that data.
2. Instructions. We process that data only on the client’s documented instructions, which are the Engagement, these terms and the client’s use of the Emanay Products.
3. Confidentiality and security. Everyone who processes the data is bound by confidentiality, and we apply the security measures in the Privacy Policy and Part 1.
4. Sub-processors. We use the sub-processors listed at a list available on request from legal@emanay.io, and will give notice of new sub-processors so the client can object on reasonable grounds.
5. Assistance. We help the client respond to individuals’ requests, carry out risk assessments where required, and meet breach-notification duties, and we notify the client without undue delay after becoming aware of a breach affecting its data.
6. Return and deletion. When the Engagement ends, we return or delete the client’s data at the client’s choice, except where the law requires us to keep it.
7. Audit. We make available information reasonably needed to show compliance with this addendum.
8. Transfers. Cross-border transfers follow Part 7, section 10.
KYC/AML and Identity Verification Notice
1. To help fight money laundering, terrorist financing, fraud and sanctions evasion, and to meet our obligations and those of the banks, lenders and processors we work with, we may verify the identity of clients, their beneficial owners, signatories and counterparties before and during an Engagement.
2. We may ask for your name, address, date of birth, government identification number, identity documents, proof of address, source of funds and source of wealth, and information about the beneficial owners of companies.
3. We may use identity-verification and screening providers, including sanctions and politically-exposed-person screening.
4. We may decline or end an Engagement, or delay a transaction, if we cannot verify identity or if screening raises concerns, and we may not be allowed to tell you why.
Subpoena and Law Enforcement Requests Policy
1. We disclose information to government authorities or private litigants only when we believe in good faith that the law requires it, such as a valid subpoena, court order or search warrant, or in an emergency involving a risk of death or serious injury.
2. We review each request for legal validity and scope, and narrow or challenge requests that are overbroad.
3. Where the law allows, we notify the affected client or user before disclosing, so they can seek to protect their information.
4. Requests must be served on Emanay Inc. at 1221 Brickell Avenue, Suite 900, Miami, Florida 33131, with a copy to legal@emanay.io. Emailed requests do not waive any requirement for valid service.
Programs
These summaries point to signed agreements; the signed agreement always governs.
- Associate and Advisor Program. Independent consultants work on Emanay engagements under a signed Associate Consulting Agreement, which sets their services, attribution, compensation, confidentiality and conduct.
- Referral Partner Agreement. Referral partners introduce clients or opportunities under a signed agreement that sets what counts as a referral, how referral fees are earned and paid, disclosure duties and confidentiality.
- Customer Referral Terms. Clients who refer others may receive a benefit only if offered in writing; any benefit is set by that written offer, and referrers must disclose it where the law or Part 8 requires.
- Referred Customer Terms. People who come to us through a referral are clients like any other: their Engagement governs, any referral relationship is disclosed to them, and referral arrangements never change the advice they receive.