OPENWEALTH TERMS OF SERVICE

Last Updated: October 25, 2025

1. ACCEPTANCE OF TERMS

These Terms of Service ("Terms") constitute a legally binding agreement between you ("User," "you," or "your") and ACO TECH SOLUTIONS LLC ("Company," "we," "us," or "our") governing your access to and use of the OpenWealth platform, including all associated websites, applications, features, content, and services (collectively, the "Platform").

By creating an account, accessing, or using the Platform, you acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy, which is incorporated herein by reference.

2. DESCRIPTION OF SERVICE

OpenWealth is an AI-powered investment analysis and portfolio management platform designed to help retail investors make more informed investment decisions. The Platform provides:

• Portfolio integration and aggregation from connected investment accounts
• AI-driven portfolio analysis, including risk assessment, diversification evaluation, and rebalancing recommendations
• Conversational AI research agent for investment research and education
• Personalized investment insights and strategies

3. NOT INVESTMENT ADVICE - CRITICAL DISCLAIMER

OPENWEALTH IS NOT A REGISTERED INVESTMENT ADVISER, BROKER-DEALER, OR FINANCIAL PLANNER. THE COMPANY AND THE PLATFORM DO NOT PROVIDE INVESTMENT ADVICE, FINANCIAL ADVICE, TAX ADVICE, OR LEGAL ADVICE.

3.1 Educational and Informational Purposes Only

All information, analysis, recommendations, insights, and content provided through the Platform (collectively, "Content") are for educational and informational purposes only. The Content should not be construed as:

• Personalized investment advice or recommendations tailored to your specific financial situation
• Professional financial, investment, tax, or legal advice
• An offer to buy or sell securities or other financial instruments
• A solicitation or recommendation to take any particular investment action

3.2 AI-Generated Content Limitations

The Platform utilizes artificial intelligence and machine learning algorithms to generate Content. You acknowledge and agree that:

• AI-generated content may be incorrect, incomplete, inappropriate, or misleading
• AI models may produce errors, hallucinations, or unexpected outputs
• Past performance data and historical analysis do not guarantee future results
• The Platform cannot predict market movements or investment outcomes
• You should independently verify all information before making investment decisions

3.3 Professional Consultation Required

Before making any investment decisions, you should consult with a qualified, licensed financial adviser, investment professional, tax adviser, or attorney who can provide advice tailored to your specific circumstances, financial situation, investment objectives, risk tolerance, and tax situation.

4. INVESTMENT RISKS

INVESTING IN SECURITIES INVOLVES SIGNIFICANT RISK, INCLUDING THE POSSIBLE LOSS OF PRINCIPAL. YOU MAY LOSE SOME OR ALL OF YOUR INVESTED CAPITAL.

You acknowledge and accept that:

• All investments carry risk, and past performance is not indicative of future results
• Market conditions can change rapidly and unpredictably
• You are solely responsible for all investment decisions made using or in reliance upon the Platform
• The Company is not responsible for any investment losses, damages, or opportunity costs resulting from your use of the Platform
• You should only invest funds that you can afford to lose

5. ACCOUNT REGISTRATION AND SECURITY

5.1 Eligibility

You must be at least 18 years old and have the legal capacity to enter into binding contracts to use the Platform. By creating an account, you represent and warrant that you meet these eligibility requirements and that all information you provide is accurate, current, and complete.

5.2 Account Security

You are responsible for:

• Maintaining the confidentiality of your account credentials
• All activities that occur under your account
• Notifying us immediately of any unauthorized access or security breach
• Using strong, unique passwords and enabling two-factor authentication where available

6. PORTFOLIO INTEGRATION AND DATA ACCESS

6.1 Third-Party Account Connection

The Platform may integrate with third-party financial institutions and brokerage accounts to aggregate your portfolio data. When you connect external accounts:

• You authorize the Platform to access and retrieve your financial data from connected accounts
• You grant us permission to use this data to provide the Platform's services
• You are subject to the terms and conditions of the third-party service providers
• You can disconnect accounts at any time through your account settings

6.2 No Trading Authority

The Platform does not execute trades, place orders, or otherwise transact on your behalf. We only provide read-only access to your portfolio data for analysis purposes. All investment transactions must be executed through your brokerage or financial institution.

7. INTELLECTUAL PROPERTY RIGHTS

7.1 Company Property

The Platform, including all software, algorithms, designs, text, graphics, user interfaces, visual interfaces, trademarks, logos, and other content (excluding User Content), is owned by the Company and is protected by copyright, trademark, and other intellectual property laws.

7.2 Limited License

Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Platform for your personal, non-commercial purposes. This license does not permit you to:

• Copy, modify, distribute, sell, or lease any part of the Platform
• Reverse engineer, decompile, or attempt to extract source code from the Platform
• Use the Platform to create competing products or services
• Remove, alter, or obscure any copyright, trademark, or proprietary notices

8. USER CONDUCT AND PROHIBITED ACTIVITIES

You agree not to:

• Use the Platform for any unlawful purpose or in violation of any applicable laws or regulations
• Provide false, inaccurate, or misleading information
• Impersonate any person or entity or misrepresent your affiliation with any person or entity
• Interfere with or disrupt the Platform's operation or servers
• Attempt to gain unauthorized access to any part of the Platform, other users' accounts, or connected systems
• Use any automated system, including robots, spiders, or scrapers, to access the Platform without our express written permission
• Transmit any viruses, malware, or other malicious code
• Harass, abuse, threaten, or harm other users
• Use the Platform to distribute spam, unsolicited communications, or fraudulent schemes

9. DATA ACCURACY AND RELIABILITY

While we strive to provide accurate and up-to-date information, we do not warrant or guarantee:

• The accuracy, completeness, reliability, or timeliness of any Content or data
• That the Platform will be uninterrupted, error-free, or secure
• That defects will be corrected
• The results obtained from using the Platform

Market data, pricing information, and portfolio valuations may be delayed or inaccurate due to third-party data provider limitations, technical issues, or market volatility. You should verify all information independently before relying on it.

10. FEES AND PAYMENT

10.1 Subscription Fees

Certain features of the Platform may require payment of subscription fees. All fees are:

• Stated in U.S. dollars unless otherwise specified
• Payable in advance on a monthly or annual basis
• Non-refundable except as required by law or as expressly stated in these Terms
• Subject to applicable taxes

10.2 Automatic Renewal

Subscriptions automatically renew at the end of each billing period unless you cancel before the renewal date. You authorize us to charge your payment method on file for renewal fees. We will provide notice of any fee changes at least 30 days in advance.

10.3 Cancellation

You may cancel your subscription at any time through your account settings. Cancellation will be effective at the end of the current billing period, and you will continue to have access to paid features until that date. No refunds will be provided for partial billing periods.

11. TERMINATION

11.1 Termination by You

You may terminate your account and cease using the Platform at any time by contacting our support team or through your account settings.

11.2 Termination by Us

We reserve the right to suspend or terminate your access to the Platform immediately, without prior notice or liability, for any reason, including if you:

• Violate these Terms
• Engage in fraudulent, abusive, or illegal activities
• Fail to pay applicable fees
• Request account deletion
• Create risk to the Platform, Company, or other users

11.3 Effect of Termination

Upon termination:

• Your right to access and use the Platform immediately ceases
• We may delete your account data subject to our data retention policies and legal obligations
• Provisions of these Terms that by their nature should survive termination will survive, including intellectual property rights, disclaimers, indemnification, and limitations of liability

12. DISCLAIMERS OF WARRANTIES

THE PLATFORM IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.

We do not warrant that:

• The Platform will meet your requirements or expectations
• The Platform will be available at all times, uninterrupted, secure, or error-free
• The quality of any products, services, information, or other material obtained through the Platform will meet your expectations
• Any errors or defects in the Platform will be corrected
• The Platform is free from viruses or other harmful components

Some jurisdictions do not allow the exclusion of implied warranties, so some of the above exclusions may not apply to you.

13. LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY LAW, IN NO EVENT SHALL THE COMPANY, ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, OR LICENSORS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES, RESULTING FROM:

• Your access to, use of, or inability to access or use the Platform
• Any conduct or content of any third party on the Platform
• Unauthorized access, use, or alteration of your transmissions or content
• Investment decisions made based on information obtained through the Platform
• Financial losses resulting from your use of the Platform
• Any other matter relating to the Platform

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE COMPANY'S TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES, AND CAUSES OF ACTION ARISING OUT OF OR RELATING TO THESE TERMS OR YOUR USE OF THE PLATFORM SHALL NOT EXCEED THE AMOUNT YOU PAID TO US IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM, OR ONE HUNDRED DOLLARS ($100), WHICHEVER IS GREATER.

Some jurisdictions do not allow the limitation or exclusion of liability for incidental or consequential damages, so some of the above limitations may not apply to you.

14. INDEMNIFICATION

You agree to defend, indemnify, and hold harmless the Company, its affiliates, and their respective officers, directors, employees, agents, licensors, and suppliers from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys' fees) arising out of or relating to:

• Your violation of these Terms
• Your use or misuse of the Platform
• Your violation of any law, regulation, or third-party rights
• Any investment decisions you make
• Any content you submit or transmit through the Platform

15. DISPUTE RESOLUTION AND ARBITRATION

15.1 Binding Arbitration

Any dispute, controversy, or claim arising out of or relating to these Terms or the Platform (including their interpretation, performance, or breach) shall be resolved by binding arbitration administered by the American Arbitration Association (AAA) under its Commercial Arbitration Rules, except as modified by these Terms.

15.2 Class Action Waiver

YOU AND THE COMPANY AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

15.3 Exceptions

Either party may seek injunctive or other equitable relief in any court of competent jurisdiction to protect intellectual property rights or confidential information.

16. GOVERNING LAW AND JURISDICTION

These Terms shall be governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict of law principles. To the extent arbitration does not apply, you consent to the exclusive jurisdiction and venue of the state and federal courts located in Delaware.

17. PRIVACY AND DATA PROTECTION

Your privacy is important to us. Our collection, use, and protection of your personal information is governed by our Privacy Policy, which is incorporated into these Terms by reference. By using the Platform, you consent to the collection, use, and disclosure of your information as described in the Privacy Policy.

18. MODIFICATIONS TO TERMS

We reserve the right to modify these Terms at any time. We will provide notice of material changes by:

• Posting the updated Terms on the Platform with a new "Last Updated" date
• Sending notice to the email address associated with your account
• Displaying a prominent notice on the Platform

Your continued use of the Platform after any changes indicates your acceptance of the modified Terms. If you do not agree to the modified Terms, you must stop using the Platform and cancel your account.

19. MODIFICATIONS TO THE PLATFORM

We reserve the right to modify, suspend, or discontinue any aspect of the Platform at any time, with or without notice, for any reason. We shall not be liable to you or any third party for any modification, suspension, or discontinuation of the Platform.

20. THIRD-PARTY LINKS AND SERVICES

The Platform may contain links to third-party websites, services, or resources. We do not endorse and are not responsible for the content, products, services, or practices of any third parties. Your interactions with third parties are solely between you and the third party. You acknowledge and agree that the Company shall not be liable for any damages or losses arising from your use of third-party websites or services.

21. REGULATORY COMPLIANCE

21.1 SEC and FINRA Compliance

The Company is not registered with the Securities and Exchange Commission (SEC) as an investment adviser under the Investment Advisers Act of 1940, and is not a member of the Financial Industry Regulatory Authority (FINRA). The Platform does not provide investment advisory services requiring SEC or FINRA registration.

21.2 State Regulations

You are responsible for ensuring that your use of the Platform complies with all applicable state and local laws and regulations in your jurisdiction.

22. SEVERABILITY

If any provision of these Terms is found to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The invalid, illegal, or unenforceable provision shall be modified to the minimum extent necessary to make it valid, legal, and enforceable.

23. ENTIRE AGREEMENT

These Terms, together with our Privacy Policy and any additional terms to which you agree when using particular features of the Platform, constitute the entire agreement between you and the Company regarding the Platform and supersede all prior agreements and understandings.

24. WAIVER

No waiver of any provision of these Terms shall be deemed a further or continuing waiver of such provision or any other provision. Our failure to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision.

25. ASSIGNMENT

You may not assign or transfer these Terms or your rights under these Terms without our prior written consent. We may assign or transfer these Terms, in whole or in part, without restriction or notification.

26. FORCE MAJEURE

We shall not be liable for any failure or delay in performance due to causes beyond our reasonable control, including acts of God, natural disasters, war, terrorism, riots, embargoes, acts of civil or military authorities, fire, floods, accidents, strikes, or shortages of transportation, facilities, fuel, energy, labor, or materials.

27. CONTACT INFORMATION

If you have questions, concerns, or complaints about these Terms or the Platform, please contact us at:

BY USING THE OPENWEALTH PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS OF SERVICE.