Acceptable Use Policy

Introduction and concepts

Compliance with the law and the safety of our customers is paramount at CompanioEstonia OÜ. (Companio from now on). To fulfill our mission to help location independent entrepreneurs and global startups start, run and grow a thriving business while staying secure and compliant, we set up the following Acceptable Use Policy (“AUP’”). The AUP is the set of rules that we follow to decide which companies and businesses we can accept as customers. We communicate transparently what business activities are supported by Companio. However, please be aware that the following information is not exhaustive and Companio reserves the right to reject a customer for other reasons not contained in this document.

This document establishes three areas of business or categories of activities that we cannot accept as customers. The first category includes all activities that are prohibited. The second category contains business activities that require a pre-approval before registering or switching to Companio. The third category lists all business activities that are not supported by Companio right now.

We do not question some of the latter business activities however we are simply unable to accommodate these business activities at this point in time. As we grow we hope to be able to accommodate a wider range of customers and this list as well as the whole document is subject to changes.

Supported Business Models

Customers enrolled in our plans may engage in the following business models and activities based on their subscription tier:

Virtual Plan

The Virtual plan is designed for customers who do not require accounting services. It does not include accounting functionalities such as bank account linking or invoice uploading. Customers on this plan are limited to receiving our monthly invoices only. Any additional activity beyond this scope necessitates an upgrade to the Pro or Premium plan.

Pro Plan

The Pro plan caters to customers with basic accounting needs. It supports the following business models and activities:

Digital Activities

Digital activities includes any activity in which the business offers a digital service to its customers. Some examples include:

• Online marketing agencies
• Software development firms
• Graphic design studios
• UI/UX design services
• Influencers, Streamers, Youtubers (with proper invoice documentation from the paying platform)
• Media and News outlets

Professional Activities

Professional activities includes any activity based on a professional skill or specific knowledge of the professional owning the company, who basically acts as a freelancer. Examples include:

• Business consulting firms
• Legal services and consultancy
• Education and training providers
• Architecture consulting and design/build firms
• Translation services
• Copywriting agencies
• CTO/CFO/CEO as a service
• Development, Data analysis, Data mining
• Highly skilled services with no physical premises or permanent establishment

Startups

This category includes new digital businesses with an innovative digital service or product that can be served online to its customers. Some examples include:

• Digital product or service startups
• Music, video, or digital content streaming platforms
• Ridesharing and food delivery platforms
• Social media platforms

Examples of activities NOT supported in the Pro plan

The following activities are not supported in the Pro plan, but they are supported in the Premium plan.

• Dropshipping businesses
• Investment in regulated platforms
• Crypto activities

Premium Plan

The Premium plan offers advanced accounting features and supports additional business models and activities, including those allowed in the Pro plan, along with the following:

Dropshipping and E-Commerce Online Shops

This category includes pure dropshipping business models in which the Estonian business does not import/export the goods, keep stock, buy or sell anything directly, or own a warehouse. The provider of the goods, in charge of sending the goods to the final customer, must be a company or a provider (or a limited number of them). The providers of the goods cannot be individuals or physical persons.
The business should act as a mere online sales facilitator. Examples include:

• Amazon FBA.
• Amazon FBM businesses where a third-party fulfillment service is utilized.
• Dropshipping ventures.
• Second-hand shops (acting solely as intermediaries).

Seller/Buyer Marketplaces

This category includes all services in which the business puts buyers and sellers in contact or facilitates a financial agreement between them, without performing any specific activity, or keeping any physical stock or premises. Examples include:

• Online marketplace intermediaries (second-hand items, cars, etc)
• Services marketplace (cleaning, teaching, maintenance, etc)

Investment in Regulated Platforms

Investment in regulated platforms (e.g., eToro, Interactive Brokers) with strict account separation and reporting requirements.

Some examples of these platforms include e-Toro or Interactive Brokers.

Crypto Transactions

Companio supports a limited set of crypto activities and transactions in the Premium plan, including:

• Investing in supported exchanges. The business must open a dedicated corporate wallet or account.
• Exchanging crypto through approved banking channels (example, Revolut Business). Only for corporate bank accounts that support this exchange within the own balances of the account.
• Receiving and sending crypto payments for business purposes, including paying for expenses in crypto and receiving sales in crypto. The business must own a corporate wallet for all cryptocurrencies it uses, separated from any other wallet belonging to any particular or other company.

Crypto activities NOT Supported in the Premium Plan

The following business models and activities are not supported in the Premium plan (or any other plan).

• NFT-related activities
• ICOs/IPOs
• Launching cryptocurrency exchanges
• Cryptocurrency mining operations

Unsupported Business Models

Certain business models and activities are strictly prohibited across all subscription plans:

Physical Businesses

Physical businesses are those requiring a permanent establishment in a country outside of Estonia, or requiring the use of facilities, offices, premises, warehouses, or the management of physical goods, stock, or physical products. Examples include:

• Real estate ownership or rental
• Storage and sale of physical goods
• Physical shops or commerces
• Manufacturing
• Employment in physical offices outside Estonia

Crypto And Financial Businesses

The following crypto and financial businesses are not supported:

• NFT-related activities (creation, buying, selling)
• ICOs/IPOs
• Launching cryptocurrency exchanges
• Cryptocurrency mining operations
• Any business model or activity requiring a license to provide Virtual Assets services

Investment Businesses

The following investment or financial business models are not supported:

• Any business model or activity requiring a license to provide Financial Institution services.
• Robo-advisors
• Investment in non-regulated platforms
• Direct investments in shares, bonds, etc., outside regulated platforms

Business Models That Are Prohibited

It is prohibited to use the Companio service for activities that:

• Violate any law, statute, ordinance, or regulation
• Violate personal information of third parties in breach of applicable law
• Violate applicable laws or industry regulations regarding the sale of alcoholic drinks, smoking products, tobacco products, or prescription drugs and devices
• Violate copyright, trademark, right of publicity or privacy, or any other proprietary right under the laws of the account owner’s jurisdiction
• Gambling, betting, or casino-related activities and services
• Are performed on behalf of a legal entity not based within the EEA
• Any illegal products, services, or activities, including encouraging, promoting, facilitating or instructing others to engage in illegal activities
• Doing business that is not allowed with any listed sanctioned countries. Businesses or businesses with persons subject to international/national sanctions, suspected or convicted of terrorism, financial crime or any other offense
• Providing false information relating to the customer’s identity or business activities
• Constitute or promote scams, pyramid schemes, or Ponzi schemes
• Any product, service, or activity that finance terrorism

Business Models That Require a Pre-approval

The below-mentioned business models will only be accepted subject to a pre-approval process. Contact us beforehand to make sure we can accept your business.

• Online pharmacy, healthcare, weight loss products, nutraceuticals
• Religious groups and charitable organizations
• Money and debt collection services without a license
• Accounting and bookkeeping services
• Political parties and affiliations
• Real estate services

Business Models That Are Currently Not Supported

We currently do not support the following business models:

• Physical businesses (i.e: those requiring facilities outside of Estonia, such as restaurants, car repair shops, etc).
• Physical shops
• Narcotics, steroids, certain controlled substances or other products that present a risk to consumer safety, products including THC, or any activity that relates to drug paraphernalia
• Art dealing
• Holding companies & holding structures
• Products, services, or activities including media and journalism, that could be considered as being of a discriminatory, hateful, racist, or exploitative nature, or of inciting harassment, bestiality, mutilation, or violence.
• Any item, service, or activity that could be considered of sexual or adult nature
• Live animals or endangered animal species
• Services where the company collects money on behalf of others as a payment services provider, cheque encashment agencies, bureaux de change, money transmitters, remittance agencies, traveler’s cheques, or money orders
• Ammunition, explosives, arms, defense or weapons, replica weapons, gun parts or related parts or accessories, hunting, manufacture/distribution of weapons
• Collecting money without a license when compulsory in the account owner’s jurisdiction
• Multi-level marketing programs, network sales or affiliate marketing, matrix programs, outbound, and inbound telemarketing, or other similar programs including pyramid and Ponzi schemes
• Factoring, lending, investment services, financial, escrow or mortgage services, pawn shops
• Jewels, precious metals and stones, wholesale of scrap metal, unregistered waste management business
• Ticket agencies without a license, ticket resale
• Prepaid phone cards
• Replica clothes and products, or counterfeit goods
• Objectionable, offensive, indecent, harassing, threatening, embarrassing, distressing, vulgar, hateful, racially, ethnically or sexually offensive, or otherwise inappropriate behavior towards the company, its customers or its employees.
• Surrogacy, and any other pregnancy or fertility-related services/activities
• Products, services or activities relating to astrology, fortune-telling or palm reading
• Highly rated politically exposed persons (PEP)

Accounting Activities And Matchings Supported

To make things easy for customers, Companio defines the concept of “matchings“. A matching is an explanation of an activity related to a transaction, sometimes (but not always) linked to a document that justifies the transaction. For example:

• An outgoing transaction matched as “purchase invoice” with a document that justifies the transaction as marketing expenses for the company.
• An incoming transaction matched as “sales invoice” with a document that justifies the transaction as a sale for a consulting session.
• An outgoing transaction matched as “bank fee”, as it is a commission from the bank.
• An incoming transaction matched as an “internal movement” will me paired with the outgoing transaction from another corporate bank account of the same company (in the case of sending money from one corporate account of the business to another).

Supported Activities And Matchings

These are the supported matchings and their corresponding activities in Companio.

Sales invoices

Sales invoices are due to sales of digital services or goods from our customers to their clients. For example, if you provide web design services to a client, you’d match the payment received with the corresponding sales invoice.

Purchase invoices

Purchase invoices are expenses for which you get an invoice for the purchase of goods or services required by the business. For instance, if you buy a laptop for your business from a vendor, you’d match the payment made with the purchase invoice received.

Supported expenses include:

• Logistics or forwarding costs for dropshipping businesses for delivering the product to the final customer by their dropshipping provider or Amazon FBA/FBM provider. Physical purchases of goods or direct shipping costs are not allowed.
• Low value assets (stationery, small tools). Furniture, construction materials, or repairs (plumbing, electricity, etc) are not allowed.
• Subcontracted work, professional services, digital services from contractors (design, development, marketing, etc).
• Co-working spaces or non-permanent, temporary office rentals (up to 6 months). Utility bills (water, electricity, etc) need to be included in the price and are not supported separately.
• Expenses for miscellaneous services related to business operations, such as legal consultation services or marketing services for promotional campaigns.
• Set-up costs for digital services (only) such as digital operations or software licenses. Not allowed for physical setups such as furniture, equipment for a new office, or a license for physical operations or sales.
• Room rental. Only for short term rentals such as renting a meeting room for a 1-week business conference or leasing a conference room for training sessions.
• Advertising expenses and digital marketing (Google adwords, social media adwords, advertisement campaigns, etc).
• Telephone and internet. Only services not tied to an office. Mobile phone lines are supported, office landlines are not.
• IT and computer accessories: Laptops, IT services.
• Office supplies and postal expenses. Paper, pencils, etc. Nothing that implies a permanent establishment or office.
• Consultations and training. For consultations and trainings, example, business consulting services.
• Auditor fees. For financial audits or reviews.
• Accounting services. For business accounting.
• Other operating expenses. Only for digital services that don’t fall into any other category. Like the rest, these expenses need a proper invoice.
• Operating lease of cars. Needs an invoice in the name of the company. Only for temporary short leasings or rentals (usually a couple of days or weeks, never exceeding 6 months).
• Car insurance. Only allowed for rental cars and only if the insurance needs to be paid separately. Can never be used for a vehicle property of the business (as owning vehicles is not supported by Companio) or any of the the members of the company.
• Travel expenses: For business trips, acommodation, flights and train tickets. Cannot be used for meals, drinks, beverages, coffee, etc.

Expenses that don’t match any of these categories, or for which a proper purchase invoice is not uploaded in time (as per the provisions of the Income Tax Act of Estonia (§ 51.3)) according to our terms of service will be declared as “Non-business expenses”, and subject to tax liability in Estonia.

Banking fees

• Paying fees for business bank accounts.
• Using wire transfer services for international payments.

State fees

• Paying annual business registration fees.
• Covering licensing fees for regulated industries.

State refund

The opposite of a “State fee”, a refund paid by the government to the business. Examples include:

• Reimbursements of overpaid taxes
• Refunds for excess fees paid to governmental bodies
• Reimbursements from the e-Business register for registration-related payments.

Trips and Daily allowance

Employees and members of the company are allowed to go on business trips. Board members are entitled to “Daily allowance” for the trip. Regarding the expenses that appear during the trip, we differentiate three categories:

• Accommodation, transportation, baggage, insurance, and visa are purchase expenses that are deductible, and require a purchase invoice (“Purchase invoice (Travel expenses)” matching applies).
• The daily allowance matching is used for payments of the daily allowance from the business to the board member’s personal account after a trip.
• Coffee, meals etc, should be paid with the personal funds of the employee or board member, and would not be considered “Purchase expenses”, instead, they will be added to the trip as “non-deductible trip expenses” to serve as justification for the daily allowance payout.

Internal movements

Internal transactions between the bank accounts of the company (and not between accounts from different companies, even if they belong to the same members/shareholders) will be classified as Internal Movements.

Share Capital contributions

This matching represents the contribution from shareholders of the share capital of their companies, either the first share capital payment or an increase in the share capital.

Dividends distributed

This matching represents the payment of dividends after the fiscal year, and after the annual report is submitted (and if it results in profits).

Card verifications

This matching is used for verifications from banking providers and merchants of a payment method, usually for 0€ or an insignificant amount (like 0.01€).

Received interest

Received interest is available to Premium users, for gains or losses in financial investments (regulated platforms such as e-Toro, or crypto exchanges such as Kraken).

Bank cashback

Accounts for the revenue generated from your bank provider. This typically includes interest earned from bank deposits or account balances.

Non-business related expenses

• Covering costs unrelated to business activities, such as personal expenses.
• Meals, food, beverages.
• Clothing
• Expenditures that are not tax-deductible.
• Expenditures without proper justification or document after the time frame established in Companio’s terms of use.

Held Fund Reserve & Released Fund Reserve

1. There is one bank or payment gateway (i.e: Stripe) that is used to receive money from your clients. After receiving some money, this entity keeps or holds some amount as “Reserved Funds” as a guarantee to make sure you’ve got funds to pay in case of chargebacks, refunds, etc.
2. Then after some time, the bank/payment gateway credits this money back to the account as “Reserved Funds”.

Commission earnings

Commission earnings are small fees or commissions that your business earns due to an activity that is NOT the main activity of the company (for facilitating sales or transactions on behalf of others). Examples include a commission for referring new customers to their bank, or to an online platform they use for their business.

Personal loans from owner

Personal loans from the owner to the company are supported, allowing business owners to lend money to their company. This provides an alternative to increasing share capital when the business needs additional funds. The loan must be properly documented with a loan agreement. Please note that:

• Only loans from the owner to the company are allowed; the company cannot lend money to the owner
• The loan should not be the primary source of company funding when there’s no business income
• The loan can be waived if needed, providing flexibility in managing the company’s finance

Unsupported Activities And Matchings

All activities not mapped to a specific matching are not supported by Companio.

The following matchings and activities are discontinued and are no longer supported in any plan:

• Corporate loans to Owner: The company lending money to the owner is not supported.
• Donations: donations are no longer supported. As a Companio customer, you need to provide an invoice for all money earned or, exceptionally, an appropriate justification for that incoming transaction (returns of investment, refunds for a expense with the corresponding credit invoice, etc). Depending on your plan, certain sources of revenue will be allowed or not (see above).
• Costs of entertaining guests: costs of entertaining guests are not be supported anymore. Any expenses such as meals, foods, beverages, clothing, invitation to events, bars, concerts, etc, will be declared as “Non business expenses”.
• Decreasing the share capital: decreasing the share capital is not supported by Companio.

Violations and Enforcement of the Acceptable Use Policy

By registering a company or using the services of Companio you agree to the following:

• You adhere to the Companio Terms of Service, Privacy Policy, and this AUP when registering a company or using the services of Companio.
• You are required to inform Companio as soon as possible of any changes to your business activity.
• You are independently responsible for complying with all applicable laws and regulations in all of your actions related to your use of Companio. 4.4 You are independently responsible for not using the Companio service for transactions that may be considered illegal in the Estonian jurisdiction.
• Companio reserves the right, in its sole discretion, to amend the list of prohibited activities with immediate effect.
• If Companio has reasonable grounds to believe that you may be engaging in or have engaged in fraudulent activities or activities that violate any of the terms and conditions of this AUP, Companio may suspend or terminate your access to the Companio service without prior notice.

Other Violations of Our Acceptable Use Policy

It is strictly forbidden, while using our services, to carry out any of the following activities:

• Try to contact any of our employees outside of our official communication channels (user support tickets and regulatory consulting sessions)
• Request, to any of our employees, services independently of CompanioEstonia OÜ
• Request information from our employees about confidential information of the Company In Estonia OÜ, including tools, procedures, or confidential information of the company, its employees, or its customers
• Any misuse, illegal use, or ethically questionable use of our services
• Defame, insult, or publicly undermine the image of CompanioEstonia OÜ or any of its directors, members, employees, or shareholders

Scope And Acceptable Use Of Our Virtual Office Service

As part of its monthly services, CompanioEstonia OÜ offers a virtual office service to all its customers with an active monthly subscription. This service is intended to cover the customer’s need of having a person of contact and a legal address in Estonia as required by the authorities when the shareholders and board members of the company live abroad.

The service also serves to receive postal mail directed to the business that serves the purposes of the business. This typically includes receiving postal mail from the bank, communications from lawyers, messages from the authorities, or occasionally, packages that need to be received by the business owners such as bank cards (credit or debit cards) issued to the company. This is different from a logistics service. The customer cannot use it to deliver goods or products to customers through it. The postal mail received by the Virtual Office service is supposed to include only items that need to be sent, and can only be sent, to the business address.

It is not allowed to use the Virtual Office service offered by CompanioEstonia OÜ to:

• Send, receive, forward, or otherwise transport any illegal product, including drugs, pornography, and others
• Use the service as a logistics service in order to transport or return goods or products offered by the business to clients, partners, or third parties
• Use the service to send, receive, forward, or otherwise transport personal items, products, or goods that are not directly related to the operations of the business
• Use the service to send, receive, forward, or otherwise transport items that can be ordered, purchased, received, or returned by the owners of the business directly at their domiciles
• Use the service for any package whose volume exceeds 40cm x 25cm x 55cm or whose weight exceeds 10 kg
• Use the service to send, receive, forward, or otherwise transport the following items:
  • Pistols, firearms, or any other devices that can shoot projectiles.
  • Metal or plastic toy guns/replicas, including water pistols.
  • Slingshots, darts, or sports clubs or bats.
  • Objects with sharp points or edges, such as razors, knives, scissors, and other objects with sharp blades over 6cm in length, syringes
  • Work tools.
  • Fireworks, flammable liquids, or solids.
  • Bleach, acids, and poisons.
  • Objects containing compressed air or gas.
  • Plants, animals, or organic elements (organs, seeds, etc)
  • Bio-chemical products

Unsupported Countries

Companio allows registration as long as at least one company member holds a passport from a country not on the following list:

Afghanistan
Algeria
Burkina Faso
Egypt
Iraq
Iran
Yemen
Jordan
Democratic Republic of the Congo
Lebanon
Libya
South Sudan
Mali
Morocco
Mozambique
Nigeria,
Niger
Pakistan
State of Palestine
North Korea
Russia
Saudi Arabia
Somalia
Sudan
Syria
Tunisia
Uzbekistan
Turkey

I have noticed a violation of Companio’s AUP / I have a question regarding the AUP

If you have noticed a violation of our Acceptable Use Policy, we encourage you to immediately report it to us. If you have questions or concerns regarding the AUP, you can contact Companio using our ticket system.