Data Licence

1. Definitions

1.1 Capitalized terms not defined in this Data Licence have the meaning given in the Terms of use. In addition:

(a) "Source Data" means the underlying facts, figures and text of a Public Record as originally published by a Source Publisher (for example, the fact that a named individual appears on a particular sanctions list as of a particular date);

(b) "Crown Compilation Layer" means everything Crown adds to Source Data in producing the Content: extraction and parsing logic, field normalization, entity resolution and matching, deduplication, cross-source merging, structuring into Crown's data model, refresh scheduling, search indexing, and any Crown-authored commentary, labels or metadata;

(c) "Licensed Data" means the combination of Source Data and the Crown Compilation Layer as delivered to you in a download, export, bulk file or API response;

(d) "Non-Commercial Use" means use by a natural person or organization that does not derive revenue, cost savings, competitive advantage or any other commercial benefit from the use, and that does not involve screening customers, counterparties, employees, tenants or applicants in the ordinary course of a business or regulated activity. Illustrative Non-Commercial Use includes individual due-diligence lookups on a single matter, academic research, and journalism; and

(e) "Commercial Use" means any use that is not Non-Commercial Use, including screening at scale, integration into a compliance program, resale, or use by or on behalf of a business, financial institution, government contractor or professional services firm in connection with its operations or client work.

2. The foundational position: fees are for the service, not the data

2.1 Public Records are, and remain, public. Crown does not claim to own, and does not purport to grant or withhold, any right in the underlying facts contained in Source Data. Sanctions designations, PEP disclosures, debarment notices, corporate filings and beneficial ownership records are published by Source Publishers under their own legal authority and, in most cases, may be independently obtained by any person directly from the Source Publisher.

2.2 Crown's fees, where charged, are consideration for the service — the identification, extraction, cleaning, matching, deduplication, merging, structuring, refresh, hosting, search, delivery (including bulk files and the screening API), and support Crown provides around Source Data — and are not, and must not be construed as, a fee for ownership of, or a licence to, the Source Data itself, nor as Crown asserting an exclusive right to facts that are otherwise public.

2.3 Any restriction in this Data Licence therefore applies only to: (a) the Crown Compilation Layer; and (b) your access to and use of Crown's delivery systems (the Site, downloads, bulk files and API). No restriction in this Data Licence is intended to, or does, restrict your right to obtain the same Source Data directly from the relevant Source Publisher, nor your use of Source Data so obtained.

3. Priority of the Source Publisher's own terms

3.1 Source Data remains subject to whatever terms of use, licence, or restriction the originating Source Publisher applies to it. Where a Source Publisher's own terms are more restrictive than this Data Licence — for example, a registry that prohibits bulk redistribution, or a list that requires specific attribution language — the Source Publisher's terms prevail over this Data Licence with respect to that Source Data, and you are responsible for complying with them independently of your compliance with this Data Licence.

3.2 Where Crown is aware of a Source Publisher restriction that is materially more limiting than this Data Licence, Crown labels the affected record or field accordingly, consistent with the Attribution notice. The absence of such a label is not a representation that no restriction exists; you remain responsible for your own diligence where redistribution to third parties is contemplated.

4. Licence grant

4.1 Non-Commercial Use. Subject to sections 3, 5 and 6, Crown grants you a non-exclusive, non-transferable, revocable licence to download, store, and use Licensed Data obtained through the Free Services for Non-Commercial Use, provided that you comply with the attribution requirements in section 5.

4.2 Commercial Use. Commercial Use of Licensed Data requires a separate written licence from Crown (a screening licence, bulk data licence, or reseller/OEM licence, as summarized in the Commercial licence summary). Downloading Licensed Data through the Free Services does not grant, and must not be treated as granting, any right of Commercial Use.

4.3 No licence granted under this Data Licence includes any right to: (a) represent Licensed Data as certified, verified or complete; (b) remove, obscure or alter attribution, source labels, "as of" dates or Crown's compilation notices; or (c) sublicense, resell or otherwise make Licensed Data available to a third party for that third party's independent use, except as expressly permitted under a Commercial Use licence.

5. Attribution

5.1 Any reproduction, publication, or downstream use of Licensed Data, whether under Non-Commercial or Commercial Use, must carry attribution substantially in the following form, adjacent to the data or in an accompanying methodology note:

"Source: [Source Publisher name], compiled by Crown Intelligence (crownintelligence.net). Data as of [date shown on record]. Verify against the original source before relying on this information."

5.2 Where a Source Publisher requires its own specific attribution wording (see section 3), you must include that wording in addition to, not instead of, the Crown attribution in section 5.1.

5.3 Attribution requirements survive any termination of your licence with respect to Licensed Data you retain.

6. Restrictions applicable to all uses

6.1 Regardless of Non-Commercial or Commercial Use, you must not:

(a) use Licensed Data as the sole basis for an adverse decision about a named individual or entity without independent verification against the current Source Publisher record, consistent with the Terms of use;

(b) misrepresent the currency, completeness or certainty of Licensed Data, including by omitting the "as of" date; or

(c) use Licensed Data in a manner that would infringe a Source Publisher's own published restrictions of which you have been made aware (see section 3.2).

7. No warranty; risk allocation

7.1 Licensed Data is provided subject to the "No warranty" and "Limitation of liability" provisions of the Terms of use (Non-Commercial Use) or the applicable Commercial Use agreement (Commercial Use). Crown's compilation work does not create any warranty, express or implied, that Source Data is accurate, current or complete; that warranty, if any, rests with the Source Publisher.

8. Term and termination

8.1 The licence granted under section 4.1 continues until terminated by either party. Crown may terminate or suspend it immediately on breach of this Data Licence, in particular sections 3, 5 or 6. On termination, you must cease using Licensed Data for any purpose requiring a live licence, except that data already lawfully published with correct attribution before termination need not be retracted.

9. Governing law

9.1 This Data Licence is governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein, and is subject to the dispute-resolution provisions of the Terms of use, section 13, unless a Commercial Use agreement states otherwise.

10. Relationship to other documents

10.1 This Data Licence should be read together with the Terms of use, the Attribution notice, and, for paid licensees, the Commercial licence summary and the applicable order form or licence agreement. In the event of conflict between this Data Licence and a signed Commercial Use agreement, the signed agreement prevails.