Terms of Service

1. Provider Information (Impressum)

1.1 Service Provider

Trusted Codes is operated by:

Stefan Sonntag
operating under the trade name Trusted Codes
(Sole Proprietor / Einzelunternehmer)

Leonrodstr. 14b
80634 Munich
Germany

Email: legal@trusted.codes

1.2 Legal Status

Trusted Codes is not a separate legal entity. All services are provided by Stefan Sonntag as a sole proprietor under German law. The business is not entered in a commercial register and has no VAT identification number. In these Terms, “Trusted Codes”, “we” and “us” refer to Stefan Sonntag in this capacity.

1.3 Applicable Law and Jurisdiction

German law applies, excluding the UN Convention on Contracts for the International Sale of Goods (CISG). For consumers, this choice of law does not remove the protection of the mandatory law of the country in which they have their habitual residence.

If you are a merchant (Kaufmann), a legal entity under public law or a special fund under public law, or if you have no general place of jurisdiction in Germany, the exclusive place of jurisdiction for all disputes arising from this contract is Munich, Germany.

2. Scope, Conclusion of the Contract and Language

2.1 Scope

These Terms of Service (“Terms”) govern your use of the Trusted Codes service (“Service”): the mobile app, the desktop app, the account and organisation portals, the public verification pages, the programming interfaces, the assistant and the MCP relay.

2.2 Conclusion of the Contract

The contract for the use of the Service is concluded when you create an account and accept these Terms. A contract for a paid plan is concluded when you complete the order in the account portal (my.trusted.codes).

We store the text of these Terms. Each version remains available at its own address on trusted.codes, so you can read the version you accepted at any time.

2.3 Personal Use (Free Plan)

The Free plan is intended exclusively for personal, non-commercial use by individuals. Use for business, commercial, professional or organisational purposes is not permitted under the Free plan. This includes in particular:

• Verifying customers, clients or business contacts
• Integration into business processes or workflows
• Use by employees on behalf of an organisation

Such use requires a Business plan or an Enterprise agreement (Section 5). We may end business use on the Free plan in accordance with Section 12.

2.4 Business Customers

Paid plans are offered exclusively to entrepreneurs within the meaning of §14 BGB (German Civil Code), that is, persons and organisations acting in the exercise of their commercial or independent professional activity. By ordering a paid plan, you declare that you order as an entrepreneur. For Business customers, the Data Processing Agreement applies in addition to these Terms. It is accepted in the account portal when the Business organisation is set up, after the order.

2.5 Minimum Age

You must be at least 16 years old to use the Service. By creating an account, you confirm that you meet this requirement.

2.6 Language

These Terms are published in English, German, Spanish, French, Italian and Dutch. The English text is authoritative. The translations are provided for convenience; where they differ from the English text, the English text governs.

3. Description of the Service

3.1 Core Functionality

Trusted Codes is a verification service for known contacts. Two parties who have connected through the Service see the same rotating code words, derived by cryptographic methods from a secret they share. By comparing the words over any communication channel, they can check that they are dealing with the same party they connected with.

The Service:

• Generates rotating code words for each connection
• Shows and checks code words on your device, also without a network connection once a connection is set up
• Can be used with any communication channel
• Uses end-to-end encryption for code secrets where your app supports it

In some cases we also process code secrets on our servers, for example for codes generated for organisations, for the desktop app and machine clients, for invitations until the recipient’s device has received the secret, and for accounts that use the server key backup. The Privacy Policy describes these cases and how the data is protected.

Trusted Codes does not establish who a person is. It checks whether two parties share the same cryptographic reference.

3.2 Important Transparency Notice

Trusted Codes is one security layer, not a complete fraud prevention system.

In particular:

• The Service verifies consistency, not a person’s original identity
• You should only connect with contacts you have verified through other means
• The Service cannot protect you if verification is skipped
• Trusted Codes cannot prevent fraud committed despite correct use

3.3 What Trusted Codes Is Not

To avoid misunderstanding, Trusted Codes:

• Does NOT establish or confirm the identity of a person; it only checks whether two parties share a cryptographic reference
• Is NOT an authentication or access control system
• Is NOT a fraud prevention, detection or insurance service in any legal, financial or regulatory sense
• Does NOT guarantee protection against scams, impersonation, deepfakes, financial loss or any form of deception
• Does NOT replace due diligence, professional advice or independent verification

Do not rely on Trusted Codes as your only safeguard against fraud or identity-related risks.

3.4 No Outcome Guarantees

Trusted Codes does not guarantee any specific outcome, result or level of protection. In particular:

• A successful verification does not guarantee the authenticity, honesty or trustworthiness of any party
• The Service cannot prevent fraud, deception or loss if verification results are bypassed, ignored or misinterpreted
• No security system is infallible; Trusted Codes reduces risk but cannot eliminate it

The effectiveness of the Service depends on its proper use. Our liability is governed exclusively by Section 13.

3.5 Guest Codes

A guest code lets you verify a person who does not use Trusted Codes, for example a visitor or a tradesperson. You decide to whom you give it, and you are responsible for passing it only to that person. Depending on your plan, you can set how long a guest code remains valid and how often it may be used, and you can invalidate it at any time. A guest code shows only that its holder received the words from you or from someone who had them. When a guest code is verified, the Service records who verified it and when.

3.6 Trust Ratings and Trust Score

The trust score is part of the Service. When a person checks a code or receives an invitation, Trusted Codes shows them whether the connection exists and a trust score for the account behind it. The score is computed from ratings by other users, the age and use of the account and the results of fraud prevention. It is an indication, not a statement of fact about a person. A low score is not a finding that someone has acted wrongly.

Ratings must be truthful and based on your own experience with the rated account. We remove ratings that break these Terms. You can ask us to review a rating about you at legal@trusted.codes.

Because the trust score is part of the Service you contract for, we process the data needed for it in order to perform this contract (Art. 6(1)(b) GDPR). Details are in the Privacy Policy.

3.7 Vault Sharing

A vault holds codes that a group of people use together. When you share a vault or add a person to it, that person receives the code secrets of the vault on their devices and can see its codes. You are responsible for choosing whom you add. Removing a member ends their access through the Service; it cannot undo what the member has already seen or copied.

3.8 Seals and Beacons

A seal is a statement signed by your device about a text or a file: that it existed no later than a given time and, if you choose, that it came from you. A seal is not a qualified electronic signature and does not satisfy a written or electronic form required by law. You choose who can read a sealed text when you make the seal, and this choice cannot be changed afterwards. A seal at the public level can be read by anyone who has the link, and by us. A fingerprint of the seal records is published in a public transparency log operated by a third party; this fingerprint contains no personal data and cannot be withdrawn.

A beacon publishes code words that anyone can check. When you switch on a beacon, its words and the name shown with them are public for as long as the beacon is on. Only publish a beacon under a name you are entitled to use.

3.9 Public Verification Pages

Public verification pages of the Service let anyone, with or without an account, check code words, for example the words of a beacon or a seal. The result shows what the Service holds at the time of the check. Checks are recorded as described in the Privacy Policy. Automated or mass queries of these pages are not permitted; use the programming interfaces within their limits instead (Section 3.12).

3.10 AI Assistant

The Service includes an assistant. When you use it, you are interacting with an AI system, not with a person.

• Answers are generated automatically and can be incomplete or wrong. Check important answers before you rely on them.
• The assistant can prepare actions in your account, for example creating a guest code or sending an invitation. It carries out an action only after you have confirmed it. You are responsible for the actions you confirm.
• Plans that include the assistant contain a limited number of answers per month composed with the AI model we provide, currently three. After that, further answers require your own API key.
• If you store your own API key of an AI provider, your questions are sent to that provider under your own contract with it, and that provider charges you. We are not responsible for the service of that provider. We store your key encrypted and use it only for your requests.

Which provider we use for the assistant, and how questions and answers are stored, is described in the Privacy Policy.

3.11 Desktop App, Local API and MCP Relay

The desktop app runs on your computer. It provides a local programming interface (local API) and an interface for AI clients using the Model Context Protocol (MCP). You decide which programs and AI clients may use your account through these interfaces, and with which access rights. You are responsible for the access you grant. An AI client you connect is a third-party service under your own contract with its provider; we are not responsible for what it does with the data you let it read.

The local API is intended for access from your own computer. Do not make it reachable from a network.

To use an AI client that does not run on your computer, you can connect it through our relay (mcp.trusted.codes). The relay passes requests between the AI client and your desktop app and does not store their content. Connection logs are kept as described in the Privacy Policy.

3.12 Programming Interfaces and API Keys

Depending on your plan, you can create API keys in the account portal to use the programming interfaces of the Service. Some interfaces are available without an account, for example to check beacons or seals. Use the interfaces only as documented and within their limits.

Keep your API keys secret. Anyone who holds a key can use it within its scope. Revoke a key without delay if you suspect that it has become known to someone else. We may limit request rates and block keys that are used in breach of these Terms.

3.13 Federation

Servers operated by other organisations (“nodes”) can be connected to the Service. You can connect with and verify users whose account is held on such a server. That server is operated under the responsibility and the terms of its operator; we do not operate or control it and are not responsible for its availability, security or conduct. When you connect with a user on another server, the data needed for that connection is exchanged with that server, as described in the Privacy Policy.

3.14 Enterprise Operation on Your Own Server

Organisations can run the Service on their own server (Enterprise). This requires a separate agreement, which governs that operation and takes precedence over these Terms. The Data Processing Agreement for the Business plan does not apply to Enterprise operation.

4. User Accounts and Organisations

4.1 Account Responsibility

You are responsible for:

• Maintaining the security of your devices
• Protecting access to your account, including recovery words and API keys
• Activity under your account that you caused or could have prevented

Each person may hold only one personal account.

4.2 Accurate Information

You must provide accurate and complete information and keep it up to date.

4.3 Unauthorised Access

You must notify us without delay if you suspect unauthorised access to your account or that one of your devices has been compromised.

4.4 Organisations

A Business plan is held by an organisation. The organisation is the contracting party. The person who creates the organisation or orders the plan confirms that they are authorised to act for it. The owner and the administrators of the organisation manage its members, roles and settings.

4.5 Roles and Seats

Members of an organisation have roles. What each role may do is shown in the organisation console. A plan contains a number of seats as shown in the plan description; members cannot be added beyond that number.

4.6 Members and Their Data

Members use their own personal account in the context of the organisation. For personal data processed in the organisation’s context, the organisation is the controller, and we process it on its behalf under the Data Processing Agreement.

When a member leaves the organisation or is removed, their access to the organisation’s connections, vaults and codes ends. Their personal account and their personal connections are not affected. Records of the organisation are retained as described in the Privacy Policy and the Data Processing Agreement. Administrators can export the organisation’s data in the organisation console.

5. Plans

5.1 Available Plans

The functions, limits and prices of each plan are those shown in the plan description at the time of your order (trusted.codes/pricing).

• Free: personal, non-commercial use, with the limits shown in the plan description.
• Business: for organisations only; ordered in the account portal (my.trusted.codes); starts with a free trial of 14 days; after the trial, the subscription is charged unless it is cancelled before the trial ends.
• Enterprise: operation on your own server, under a separate agreement (Section 3.14).

5.2 No Performance Guarantees on the Free Plan

The Free plan is provided free of charge. It carries no commitment to a particular availability or performance.

6. Subscriptions and Billing

6.1 Payment Provider

Payments are processed by Stripe. Trusted Codes does not store payment card data.

6.2 Billing Periods

Subscriptions are billed in advance for the billing period chosen at the time of the order, from the billing periods offered in the plan description.

6.3 Automatic Renewal

Subscriptions renew automatically for the same billing period unless they are cancelled before the end of the current billing period.

6.4 Cancellation

You can cancel at any time in the account portal (my.trusted.codes → Manage subscription), with effect at the end of the current billing period. Access to paid functions continues until then. The apps contain no billing functions.

6.5 Failed Payments

If a payment fails, our payment provider retries the payment. For Business subscriptions, access continues for up to 30 days from the first failed payment; after that, paid functions can be restricted until the payment is made. We inform you by email.

6.6 Price Changes

We may change the prices of paid plans with effect from the next billing period. We inform you of a price change by email at least six weeks before it takes effect. If you do not agree, you can cancel with effect from the date on which the new price would take effect.

7. Right of Withdrawal

7.1 Paid Plans

Paid plans are available only to entrepreneurs within the meaning of §14 BGB. A statutory right of withdrawal for consumers therefore does not apply to them. The Free plan is free of charge.

7.2 Future Consumer Offers

If we offer a paid plan to consumers in the future, we will inform consumers about their right of withdrawal before they order.

8. Refunds and Changes to the Service

8.1 Refunds

Payments are not refunded unless this is required by law or provided for in these Terms (Section 12.2).

8.2 No Partial Refunds

A cancellation takes effect at the end of the current billing period (Section 6.4). Fees for the current billing period are not refunded in part.

8.3 Changes to Functions

We develop the Service further. We may change, add or remove functions for valid reasons, in particular for security, changes in law or technical development, where the change is reasonable for you and does not significantly reduce the functions of your paid plan as described in the plan description. If a change impairs your access to or use of the Service more than insignificantly, we inform you in good time before the change on a durable medium, for example by email; as a consumer, you may then terminate the contract free of charge within 30 days (§327r BGB). Changes to these Terms are governed by Section 16.

8.4 No Binding Roadmap

Statements about planned features, roadmaps or future functionality are for information only and are not a binding commitment.

9. Acceptable Use

You may not:

• Use the Service for illegal purposes
• Attempt to reverse engineer, overload or compromise the Service
• Impersonate others or use a name you are not entitled to use
• Add contacts under false pretences
• Share verification codes with unauthorised parties
• Facilitate fraud or scams
• Submit untruthful ratings or ratings not based on your own experience
• Query public verification pages or programming interfaces automatically or in bulk beyond their documented limits

The consequences of a breach are governed by Section 12.3.

10. Data Protection and Privacy

10.1 Controller

We are the controller under the GDPR for the personal data we process to provide the Service to you. Where we process personal data on behalf of a Business customer, the Business customer is the controller and we are its processor (Section 10.3).

10.2 Encryption and Account Deletion

Personal data is encrypted with AES-256-GCM before it is stored. The key is held in a separate key-management service in the European Union, not in the database. Our servers can decrypt this data in order to provide the Service. Where your app supports it, code secrets are end-to-end encrypted between your devices, and we cannot decrypt that copy. The cases in which we also process code secrets on our servers are listed in the Privacy Policy.

When you delete your account, we delete your data as described in the Privacy Policy. Records we must keep, in particular the record of which version of a legal document you accepted and billing records held by Stripe, are retained for the periods stated there.

10.3 Business Customers

Where we process personal data on behalf of a Business customer, that processing is governed by the Data Processing Agreement, which is published in full and accepted in the account portal when the Business organisation is set up. No request is needed to obtain it.

A customer whose own legal team requires a negotiated or counter-signed agreement may request one at privacy@trusted.codes. That request does not delay an order: the published agreement applies in the meantime.

10.4 Privacy Policy

How we process personal data is described in the Privacy Policy. It is information under Art. 13 GDPR and not part of this contract.

11. Intellectual Property

All intellectual property rights in the Service belong to Stefan Sonntag, trading as Trusted Codes. For the duration of the contract, you receive a non-exclusive, non-transferable right to use the apps and the Service for the purposes permitted by these Terms.

You retain ownership of your data. You grant us the rights needed to process it solely to provide the Service. For content you publish through the Service, such as public seals, beacons or ratings, you grant us the non-exclusive right to store and show it within the Service for as long as it is published, and you confirm that you hold the rights needed for this.

12. Termination

12.1 By You

You may terminate the contract at any time by deleting your account. A paid subscription is cancelled as described in Section 6.4.

12.2 By Trusted Codes

We may terminate the contract with the following notice:

• Free plan: 7 days’ notice
• Paid plans: 30 days’ notice

Fees paid in advance for the time after the termination takes effect are refunded.

12.3 Termination for Cause

Either party may terminate the contract for good cause without notice (§314 BGB). Good cause exists for us in particular if you seriously or repeatedly breach Section 9 or use the Service for illegal purposes. As a rule, termination for cause requires a prior warning or a period to remedy the breach, unless the law does not require one.

Instead of terminating, we may temporarily block your access or individual functions where this is a proportionate response to a breach or necessary to protect other users or the Service. We take your legitimate interests into account and inform you of the reason.

12.4 Effects of Termination

• Access to the Service ends
• Your data is deleted as described in the Privacy Policy
• Payments are not refunded, except as provided in Section 12.2 or where required by law

13. Liability

13.1 Unlimited Liability

We are liable without limitation for intent and gross negligence, for injury to life, body or health, under the Product Liability Act (Produkthaftungsgesetz), and under any guarantee we have given.

13.2 Slight Negligence

For slight negligence, we are liable only for breach of an essential contractual obligation (an obligation whose fulfilment makes proper performance of the contract possible in the first place and on whose fulfilment you regularly rely), limited to the damage that is typical for this contract and foreseeable at its conclusion. For Business customers, this liability is further limited per calendar year to the fees paid in the twelve months before the damage occurred.

13.3 Exclusion

Otherwise, liability for slight negligence is excluded. For the Free plan, §§521 and 599 BGB apply accordingly (liability only for intent and gross negligence), subject to Section 13.1.

13.4 Decisions Taken After Verification

Trusted Codes checks whether two parties share a cryptographic reference. It does not check who a person is. Loss caused by a decision you take after a failed or skipped verification is not caused by the Service.

13.5 Our Staff and Agents

The limitations in this Section also apply to the personal liability of our employees, representatives and vicarious agents.

14. Indemnification (Business Customers Only)

This Section applies only to Business customers. The customer indemnifies Trusted Codes against third-party claims arising from the customer’s culpable breach of these Terms or of the law.

15. Force Majeure

We are not liable for failures of the Service caused by events beyond our reasonable control, such as natural disasters, government action or cyberattacks, unless the failure results from our not having taken appropriate security measures.

16. Changes to These Terms

We may change these Terms for valid reasons, in particular changes in law, court decisions or new functions, where the change does not alter the balance between performance and price to your disadvantage. We send the changes by email at least six weeks before they take effect.

For consumers, a change takes effect only when you accept it. Business customers may object within the six weeks; without an objection, the change takes effect, and we point this out in the notice. If you do not accept a change, either party may terminate the contract with effect from the date on which the change would take effect.

17. Dispute Resolution

We are not willing and not obliged to take part in dispute resolution proceedings before a consumer arbitration board.

18. Severability

If any provision of these Terms is or becomes invalid, the remaining provisions remain valid. In place of the invalid provision, the statutory provisions apply.

19. Entire Agreement

These Terms, the plan description at the time of the order and, for Business customers, the Data Processing Agreement form the entire agreement.

20. Contact

Legal questions: legal@trusted.codes

Privacy questions: privacy@trusted.codes

Formal notices may be sent to the address given in Section 1.