Welcome to Trupenny. By using our services, you agree to comply with and be bound by the following terms and conditions. Please read them carefully. If you do not agree with any part of these terms, you may not use our services.
1.1 Agreement Overview
These Terms of Service (“Terms”) form a legal agreement between you (“Customer”) and Trupenny LLC, a company incorporated under the laws of State of Texas with its registered office at 801 Travis Street Suite 2101, Houston, TX 77002 (“Trupenny”). These Terms govern your use of our website at https://trupenny.co (the “Site”), our web and mobile applications (each an “App”), and any related services we provide (collectively, the “Services”).
By creating an account, clicking an acceptance button, installing an App, or otherwise using the Services, you confirm that you have read, understood, and agree to these Terms. If you are using the Services on behalf of a corporation, partnership, or other entity, you represent that you are authorized to bind that entity and that all obligations under these Terms apply to it. If you do not agree, you may not use the Services.
1.2 Changes to These Terms
We may update these Terms from time to time to reflect changes in our business, Services, or applicable law. The most current version will always be available on the Site, and the “last updated” date will show when changes were made. Where updates are material, we may also notify you by email, within the App, or through other reasonable means. By continuing to use the Services after changes are posted, you agree to the revised Terms. If you do not accept the updated Terms, you must stop using the Services.
1.3 Individual Claims Only
To the extent permitted by law, any disputes under these Terms must be resolved individually. By agreeing to these Terms, you waive the right to participate in any class action, group claim, or representative proceeding against Trupenny.
1.4 Governing Law and Jurisdiction
These Terms are governed by the laws of the State of Texas. You agree that the courts of State of Texas will have exclusive jurisdiction over any disputes relating to these Terms or the Services, except where mandatory law gives you the right to bring a claim elsewhere.
2.1 Scope of Services
Trupenny provides cloud-based bookkeeping and related financial reporting tools (the “Services”). These Services may include, but are not limited to:
The Services are made available solely for use by businesses and organizations. They are not intended for personal or consumer purposes. Subject to compliance with these Terms and payment of all applicable fees, Trupenny grants you a limited, non-exclusive, non-transferable license to use the Services for your internal business purposes. No ownership rights are transferred to you, and your license ends when these Terms are terminated.
2.2 Modifications to Services
We may improve or change the Services from time to time. Features may be added, removed, or updated without notice. We may also schedule downtime for maintenance, updates, or upgrades. While we strive to keep interruptions minimal, we do not guarantee uninterrupted access to the Services.
2.3 Customer Responsibilities
The quality of the Services depends on your cooperation. You agree to:
If you fail to provide documents or responses when needed, we cannot guarantee timely completion of work or accuracy of results. Trupenny is not responsible for penalties, missed deadlines, or errors caused by incomplete, late, or inaccurate information you provide.
2.4 Corrections and Updates
You may request corrections or updates to deliverables within 30 days of receiving them. Trupenny will make reasonable efforts to address these requests at no additional charge. Requests made after 30 days may require additional fees, which will be communicated before work begins.
2.5 Errors
If you discover an error in how the Services were delivered, you must notify us immediately. We will investigate using commercially reasonable efforts and may attempt to correct the issue. However, we do not guarantee that every error can be fixed, nor do we guarantee that reports or outputs will be error-free. Some financial outcomes depend on external systems, and we are not responsible for errors originating outside the Services.
2.6 Financial Transactions
Trupenny does not move money, initiate payments, or execute transactions of any kind on your behalf. The Services are limited to bookkeeping, data storage, and reporting. If you choose to act on information from the Services through banks, payment providers, or other third parties, you are responsible for those actions and any consequences.
2.7 Use with Third-Party Services
You may connect Trupenny with third-party platforms (such as banks or accounting software). We are not responsible for the accuracy, security, or reliability of those services. Any data shared with or obtained from third parties is outside our control, and you assume all risk in using such integrations.
2.8 Not Professional Advice
The Services do not include tax preparation, audit, legal advice, investment advice, or any other professional services. Trupenny is not a licensed public accounting firm or law firm. The reports and dashboards we provide are intended to help you organize your financial information but may not conform to GAAP, IFRS, or other recognized accounting standards. You are responsible for consulting qualified professionals before making decisions based on information produced by the Services.
2.9 Data Storage and Reliability
The Services allow you to store and access financial information. We will take reasonable steps to safeguard this data, but we do not guarantee that it will always be available, free of loss, or secure from all breaches. You are encouraged to maintain your own backups. Trupenny is not liable for data loss caused by system failures, outages, or circumstances beyond our control.
2.10 Customer Verification
In order to provide the Services, we may require you to supply identifying information about your business or its owners, directors, or representatives. You agree that we may verify this information through third parties as permitted by law.
2.11 Service Limitations
You may not use the Services for unlawful purposes, or in any way that could damage, disable, or impair our systems. We may restrict or suspend your access if your use presents a security risk, violates these Terms, or disrupts normal operation of the Services.
2.12 Support
We provide support to Customers through email, phone, and in-app chat during our regular business hours. Support may cover technical questions, general guidance, or troubleshooting. While we aim to respond promptly, we do not guarantee that every issue will be resolved or that the Services will always meet your specific requirements.
2.13 Service Availability
Trupenny strives to keep the Services accessible, but we cannot promise that they will be available at all times. Performance may be affected by maintenance, system upgrades, internet connectivity, or other factors outside our control. You acknowledge that downtime or limited access does not entitle you to refunds or credits unless expressly stated in your Subscription Plan.
3.1 Account Creation and Access
When you register for the Services, Trupenny will create a unique customer account (the “Account”). The Account serves as your central access point for financial information, reports, and any related deliverables. Trupenny may provide you with login credentials, user IDs, or other secure methods of access. You are responsible for keeping these credentials confidential and for all activity that occurs under your Account.
3.2 Responsibility for Use
You must not share your login credentials with third parties, except as expressly permitted in these Terms. If you choose to allow employees, contractors, or advisors to access your Account, you are fully responsible for their actions and compliance with these Terms. Trupenny may rely on instructions or activity carried out through your Account as though it were authorized by you.
3.3 Security of Credentials
If you believe your password, access code, or other credential has been lost, stolen, or disclosed without authorization, you must notify Trupenny immediately at [support@trupenny.co]. We may suspend or reset access until security is restored.
3.4 Technical Requirements
You are responsible for providing the equipment, software, and internet connection required to access the Services. Trupenny is not responsible for interruptions or performance issues caused by your devices, networks, or third-party providers.
3.5 Data Protection and Confidentiality
While Trupenny takes reasonable steps to safeguard Account access, we cannot guarantee absolute security. You agree to implement appropriate measures (such as strong passwords and device protections) to protect your data and Account. Trupenny will not be liable for losses arising from unauthorized access resulting from your failure to follow reasonable security practices.
4.1 Prohibited Users
The Services are available only to businesses and organizations. The following are not permitted to use the Services:
We may decline or discontinue service at our discretion if we believe that a user falls within these categories.
4.2 Restrictions on Use
You agree not to, and will not permit others to:
4.3 Prohibited Content
You may not upload, enter, or store any data in the Services that:
Trupenny reserves the right to suspend or terminate Accounts, remove prohibited content, or take other actions if we determine that these limitations have been violated.
5.1 Subscription Plans
Access to the Services requires enrollment in a subscription plan (a “Subscription Plan”). Details of current plans and pricing are available at https://trupenny.co/pricing or as otherwise communicated in writing by Trupenny. By selecting a Subscription Plan, you agree to pay all applicable fees (“Fees”) as described at the time of enrollment. Unless stated otherwise, all Fees are in U.S. dollars and are non-refundable.
5.2 Changes to Plans and Fees
We may revise our Subscription Plans or adjust Fees from time to time. Changes will take effect no earlier than thirty (30) days after we post them on the Site or notify you by email, unless you accept them sooner. If you do not agree to a change in Fees, you must cancel your Subscription Plan before the change becomes effective. Continued use of the Services after changes take effect constitutes your acceptance of the new Fees.
5.3 Billing and Payment Methods
By providing a credit card, debit card, bank account, or other accepted payment method, you authorize Trupenny to charge all Fees and applicable taxes to that payment method on a recurring basis. If your payment method is declined or cannot be processed, we may suspend or terminate your access until payment is received.
We may also perform pre-authorization checks on credit or debit cards to verify validity and available funds. All payment information you provide must be accurate and kept up to date.
5.4 Billing Frequency and Renewals
Subscription Plans may be billed monthly or annually. Unless cancelled in accordance with Section 6, your Subscription Plan will automatically renew for successive periods of the same length. By enrolling, you authorize recurring charges for each renewal period until you cancel. If you wish to avoid renewal, you must cancel at least 15 days before the end of a monthly term or 60 days before the end of an annual term.
5.5 Late or Missed Payments
If a payment is late, declined, or otherwise unpaid, Trupenny may:
5.6 Taxes
All Fees are exclusive of applicable taxes. You are responsible for all sales, use, value-added, goods and services (GST/HST), or similar taxes, duties, or charges imposed by any government authority in connection with your purchase of the Services. You agree to indemnify and hold Trupenny harmless for any such taxes, duties, or charges (other than taxes on Trupenny’s net income).
5.7 Bank Debits and Wire Transfers
If you authorize payment by direct debit or wire transfer, you confirm that you have the right to use the bank account provided and that sufficient funds will be available to cover each transaction. If funds are incorrectly deposited or withdrawn due to incorrect information provided by you, Trupenny may attempt to assist in recovery but is not liable for restitution. We may bill you for time spent assisting in such recovery at our then-current rates.
5.8 No Offsets or Withholding
You may not withhold or set off any Fees owed to Trupenny against amounts you claim we owe you, unless required by law.
6.1 Initial Term
Your agreement with Trupenny begins when you accept these Terms, create an Account, or otherwise start using the Services. The initial subscription period (the “Initial Term”) depends on the plan you select at sign-up and will be either monthly or annual.
6.2 Automatic Renewal
At the end of the Initial Term, your Subscription Plan will automatically renew for successive periods of the same length (each a “Renewal Term”), unless either you or Trupenny provides written notice of non-renewal. Notice must be given at least 15 days before the end of a monthly term or 60 days before the end of an annual term. If notice is not provided, the Subscription Plan will renew automatically and Fees for the Renewal Term will apply.
6.3 Termination by You
You may stop using the Services at any time by closing your Account or providing notice of non-renewal under Section 6.2. Closing your Account does not relieve you of the obligation to pay any Fees due for the remainder of the then-current Term.
6.4 Termination by Trupenny
Trupenny may suspend or terminate your access to the Services if you fail to pay Fees when due, violate these Terms, or if continued use presents a security, compliance, or legal risk. Termination may be communicated by email, through the Site, or via the Account.
6.5 Effect of Termination
Upon termination, your license to use the Services ends immediately. You remain responsible for all Fees incurred up to the termination date.
7.1 Ownership of Services
All rights, title, and interest in the Services, including all software, code, interfaces, designs, features, and related documentation, are and will remain the exclusive property of Trupenny and its licensors. Except for the limited license granted under these Terms, no rights are transferred to you, and all other rights are expressly reserved.
7.2 Trademarks and Branding
The Trupenny name, logo, and any other marks or branding used in connection with the Services are trademarks or trade dress owned by Trupenny. You may not use these marks without our prior written consent, except to truthfully identify yourself as a customer.
7.3 Restrictions
You may not copy, distribute, modify, or create derivative works of the Services or related materials, except as expressly permitted in writing by Trupenny. Reverse engineering, decompiling, or attempting to extract source code is prohibited to the maximum extent allowed by law.
7.4 Feedback
If you choose to provide feedback, ideas, or suggestions regarding the Services, you grant Trupenny a worldwide, perpetual, irrevocable, royalty-free license to use and incorporate that feedback into the Services without obligation to you.
8.1 Customer Data Responsibility
The Services require you to provide certain information about your business, including financial records, contact information, and other materials (“Customer Data”). You remain solely responsible for the accuracy, quality, and completeness of all Customer Data. Trupenny does not verify or audit Customer Data, and we rely on you to ensure it is accurate and lawful.
8.2 Ownership of Customer Data
You retain all ownership rights in your Customer Data. By submitting Customer Data to Trupenny, you grant us a limited license to collect, store, process, and use that data as necessary to provide the Services, improve our offerings, and comply with applicable law.
8.3 Use of Aggregated and Anonymized Data
Trupenny may compile and use Customer Data in anonymized and aggregated form for analytical, benchmarking, or research purposes. Any insights created in this way will not identify you or disclose confidential information. You consent to such use, subject to applicable privacy laws.
8.4 Data Security
We implement reasonable technical and organizational safeguards to protect Customer Data against unauthorized access, loss, or misuse. However, no system is completely secure. You are responsible for maintaining appropriate protections on your own systems, including strong passwords, access controls, and backups. Trupenny will not be liable for losses arising from security breaches or device compromises outside our control.
8.5 Data Retention and Deletion
We retain Customer Data for as long as necessary to provide the Services or as required by law. After your Account is closed, we may retain data for backup, audit, or legal purposes, unless you request deletion in writing and applicable law permits it. Please note that once data is deleted, it cannot be recovered.
8.6 Sharing of Data with Third Parties
Trupenny may share Customer Data with service providers and partners who assist us in delivering the Services (for example, cloud hosting providers). These third parties are required to handle your information securely and only for the purposes specified. Trupenny is not responsible for how third-party services chosen by you (such as your bank or accounting software) handle your data, and you assume all risk when authorizing such connections.
8.7 Compliance and Disclosure
We may access, preserve, or disclose Customer Data when required by law, regulation, legal process, or governmental request. We may also disclose information if we believe it is necessary to:
8.8 Use of Artificial Intelligence (AI) Tools
Trupenny may use artificial intelligence or machine learning tools to help process or categorize Customer Data. Such tools are designed to improve efficiency and accuracy but do not replace human oversight. You acknowledge that outputs may not be perfect and agree to review any reports or recommendations before relying on them.
8.9 Customer Consents
By using the Services, you confirm that:
8.10 Feedback and Communications
If you provide suggestions, ideas, or comments relating to Customer Data or the Services, Trupenny may use them freely without obligation to you. We may also contact you about updates, new features, or administrative matters related to your Account.
9.1 Definition of Confidential Information
During the course of providing and receiving the Services, both you and Trupenny may gain access to non-public information about the other party, including financial records, business practices, client information, technology, or other sensitive data (“Confidential Information”). Customer Data will always be considered your Confidential Information, and information about the Services, pricing, and operations of Trupenny will be considered Trupenny’s Confidential Information.
9.2 Obligations
Each party agrees to protect the other party’s Confidential Information using at least the same level of care it uses to protect its own confidential materials, and never less than a reasonable standard of care. Confidential Information may only be used for purposes directly related to these Terms and may not be disclosed to third parties except to employees, contractors, or advisors who need to know it in order to fulfill their duties, provided that they are bound by confidentiality obligations at least as protective as those in this Section.
9.3 Exclusions
Confidential Information does not include information that:
9.4 Survival
These confidentiality obligations continue even after your Account is closed or these Terms are terminated.
10.1 Your Obligations
You agree to defend, indemnify, and hold harmless Trupenny, along with our officers, directors, employees, affiliates, service providers, and licensors, from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) that arise from:
10.2 Trupenny’s Rights
Trupenny reserves the right to assume exclusive defense and control of any matter subject to indemnification by you. If this occurs, you agree to cooperate fully with us in defending such matters and will not settle any claim without our prior written consent.
10.3 Scope of Protection
Your indemnification obligations apply to claims brought by third parties, including government agencies. These obligations remain in effect even after your Account is closed or your use of the Services ends.
11.1 Your Representations
By using the Services, you represent and warrant that:
11.2 No Reliance on Unofficial Information
You acknowledge that any financial or business information available through the Services, unless provided in writing by Trupenny as part of the Services, is for general informational purposes only and may not reflect the most current developments in accounting or business practices. You agree not to rely on such information without first consulting qualified professionals.
11.3 Survival of Warranties
The representations and warranties in this Section remain in effect for as long as you use the Services.
12.1 Services Provided “As Is”
The Services, including all content, reports, dashboards, and other outputs, are provided “as is” and “as available.” To the fullest extent permitted by law, Trupenny disclaims all warranties, whether express, implied, statutory, or otherwise, including warranties of merchantability, fitness for a particular purpose, title, non-infringement, accuracy, reliability, and quiet enjoyment.
12.2 Third-Party Content and Links
The Services may include links or integrations with third-party websites, applications, or services. Trupenny does not control, endorse, or guarantee the accuracy or quality of such third-party content. Any reliance on or use of third-party materials is at your own risk. We are not responsible for, and disclaim all liability in connection with, the content, practices, or services of third parties, even if accessed through the Services.
12.3 Data and Reports
Trupenny strives to deliver accurate financial reporting and dashboards, but we do not warrant that the Services will be error-free, uninterrupted, or immune from inaccuracies. Reports may not meet formal accounting standards such as GAAP or IFRS and should not be relied upon as a substitute for professional accounting, tax, or legal advice. You are responsible for reviewing outputs and consulting appropriate professionals before taking action based on the information provided.
12.4 Customer Responsibility
You assume full responsibility for your use of the Services, including the safeguarding of your data, devices, and login credentials. Downloading, storing, or otherwise using materials from the Services is done at your own discretion and risk.
12.5 Local Variations
Some jurisdictions may not allow disclaimers of implied warranties. To the extent that applicable law prohibits disclaimers, those protections remain in force, but Trupenny’s liability will be limited to the minimum extent required.
13.1 Maximum Liability
To the fullest extent permitted by law, Trupenny’s total liability to you for any claims arising out of or relating to these Terms or the Services will not exceed the total Fees you paid to Trupenny during the three (3) months immediately preceding the event giving rise to the claim.
13.2 Types of Damages Excluded
Trupenny, its affiliates, officers, employees, and service providers will not be liable for any:
These limitations apply regardless of the cause of action, whether in contract, tort (including negligence), strict liability, or otherwise, even if Trupenny has been advised of the possibility of such damages.
13.3 Allocation of Risk
You acknowledge that the Fees charged for the Services reflect this allocation of risk and that the limitations set out in this Section are an essential basis of the bargain between you and Trupenny.
13.4 Local Variations
Some jurisdictions may not allow limitations or exclusions of liability for incidental or consequential damages. In such cases, Trupenny’s liability will be limited to the maximum extent permitted by applicable law.
14.1 Method of Delivery
Notices or communications required under these Terms must be in writing and will be considered delivered when:
14.2 Trupenny Contact Information
Notices to Trupenny should be addressed to:
We may update our contact details by posting revised information on the Site.
14.3 Customer Contact Information
Notices to you will be sent to the email address or mailing address associated with your Account. You are responsible for keeping this information accurate and current.
14.4 Electronic Communications
By using the Services, you consent to receive communications from Trupenny electronically. You agree that electronic notices have the same legal effect as paper notices. If you withdraw consent to electronic communications, you must stop using the Services.
15.1 Governing Law
These Terms and any disputes or claims arising from them are governed by the laws of State of Texas applicable therein, without regard to conflict of law rules.
15.2 Exclusive Jurisdiction
You and Trupenny agree that the courts of State of Texas will have exclusive jurisdiction over all disputes or claims arising out of or relating to these Terms or the Services, except where mandatory law grants you rights to bring a claim in another jurisdiction.
15.3 Individual Actions Only
To the fullest extent permitted by law, you and Trupenny agree that disputes must be brought on an individual basis. Neither party may pursue a claim as a plaintiff or class member in any class, collective, or representative proceeding.
15.4 Good Faith Resolution
Before starting formal legal proceedings, both you and Trupenny agree to attempt in good faith to resolve any dispute informally. Either party may initiate this process by providing written notice to the other party describing the dispute and proposed resolution. If the parties cannot resolve the dispute within thirty (30) days of such notice, either party may bring an action in the courts of State of Texas.
15.5 Equitable Relief
Despite the requirement to resolve disputes in the courts of State of Texas, either party may seek injunctive or equitable relief in any jurisdiction if such relief is necessary to protect intellectual property rights, confidential information, or prevent unlawful conduct.
15.6 Time Limit on Claims
Any claim or cause of action arising out of or relating to the Services or these Terms must be filed within one (1) year after the event giving rise to the claim, unless a longer period is required by applicable law. Claims not filed within this period are permanently barred.
15.7 Severability of Provisions
If a court determines that any part of this Section 15 is unenforceable, the remaining provisions will remain valid and enforceable to the maximum extent permitted by law.
16.1 Entire Agreement
These Terms, together with our Privacy Policy, form the entire agreement between you and Trupenny regarding the Services and supersede all prior or contemporaneous agreements, communications, and understandings, whether written or oral.
16.2 Assignment
You may not assign or transfer these Terms, or any rights or obligations under them, without our prior written consent. Any attempt to assign without consent will be void. Trupenny may assign these Terms, including in connection with a merger, acquisition, or sale of assets, without restriction.
16.3 Independent Contractors
You and Trupenny are independent contractors. Nothing in these Terms creates a partnership, joint venture, employment, or agency relationship between us, and neither party has authority to bind the other.
16.4 Force Majeure
Trupenny will not be responsible for any delay or failure in performance caused by circumstances beyond our reasonable control, including natural disasters, labor disputes, power outages, internet or telecommunications failures, or government actions.
16.5 Waiver
Failure to enforce any provision of these Terms will not constitute a waiver of that right or provision. Any waiver must be in writing and signed by an authorized representative of the waiving party.
16.6 Severability
If any provision of these Terms is found invalid, illegal, or unenforceable, the remaining provisions will remain in full force and effect.
16.7 Export Compliance
You agree to comply with all applicable export and re-export laws and regulations. You may not use or access the Services in violation of such laws or provide the Services to any person or entity prohibited by applicable export laws.
16.8 Marketing Use
Unless you notify us otherwise in writing, you agree that Trupenny may use your business name and logo to identify you as a customer in marketing materials, on our Site, and in presentations.
16.9 Language
It is the express wish of the parties that these Terms and all related documents be drafted in English.
16.10 Survival
The following sections will survive termination or expiration of these Terms: Fees and Payment, Intellectual Property Rights, Customer Data and Consent, Confidentiality, Indemnification, Representations and Warranties, No Warranties, Limitation of Liability, Governing Law and Dispute Resolution, and any other provisions that by their nature should reasonably survive.
16.11 Notices
See Section 14 for details on notices and contact information.
16.12 Construction
Headings are for reference only and do not affect interpretation. The term “including” means “including without limitation.” Remedies are cumulative unless expressly stated otherwise.
16.13 Amendments
We may update or amend these Terms from time to time. The most current version will always be posted on the Site. Material changes may also be communicated to you by email or within the Services. By continuing to use the Services after changes take effect, you agree to be bound by the updated Terms.
16.14 E-Sign Consent
You agree that electronic acceptance of these Terms and related documents has the same legal effect as a handwritten signature.
16.15 Governing Language
If these Terms are translated into another language, the English version will prevail in case of conflict.
For purposes of these Terms, the following definitions apply:
“Account” – The secure online account created for you by Trupenny through which you access the Services and related deliverables.
“Affiliate” – Any entity that directly or indirectly controls, is controlled by, or is under common control with another entity.
“App” – A mobile or web-based application made available by Trupenny that enables access to the Services.
“Confidential Information” – All non-public, proprietary, or sensitive information disclosed by one party to the other, whether orally, in writing, or electronically, including financial data, business strategies, customer information, and technical details. Customer Data and Trupenny business information are each considered Confidential Information.
“Customer” – The business or organization that accepts these Terms and any authorized representatives acting on its behalf.
“Customer Data” – All financial information, documents, records, and other data submitted, uploaded, or otherwise made available by you to Trupenny through the Services.
“Data” – Collectively refers to Customer Data and any information generated or provided by Trupenny in connection with the Services.
“Fees” – The charges you are required to pay for access to and use of the Services, as set out in your Subscription Plan or otherwise agreed in writing.
“Intellectual Property Rights” – All current and future rights under patent, copyright, trade secret, trademark, and other similar laws, including applications, renewals, extensions, and registrations.
“Party” – Either you as the Customer or Trupenny, and “Parties” means both together.
“Privacy Policy” – The policy posted at https://trupenny.co/privacy (as updated from time to time) describing how Trupenny collects, uses, and protects personal information.
“Services” – The bookkeeping, reporting, dashboard, and related tools provided by Trupenny through the Site, Apps, or other channels.
“Site” – The website located at https://trupenny.co.
“Subscription Plan” – The specific package of Services, features, and Fees selected by you when enrolling, which may be monthly or annual.
“Term” – The period beginning when you accept these Terms and continuing through the Initial Term and any Renewal Terms, until terminated as provided herein.
“Third-Party Services” – Any software, platform, or service not operated by Trupenny that may integrate with, connect to, or be used in conjunction with the Services (for example, banking platforms or accounting tools).
“Transaction” – Any transmission of Customer Data through the Services, including submission, storage, or retrieval of financial records.