CloviCFO
This document was prepared with AI assistance and reflects our current practices. It is being reviewed by counsel; for questions email [email protected].

Terms of Service

Effective Date: July 14, 2025 Entity: Vital Webmaster LLC


IMPORTANT NOTICE — PLEASE READ CAREFULLY. These Terms of Service contain a binding arbitration clause and class-action waiver (Section 20). By using the Services you agree to resolve disputes through individual arbitration rather than in court. If you do not agree, do not use the Services.


Table of Contents

  1. Parties and Agreement
  2. Description of Services
  3. Acceptance and Eligibility
  4. Account Registration
  5. Subscriptions, Fees, and Billing
  6. Metered and Overage Charges
  7. Cancellation and Refunds
  8. License Grant and Restrictions
  9. Acceptable Use Policy
  10. CloviShell-Specific Terms
  11. User Content and Data Ownership
  12. Plaid Financial-Data Connection
  13. AI-Generated and Automated Output
  14. Intellectual Property
  15. Privacy and Data Processing
  16. Security
  17. Disclaimers
  18. Limitation of Liability
  19. Indemnification
  20. Dispute Resolution and Arbitration
  21. Governing Law and Venue
  22. Termination and Data Export
  23. Changes to These Terms
  24. Force Majeure
  25. Assignment
  26. General Provisions
  27. Contact Information

1. Parties and Agreement

1.1 Parties. These Terms of Service (these "Terms") constitute a legally binding agreement between Vital Webmaster LLC, a limited liability company (the "Company", "we", "us", or "our"), which owns and operates the CloviTek suite of products, and the individual or legal entity accessing or using any of the Services described in Section 2 ("you" or "User").

Reviewer Note: The Company's registered state of formation should be confirmed and inserted here. Existing CloviLegal platform references use "Utah"; confirm whether Vital Webmaster LLC is a Utah LLC or another state and update the governing-law clause in Section 21 accordingly.

1.2 Effect. By creating an account, clicking "I Agree," accessing, or using any Service, you agree to be bound by these Terms and all documents incorporated by reference, including the:

All incorporated documents are hereby made a part of these Terms. In the event of a conflict between these Terms and an incorporated document, these Terms control unless the incorporated document expressly states otherwise.

1.3 Business Users. If you are entering into these Terms on behalf of a company or other legal entity, you represent that you have authority to bind that entity and all references to "you" mean that entity.


2. Description of Services

2.1 CloviTek Platform. The Company operates the CloviTek fleet of products. These Terms govern the following Services:

(a) CloviCFO — an AI-assisted bookkeeping and financial reporting platform. CloviCFO allows Users to:

(b) CloviShell — a paid software-as-a-service platform that provides Users with sandboxed, isolated code-execution environments. Users may write, upload, and execute code within the resource limits established for their subscription tier.

2.2 Not Covered. These Terms do not govern CloviTrade, CloviCrypto, CloviLegal, or other CloviTek products, which are subject to their own applicable terms.

2.3 Service Evolution. We may modify, add to, or discontinue features of the Services at any time, subject to Section 23 (Changes to These Terms) and applicable law. Material reductions in core functionality of a paid subscription will be communicated with at least thirty (30) days' advance notice where reasonably practicable.


3. Acceptance and Eligibility

3.1 Age Requirement. You must be at least eighteen (18) years of age to use the Services. By accepting these Terms, you represent and warrant that you are at least 18 years old.

3.2 Legal Capacity. You represent and warrant that: (a) you have the legal capacity to enter into a binding contract in your jurisdiction; (b) your use of the Services is not prohibited by applicable law; and (c) if you are registering on behalf of a legal entity, that entity is duly formed and in good standing.

3.3 Geographic Restrictions. You may not use the Services if you are located in, or are a national or resident of, any country subject to comprehensive U.S. trade sanctions or embargo, or are on any U.S. government restricted-parties list. We make no representation that the Services are available or appropriate for use in all jurisdictions.


4. Account Registration

4.1 Account Creation. To access the Services you must register for an account by providing accurate, current, and complete information. You agree to promptly update your account information to keep it accurate and current.

4.2 Credentials. You are responsible for maintaining the confidentiality of your login credentials. You are solely responsible for all activity that occurs under your account, whether or not authorized by you. You agree to notify us immediately at [email protected] if you suspect any unauthorized access to or use of your account.

4.3 One Account Per User. Unless otherwise authorized in writing by the Company, each User may maintain only one active account. You may not share account credentials with third parties.

4.4 Account Accuracy. You may not create an account using false identity information, impersonate any person, or create an account on behalf of another person without that person's authorization.


5. Subscriptions, Fees, and Billing

5.1 Paid Subscriptions. CloviCFO and CloviShell are offered as paid subscription services with multiple tiers, as described on the applicable product pricing page (each a "Plan"). Subscription fees are billed in advance on a recurring basis (monthly or annual, as selected at checkout) through Chargebee, our subscription-billing platform, and its integrated payment processors ("Billing Platform").

5.2 Auto-Renewal. YOUR SUBSCRIPTION WILL AUTOMATICALLY RENEW AT THE END OF EACH BILLING PERIOD at the then-current rate for your Plan unless you cancel before the renewal date in accordance with Section 7. By subscribing, you authorize the Billing Platform to charge your payment method on a recurring basis without further action from you.

5.3 Price Changes. We may change subscription prices upon at least thirty (30) days' advance notice sent to your registered email address or posted within the Services. Your continued use of the Services after the effective date of a price change constitutes acceptance of the new price. If you do not accept the new price, you may cancel before the effective date per Section 7.

5.4 Payment Method. You must provide a valid payment method. You represent that you are authorized to use the payment method you provide. We do not store your full payment card number; card data is handled directly by the Billing Platform and its payment processor.

5.5 Failed Payments. If a recurring charge fails, we may (a) retry the charge, (b) notify you to update your payment method, and (c) suspend or terminate your access if payment remains outstanding after a reasonable cure period, as described in the Billing Terms.

5.6 Taxes. Subscription fees are exclusive of applicable taxes (including sales, use, VAT, or GST). You are responsible for all taxes applicable to your subscription, except for taxes on the Company's net income.


6. Metered and Overage Charges

6.1 Metered Usage. Certain features of CloviCFO and CloviShell are subject to metered usage limits (e.g., number of transactions processed, AI-assisted operations, compute hours, or API calls), as defined for each Plan on the applicable pricing page ("Usage Limits").

6.2 Overage Fees. If your usage in a billing period exceeds the Usage Limits for your Plan, you will be charged overage fees at the rates published on the pricing page or communicated to you at the time of subscription ("Overage Charges"). Overage Charges are billed in arrears at the end of the applicable billing period.

6.3 Monitoring. You are responsible for monitoring your usage. We will endeavor to provide usage dashboards or notifications when usage approaches Plan limits, but we do not guarantee that such alerts will be provided before overages are incurred.

6.4 Disputes. You must notify us of any disputed Overage Charges within thirty (30) days of the charge appearing on your account. Failure to dispute within this period constitutes acceptance of the charge. Dispute notices should be sent to [email protected].


7. Cancellation and Refunds

7.1 Cancellation. You may cancel your subscription at any time through your account settings or by contacting [email protected]. Cancellation takes effect at the end of the then-current billing period; you will retain access to the Services until that date.

7.2 Effect of Cancellation. Upon cancellation: (a) your subscription will not renew; (b) you will not receive a refund for any prepaid fees covering the remainder of the current billing period, except as provided in Section 7.3 or the Billing Terms; and (c) your account will be downgraded or deactivated at end of period.

7.3 Refunds. Refunds are governed by the Billing Terms and Refund Policy, incorporated herein by reference. Please review that policy before subscribing.

7.4 Company-Initiated Termination. If we terminate your account for convenience (i.e., not due to your breach), we will provide a pro-rated refund of prepaid fees for the unused portion of the current billing period.


8. License Grant and Restrictions

8.1 License Grant. Subject to these Terms and timely payment of applicable fees, the Company grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Services solely for your own internal business or personal bookkeeping, financial reporting, and code-execution purposes during the term of your subscription.

8.2 Restrictions. You may not, and may not permit any third party to:

(a) copy, reproduce, distribute, or create derivative works of the Services or any component thereof;

(b) reverse engineer, decompile, disassemble, or attempt to derive the source code of the Services, except to the extent expressly permitted by applicable law;

(c) sublicense, sell, resell, transfer, assign, or commercially exploit the Services or access thereto;

(d) modify or adapt the Services or build a competitive product or service using the Services' features or underlying technology;

(e) scrape, crawl, or systematically extract data from the Services by automated means other than through authorized API access;

(f) circumvent, disable, or otherwise interfere with security-related features of the Services, including features that prevent or restrict use or copying of any content;

(g) use the Services to provide service bureau, time-sharing, or similar services to third parties without our prior written consent; or

(h) remove or alter any proprietary notices, labels, or marks on the Services.


9. Acceptable Use Policy

9.1 AUP Incorporation. Your use of the Services is subject to our Acceptable Use Policy ("AUP"), available at [AUP URL], incorporated herein by reference. In the event of a conflict between these Terms and the AUP, these Terms control.

9.2 General Prohibited Conduct. Without limiting the AUP, you agree not to use the Services to:

(a) violate any applicable federal, state, local, or international law or regulation;

(b) transmit any material that is unlawful, harmful, threatening, abusive, harassing, defamatory, or obscene;

(c) infringe any intellectual property, privacy, or other proprietary rights of any party;

(d) upload or transmit viruses, malware, ransomware, spyware, or any other malicious or harmful code;

(e) attempt to gain unauthorized access to any system, network, account, or data;

(f) impersonate any person or entity or misrepresent your affiliation with any person or entity;

(g) engage in any activity that could disable, overburden, or impair the Services or interfere with other Users' use of the Services; or

(h) collect or harvest personal data about other Users without their consent.


10. CloviShell-Specific Terms

10.1 Sandboxed Environments. CloviShell provides isolated, sandboxed execution environments for running code. Each environment is subject to the compute, memory, storage, and execution-time limits defined for your Plan ("Sandbox Limits").

10.2 Prohibited Uses — CloviShell. In addition to the general AUP obligations in Section 9, you specifically agree not to use CloviShell to:

(a) execute code designed to attack, probe, scan, penetrate, or disrupt any external system, network, server, device, or service (including but not limited to distributed-denial-of-service attacks, port scanning, vulnerability scanning, or exploitation of third-party systems);

(b) mine or generate cryptocurrency or engage in resource-intensive computation unrelated to legitimate development or testing purposes;

(c) execute code designed to spread malware, viruses, or any self-replicating or destructive code;

(d) attempt to escape the sandbox environment or gain elevated privileges on underlying infrastructure;

(e) deliberately consume resources in excess of Sandbox Limits to degrade service performance for other Users; or

(f) store, process, or transmit within CloviShell any data that is (i) classified or government-restricted, (ii) regulated payment card data (PCI-DSS in-scope cardholder data), or (iii) protected health information subject to HIPAA, unless you have entered into a separate written agreement with us covering such data.

10.3 Monitoring. We reserve the right to monitor resource usage and, where technically feasible, to inspect execution for compliance with these Terms and applicable law. We will endeavor to do so in a manner that respects User privacy, consistent with our Privacy Policy.

10.4 Responsibility for Code. You are solely responsible for all code you write, upload, or execute within CloviShell and for all consequences of its execution. The Company is not responsible for any damage caused by code you execute.


11. User Content and Data Ownership

11.1 User Ownership. You retain all ownership rights in and to the data, financial records, documents, receipts, invoices, code, and other content you upload, submit, or generate through the Services ("User Content"). Nothing in these Terms transfers ownership of User Content to the Company.

11.2 License to the Company. You grant the Company a limited, non-exclusive, royalty-free, worldwide license to access, store, process, copy, display, and use your User Content solely to the extent necessary to:

(a) provide and operate the Services to you;

(b) transmit User Content (or portions thereof) to authorized sub-processors, including AI processing providers (Anthropic, OpenAI, Google), for the purpose of returning AI-assisted outputs to you as part of the Services;

(c) perform maintenance, support, backup, and security operations; and

(d) comply with applicable law or legal process.

This license does not authorize the Company to sell, share, or use your User Content for marketing, advertising, training of AI models, or any purpose other than providing the Services to you.

11.3 AI Sub-Processor Restrictions. When User Content is transmitted to AI sub-processors (Anthropic, OpenAI, and Google) as part of Service operation, the Company procures, to the extent contractually available, no-training / zero-retention terms from those providers, meaning those providers do not use your data to train or improve their underlying models. However, you acknowledge that such contractual protections depend on the terms of the Company's agreements with those providers, which may change.

11.4 Aggregated / De-Identified Data. Notwithstanding Sections 11.1–11.3, the Company may generate and use aggregated, anonymized, or de-identified data derived from your use of the Services for product improvement, analytics, and benchmarking purposes, provided that such data does not identify you or your business and cannot reasonably be re-identified.

11.5 Financial Data — No Sale or Marketing Use. The Company does not sell, share, or otherwise disclose your financial data imported through Plaid to any third party for marketing, advertising, cross-context behavioral advertising, or data-resale purposes.


12. Plaid Financial-Data Connection

12.1 Plaid Integration. CloviCFO uses Plaid Inc. to facilitate connections between your financial institution accounts (bank accounts, credit cards, and other accounts) and CloviCFO. By initiating a Plaid connection, you authorize the Company, through Plaid, to retrieve your financial data (including transaction history, account balances, and account metadata) on your behalf.

12.2 Plaid's Terms. Your use of the Plaid connection is also subject to Plaid's End User Privacy Policy and any applicable Plaid terms, which are presented to you during the Plaid connection flow. The Company is not responsible for Plaid's data practices; Plaid is an independent third-party service provider.

12.3 Consent-Based Access. Financial data is retrieved through Plaid only with your explicit, affirmative consent (via an OAuth-style authorization flow). By connecting an account, you represent that you are authorized to connect that account and to grant the Company access to the retrieved data.

12.4 Permitted Use of Financial Data. Data retrieved through Plaid is used only to provide the bookkeeping, transaction categorization, and reporting features of CloviCFO to you as the account holder. We do not share Plaid-sourced financial data with third parties except as strictly necessary to operate the Services (i.e., to sub-processors listed in Section 15.3) and as described in our Privacy Policy.

12.5 Revocation. You may disconnect any linked financial account at any time through your CloviCFO account settings. Disconnection terminates ongoing data retrieval for that account. You may also request deletion of previously imported transaction data in accordance with our Privacy Policy and Section 22.3.


13. AI-Generated and Automated Output

13.1 AI Assistance. CloviCFO uses AI and automated models to categorize transactions, generate bookkeeping entries, and produce financial summaries and reports ("AI Output"). By using these features, you acknowledge and agree to the following.

13.2 Review Required. All AI Output is a draft for your review. AI-assisted categorizations, entries, and reports may contain errors, omissions, or inaccuracies. You are solely responsible for reviewing, verifying, correcting, and approving all AI Output before relying on it for any purpose.

13.3 Not Professional Advice. CloviCFO and its AI features are bookkeeping and reporting tools only. Nothing generated by CloviCFO, including any AI Output, constitutes or should be construed as:

You should consult a qualified, licensed CPA or accountant for tax and accounting matters specific to your situation.

13.4 No Accuracy Guarantee. The Company does not warrant that AI Output is accurate, complete, current, or fit for any particular purpose. AI models are statistical in nature and may produce incorrect results, including without limitation misclassifications of transactions and errors in financial calculations.

13.5 User Responsibility. The User bears sole responsibility for the accuracy of the User's books and records. The Company shall not be liable for any financial loss, tax liability, regulatory penalty, or other consequence arising from User's reliance on uncorrected AI Output.


14. Intellectual Property

14.1 Company IP. The Services, including all software, algorithms, AI models, interfaces, designs, documentation, trademarks, logos, and all modifications and improvements thereto, are and remain the exclusive property of the Company and its licensors. These Terms do not transfer any ownership interest in Company intellectual property to you.

14.2 Feedback. If you provide the Company with suggestions, feedback, or ideas regarding the Services ("Feedback"), you grant the Company a perpetual, irrevocable, royalty-free, worldwide license to use, incorporate, and exploit the Feedback in any manner without restriction or compensation to you. Feedback does not include User Content.

14.3 Trademarks. "CloviTek," "CloviCFO," "CloviShell," and related product names and logos are trademarks or service marks of the Company. You may not use any Company trademark without our prior written permission.


15. Privacy and Data Processing

15.1 Privacy Policy. Our collection, use, storage, and disclosure of personal information is governed by our Privacy Policy, available at [Privacy Policy URL], incorporated herein by reference. By using the Services, you consent to the data practices described in the Privacy Policy.

15.2 Data Residency. Primary application servers and databases are hosted in the European Union (France) via Contabo. Uploaded documents and receipts are stored in Amazon Web Services (AWS) S3 in the United States. Accordingly, your data may be stored or processed in both the EU and the US. Cross-border transfers from the EU to the US are addressed in the Privacy Policy in accordance with applicable data-protection law, including the GDPR where applicable.

15.3 Sub-Processors. The Company uses the following categories of sub-processors in delivering the Services:

Sub-Processor Purpose Location
Plaid Inc. Financial data aggregation United States
Amazon Web Services (AWS S3) Document and receipt storage United States
Contabo Application hosting and databases EU (France)
Anthropic / OpenAI / Google AI processing and output generation United States
Chargebee Subscription billing management United States / India
[Email delivery provider] Transactional email [TBD]

The Company maintains data processing agreements with sub-processors as required by applicable law. Updated sub-processor lists are maintained in the Privacy Policy.

15.4 GDPR Applicability. To the extent the General Data Protection Regulation (EU) 2016/679 ("GDPR") applies to the processing of your personal data (for example, because you are located in the European Economic Area or the data is processed on EU-hosted servers), the Company acts as a data controller with respect to personal data processed in connection with the Services. Lawful bases for processing include:

15.5 Data-Subject Rights. If GDPR or other applicable privacy law applies to you, you may have rights including: access, rectification, erasure ("right to be forgotten"), data portability, restriction of processing, and objection. To exercise these rights, contact [email protected]. We will respond within the timeframes required by applicable law.

15.6 Breach Notification. In the event of a personal data breach, we will notify affected Users and relevant supervisory authorities without undue delay, and in any event within 72 hours of becoming aware of the breach where required under GDPR Article 33, unless the breach is unlikely to result in a risk to individuals' rights and freedoms.

15.7 Data Retention. We retain User Content and personal data for as long as your account is active or as necessary to provide the Services, and thereafter in accordance with our data retention schedules set out in the Privacy Policy, subject to legal obligations. Following verified account deletion, we will delete or anonymize your personal data within a reasonable period (typically 90 days), except where retention is required by law.


16. Security

16.1 Company Measures. The Company implements commercially reasonable technical and organizational security measures, including:

16.2 User Responsibilities. You are responsible for maintaining the security of your account credentials, configuring appropriate access controls for any team or organizational account, and ensuring that devices you use to access the Services are adequately secured.

16.3 No Absolute Security. No security measure is perfect or impenetrable. The Company does not warrant that the Services are free from security vulnerabilities or that unauthorized access will never occur. In the event of a security incident, we will act in accordance with Section 15.6 and applicable law.


17. Disclaimers

17.1 As-Is and As-Available. THE SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY HEREBY DISCLAIMS ALL WARRANTIES, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.

17.2 No Uptime Guarantee. We do not warrant uninterrupted, error-free, or secure access to the Services. We may suspend the Services for maintenance, updates, or circumstances beyond our control.

17.3 Third-Party Services. The Company does not warrant the accuracy, reliability, availability, or performance of third-party services, including Plaid, AWS, Chargebee, or AI sub-processors.

17.4 Not Professional Services. As stated in Section 13.3, CloviCFO does not provide tax, accounting, financial, investment, or legal advice or services. CloviTrade and CloviCrypto (governed by separate terms) similarly do not constitute investment advice and users of those products make their own independent decisions.

17.5 Jurisdictional Limitations. Some jurisdictions do not allow the exclusion of certain implied warranties or consumer protection rights. To the extent such jurisdictions apply to you, some of the foregoing disclaimers may not apply, and you may have additional rights.


18. Limitation of Liability

18.1 Exclusion of Consequential Damages. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT WILL THE COMPANY, ITS MEMBERS, OFFICERS, EMPLOYEES, AGENTS, OR LICENSORS BE LIABLE FOR ANY:

ARISING OUT OF OR RELATED TO THESE TERMS OR YOUR USE OF OR INABILITY TO USE THE SERVICES, HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY (INCLUDING CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE), EVEN IF THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

18.2 Aggregate Cap. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY'S TOTAL CUMULATIVE LIABILITY ARISING OUT OF OR RELATED TO THESE TERMS OR THE SERVICES SHALL NOT EXCEED THE GREATER OF (a) THE TOTAL FEES ACTUALLY PAID BY YOU TO THE COMPANY IN THE TWELVE (12) MONTH PERIOD IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM OR (b) ONE HUNDRED U.S. DOLLARS ($100.00).

18.3 Essential Basis. THE PARTIES ACKNOWLEDGE THAT THE LIMITATIONS IN THIS SECTION 18 ARE AN ESSENTIAL ELEMENT OF THE BARGAIN BETWEEN THE PARTIES, WITHOUT WHICH THE COMPANY WOULD NOT HAVE PROVIDED THE SERVICES, AND THAT THESE LIMITATIONS APPLY NOTWITHSTANDING ANY FAILURE OF ESSENTIAL PURPOSE OF ANY LIMITED REMEDY.

18.4 Exceptions. Nothing in these Terms limits either party's liability for (a) fraud or fraudulent misrepresentation, (b) death or personal injury caused by negligence, or (c) any liability that cannot be limited or excluded by applicable law.


19. Indemnification

19.1 User Indemnification. You agree to defend, indemnify, and hold harmless the Company and its members, officers, employees, agents, successors, and assigns (each, a "Company Indemnitee") from and against any and all claims, liabilities, damages, judgments, awards, losses, costs, and expenses (including reasonable attorneys' fees) ("Losses") arising out of or relating to:

(a) your violation of these Terms or the AUP;

(b) your User Content, including any claim that your User Content infringes, misappropriates, or violates any third-party intellectual property, privacy, or other rights;

(c) your use of the Services in violation of applicable law;

(d) code you execute within CloviShell that causes damage to any person or system; or

(e) your violation of any third-party rights, including Plaid's terms of service, in connection with your use of the Services.

19.2 Procedure. The Company will: (a) promptly notify you in writing of any claim for which it seeks indemnification; (b) give you sole control of the defense and settlement of the claim (provided you may not settle any claim without the Company's prior written consent if settlement imposes any obligation or liability on a Company Indemnitee); and (c) provide reasonable cooperation in the defense at your expense. The Company retains the right to participate in the defense at its own expense with counsel of its choice.


20. Dispute Resolution and Arbitration

20.1 Mandatory Informal Dispute Resolution. Before initiating arbitration, the disputing party must provide written notice of the dispute to the other party (to the Company: [email protected]) describing the claim in reasonable detail. The parties will attempt in good faith to resolve the dispute within thirty (30) days of receipt of such notice. This informal resolution period is a prerequisite to arbitration.

20.2 Binding Arbitration. If the dispute is not resolved informally within the 30-day period, either party may submit it to binding individual arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules (if you are a consumer) or Commercial Arbitration Rules (if you are a business User), as applicable, and as supplemented by this Section 20. The AAA rules are available at www.adr.org. The arbitration shall be conducted by a single arbitrator. The arbitrator shall have authority to award any relief that a court of competent jurisdiction could award.

20.3 Seat and Procedures.


DRAFT — NOT YET PUBLISHED. This document was generated by the CloviLegal DraftAgent engine (model claude-sonnet-4-6) on 2026-06-24 from the controlling facts supplied. AI drafting/review assistant — not legal advice. Consult a licensed attorney. It is an AI-generated starting draft and is not legal advice; have a licensed attorney review before publishing — especially the GDPR, Plaid, and international-transfer clauses.