Data Submission Policy

DATA SUBMISSION FROM CONSUMERS & THIRD-PARTY INSTITUTIONS AND RESPONSIBILITY FOR AUTHORIZATION.

LAST UPDATED: 2023The purpose of the Services is to review financial account data (including, but not limited to, account numbers and account holder information, account transactions, account statements, account position and balance information) (together, “Records”) from a variety of users, groups, advisors, clients, and other parties, retrieved from third party financial institutions, such as brokerages and banks, and parsed and summarized in a way that is searchable, verifiable and provides benefits to users.

You agree that the use of our Services is subject to the following terms and conditions:

Right to Share Records.

You represent and warrant that you are entitled to submit Records to Cladfy for the uses described herein, and are responsible for obtaining all rights, permissions, and authorizations, if any, to provide Records to Cladfy.

Accuracy of Records.

You agree to provide true, accurate, current and complete information in the Records, and you agree to not misrepresent the account information provided in the Records in any way. Record Ownership and User Content. As between you and Cladfy, and except for the licenses you grant Cladfy below, you retain all rights in and to User Content, but are responsible for obtaining any necessary authorizations or licenses sublicense Records from any other Record owners, as stated above and to provide Cladfy with Records for purposes of the Services. Certain features of the Services may permit you, other users or third party institutions to upload content to the Services, including but not limited to account numbers and account holder information, account transactions, account statements, account position and balance information, financial statements, financial transactions, communications data and other messages, images, text, and other types of information (“User Content”).

Cladfy takes steps to verify the accuracy of the Records before using them. For example, Cladfy may require users to provide documentation to support the information they provide in the Records, or Cladfy may use third-party services to verify the information in the Records. However, Cladfy may not be able to verify the accuracy of all of the information in the Records.

You retain any copyrights, moral rights, and any other proprietary rights that you may hold in the User Content.

With respect to User Content, you grant Cladfy a perpetual, nonexclusive, royalty-free, worldwide, fully paid, transferable and sublicensable license to use, reproduce, modify, adapt and translate your User Content. When you submit User Content on or through our Services, you understand that User Content and any associated information (such as your username) may be visible to others.

Any User Content you submit to us is provided at your own risk of loss.

You are solely responsible for all User Content you provide to Cladfy or others via the Services. You may not create, post, store or share any User Content that violates these Terms or for which you do not have all the rights necessary to grant us the license described above. Although we have no obligation to screen, edit or monitor User Content, we may delete or remove User Content at any time and for any reason with or without notice. With respect to Records, you must have the authority to grant and will grant Cladfy a non-exclusive, worldwide, royalty-free, non-transferable license to use the Records and any other related materials input or otherwise provided to Cladfy pursuant to these Terms or a separate agreement between you and Cladfy. Except for the license granted in this section, nothing contained in these Terms grants Cladfy any right, title or interest in the Records. Except as expressly authorized by these Terms or a separate agreement, you will not, and will not allow others to

• (i) permit any third party not under your control to access or use the Services,
• (ii) decompile, disassemble, reverse engineer, or otherwise attempt to derive the trade secrets embodied in the Services, or
• (iii) use the Service to violate any applicable laws.

Personally identifiable data, contact information, and financial data.

Cladfy collects personally identifiable data, contact information, and financial data from its users in a variety of ways, including:

• When users create an account, they are required to provide their name, email address, and mailing address.
• When users book a service, they are required to provide their contact information, such as their phone number and address.
• When users make a payment, they are required to provide their financial information, such as their credit card number and billing address.

Cladfy uses the data it collects to:

• Provide its users with the services they have requested.
• Contact users with important information about their services, such as changes to their appointments or billing information.
• Improve its services by analyzing user data and trends.
• Conduct marketing and promotional activities.
• Process payments of the service fees.

Bank and Mobile Money Statements

Cladfy collects Bank and Mobile Money Statements to:

1. Provide insights: Cladfy automatically analyzes the Bank and Mobile Money Statements to provide insights into customer behavior, spending patterns, and other trends. This information can be used by businesses to improve their products and services, and by individuals to make better financial decisions.
2. Assess creditworthiness: Cladfy automatically analyzes the Bank and Mobile Money Statements to assess creditworthiness. This information can be used by lenders to make informed decisions about whether or not to grant a loan.

We will not disclose your personal information to third parties without your consent, other than as described in this policy. We may disclose personal information to the following types of third parties for the following purposes:

• Third-party service providers: These are service providers that assist us in our work, such as data storage and processing facilities, payment processing service providers, customer support providers, and marketing agencies. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions.
• Law enforcement agencies and other government entities: We may disclose personal information to law enforcement agencies and other government entities if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
• Merger, acquisition, debt financing, sale of company assets, or similar transaction: In the event of a merger, acquisition, debt financing, sale of company assets, or similar transaction, we may disclose personal information to the parties involved in the transaction.
• Insolvency, bankruptcy, or receivership: In the event of an insolvency, bankruptcy, or receivership, personal information may be disclosed to third parties as one of our business assets.

Any Financial Decision Cladfy uses a variety of methods to analyze Bank and Mobile Money Statements, including algorithms and automated decision-making systems. These methods allow Cladfy to identify patterns and trends in the Bank and Mobile Money Statements, which Cladfy then uses to generate insights and endorsements. For example, Cladfy may use its algorithms to identify spending patterns or to identify businesses that are likely to be successful. Any Financial Decision you make from the Insights and/or any Endorsement of a company, property, product, service, security, or instrument by Cladfy is entirely at your own risk.