Terms of Service

These Terms of Service ("Terms") govern your access to and use of the Brieflywealth platform, website, and related services (collectively, the "Service") provided by Briefly Wealth LLC ("Brieflywealth," "we," "us," or "our"). By accessing or using the Service, you agree to be bound by these Terms. If you do not agree, do not use the Service.

If you are using the Service on behalf of an organization, you represent and warrant that you have the authority to bind that organization to these Terms, and "you" refers to both you individually and the organization.

Description of the Service

Brieflywealth provides a software-as-a-service platform designed to help financial advisors prepare for client meetings. The Service processes documents, data, and other materials you provide ("Client Data") using artificial intelligence technology to generate structured meeting preparation briefs, summaries, and related outputs ("Outputs").

The Service is intended as a productivity tool. Outputs are generated automatically and are not a substitute for professional judgment, financial advice, legal counsel, or compliance review. You are solely responsible for reviewing all Outputs and determining their accuracy and appropriateness before relying on them in any professional capacity.

Eligibility and Account Registration

You must be at least 18 years of age and capable of forming a binding contract to use the Service. When creating an account, you agree to provide accurate and complete information, keep your credentials confidential, and promptly notify us of any unauthorized access or use of your account. You are responsible for all activity that occurs under your account.

Acceptable Use

You agree to use the Service only for lawful purposes and in accordance with these Terms. You shall not:

• Use the Service in violation of any applicable law, regulation, or industry requirement, including but not limited to securities regulations, data privacy laws, the Gramm-Leach-Bliley Act (15 U.S.C. § 6801 et seq.), the Illinois Biometric Information Privacy Act (740 ILCS 14/1 et seq.), and financial industry compliance obligations.
• Upload, transmit, or provide any Client Data that you do not have the legal right to use, process, or share with a third-party service provider, or for which you have not obtained all necessary client consents and authorizations.
• Upload, transmit, or provide any biometric identifiers or biometric information as defined under BIPA or any comparable state biometric privacy law.
• Attempt to gain unauthorized access to the Service, other user accounts, or any systems or networks connected to the Service.
• Reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code or underlying algorithms of the Service.
• Use the Service to develop a competing product or service, or for benchmarking or competitive analysis purposes.
• Resell, sublicense, or redistribute access to the Service without our prior written consent.
• Introduce any malicious code, viruses, or harmful components to the Service.
• Interfere with or disrupt the integrity or performance of the Service.

Client Data and Your Responsibilities

You retain all rights in and to your Client Data. By uploading or submitting Client Data to the Service, you grant us a limited, non-exclusive license to use, process, store, and transmit that Client Data solely as necessary to provide the Service to you and as described in our Privacy Policy.

You represent and warrant that: (a) you have obtained all necessary consents, authorizations, and permissions required to provide Client Data to us for processing, including any consents required under applicable privacy laws, client advisory agreements, or regulatory obligations; (b) your disclosure of Client Data to us complies with the service provider exception under the Gramm-Leach-Bliley Act (15 U.S.C. § 6802(b)(2)) or any other applicable lawful basis for disclosure; and (c) the Client Data does not contain biometric identifiers or biometric information as defined under BIPA or any comparable state biometric privacy law. You are solely responsible for the accuracy, legality, and appropriateness of all Client Data you provide.

We do not use your Client Data to train, fine-tune, or otherwise improve general-purpose artificial intelligence models or for any purpose other than delivering the Service to you. Our downstream AI service providers are contractually prohibited from using your Client Data to train their models, improve their services for other customers, or for any purpose beyond processing your specific requests.

AI sub-processor and no-training commitment. We route Client Data only to AI sub-processors that contractually prohibit use of inputs and outputs for training general-purpose models. As of the date above, our sole AI sub-processor is Anthropic, PBC, operating under its Commercial Terms (§ B.1). A current list of AI sub-processors is maintained at brieflywealth.com/subprocessors and updated at least thirty (30) days before any material change.

Outputs and Disclaimer

Outputs generated by the Service are produced through automated artificial intelligence processing and are provided on an "as is" basis. While we strive for accuracy, Outputs may contain errors, omissions, or inaccuracies. You acknowledge that:

• Outputs do not constitute financial advice, investment advice, legal advice, tax advice, or compliance guidance of any kind.
• You are solely responsible for independently verifying any information contained in Outputs before acting on it or sharing it with clients or other parties.
• Brieflywealth is not a registered investment adviser, broker-dealer, or financial planner, and the Service does not provide regulated financial services.
• Your use of Outputs in any client-facing or professional context is at your own discretion and risk.
• You have a professional duty of care to review AI-generated content before relying on it, consistent with applicable standards of conduct for financial professionals.

Accuracy and hallucination. Outputs may contain hallucinated content, including statements that appear to be sourced from Client Data but do not in fact appear in the source material. Customer is solely responsible for verifying every factual assertion in an Output against the underlying Client Data before any client-facing use. Briefly disclaims all liability for Customer's reliance on unverified Outputs.

Marketing Rule cooperation. Customer is solely responsible for determining whether any Output, if used in communications with clients or prospective clients, constitutes an "advertisement" under SEC Rule 206(4)-1 and for ensuring compliance with the testimonial, performance, and substantiation requirements thereunder. Outputs do not constitute a "recommendation" under Regulation Best Interest or any fiduciary standard, and the advisor retains sole responsibility for the suitability and appropriateness of any advice.

Customer-side algorithmic risk (Colorado AI Act). Briefly is a developer of an AI system that may, when deployed by Customer, function as a high-risk system under Colo. Rev. Stat. § 6-1-1701 et seq. Briefly will provide Customer, on request and no less than annually, (i) a statement of intended uses and known limitations, (ii) a summary of data types used in training and fine-tuning the system's components, and (iii) information reasonably necessary for Customer to complete an impact assessment. Customer is the "deployer" for purposes of the Act and is responsible for risk management, consumer notice, and impact assessment obligations applicable to deployers.

Fees and Payment

Access to certain features of the Service may require payment of fees. All fees are described on our website or in a separate order form or subscription agreement. Unless otherwise stated, fees are quoted in U.S. dollars, are non-refundable, and are due in accordance with the billing terms specified at the time of purchase.

Fee changes and renewals. Briefly shall provide Customer not less than sixty (60) days' prior written notice of any fee increase, which shall take effect at the start of the next Renewal Term following such notice. Customer may terminate effective at the end of the then-current term by written notice within thirty (30) days of Briefly's price-change notice. For California subscribers, Briefly shall provide all notices, consents, and reminders required by Cal. Bus. & Prof. Code § 17600 et seq. (the Automatic Renewal Law), including the annual renewal reminder and the means to cancel by the same method used to subscribe.

Intellectual Property

Briefly platform and pre-existing IP. Briefly retains all rights, title, and interest in and to the Service, including the software, models, prompts, workflow architecture, and any improvements thereto. Nothing in these Terms transfers ownership of the Service to Customer.

Outputs. As between Briefly and Customer, Briefly assigns to Customer all rights, title, and interest it may have in Outputs generated from Customer's Client Data. Customer acknowledges that, under current U.S. Copyright Office guidance (Copyright and Artificial Intelligence, Part 2, January 2025), Outputs generated substantially by AI may not be eligible for copyright protection absent material human authorship contribution, and Briefly makes no representation regarding the copyrightability of any Output. Customer grants Briefly a limited, non-exclusive license to process Client Data and generate Outputs solely for the purpose of providing the Service.

Confidentiality and Data Protection

We understand the sensitive nature of financial client data and the regulatory obligations that govern it. We treat all Client Data as confidential information and maintain safeguards consistent with the requirements of 15 U.S.C. § 6801(b) of the Gramm-Leach-Bliley Act, including administrative, technical, and physical measures designed to protect against unauthorized access to or use of such information.

We will not disclose Client Data to third parties except: (a) as necessary to provide the Service, such as to our cloud hosting and AI processing providers, who are bound by contractual confidentiality obligations, data use restrictions, and security requirements commensurate with the sensitivity of the information being processed; (b) as required by law; or (c) with your consent.

Our data protection commitments include the following contractual safeguards with our AI service providers: (i) restrictions on the provider's use of Client Data for training or improving AI models; (ii) explicit confidentiality obligations covering all AI inputs and outputs; (iii) data security requirements commensurate with the sensitivity of the information, informed by industry-recognized standards such as the SOC 2 Trust Services Criteria; and (iv) audit rights to verify ongoing compliance with contractual security obligations.

Sub-processors. A current list of sub-processors (including cloud hosting and AI inference) is maintained at brieflywealth.com/subprocessors. Briefly will provide Customer at least thirty (30) days' advance notice of any new sub-processor materially involved in processing Client Data, and Customer may terminate the affected services without penalty if it reasonably objects on regulatory or security grounds.

Service-provider oversight. Customer shall have the right, no more than once annually and on reasonable notice, to review Briefly's written information security program documentation, sub-processor list, and incident response plan. Briefly shall complete Customer's standard vendor due-diligence questionnaire upon request.

Security Standards

Our information security program is informed by industry-recognized frameworks, including the SOC 2 Trust Services Criteria (security, availability, processing integrity, confidentiality, and privacy). Formal certification is on our enterprise roadmap, not yet in audit. In the interim, we apply commercially reasonable safeguards aligned with SOC 2 principles and evaluate our critical service providers based on their own security certifications and practices. Available artifacts include our written information security program documentation, sub-processor list, and incident response plan.

In the event of a security incident involving unauthorized access to or disclosure of Client Data, we will notify you in accordance with applicable federal and state data breach notification laws, including the Illinois Personal Information Protection Act (815 ILCS 530/1 et seq.).

Incident notification. Briefly shall notify Customer in writing of any actual or reasonably suspected Security Incident involving Customer Data or Client Data no later than seventy-two (72) hours after discovery, and shall provide all information reasonably necessary for Customer to satisfy its obligations under SEC Regulation S-P (17 CFR § 248.30) and the FTC Safeguards Rule (16 CFR § 314.4(j)). Briefly will also comply with applicable state breach notification laws, including but not limited to 815 ILCS 530/10 and Cal. Civ. Code § 1798.82.

Term and Termination

These Terms are effective from the date you first access or use the Service and continue until terminated. You may terminate your account at any time by contacting us or using the account management features within the Service.

Suspension and termination by Briefly. Briefly may suspend the Service only (a) upon Customer's uncured material breach following thirty (30) days' written notice, (b) upon Customer's non-payment following fifteen (15) days' written notice, or (c) immediately where required by law or to prevent imminent harm to the Service or other customers, in which case Briefly shall provide notice as promptly as reasonably practicable. Upon termination for any reason other than Customer's uncured material breach, Customer shall have ninety (90) days to export Client Data in a commercially reasonable, machine-readable format, after which Briefly shall securely delete Client Data within thirty (30) days and provide written certification of deletion upon request.

Books-and-records support. Briefly shall make Client Data and Outputs available for export in a machine-readable, archivable format (CSV, JSON, or PDF) throughout the term and for not less than ninety (90) days post-termination, and shall reasonably cooperate with Customer's obligations under 17 CFR § 275.204-2 (Investment Advisers Act Books and Records Rule).

Disclaimer of Warranties

THE SERVICE 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, ACCURACY, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, OR COMPLETELY SECURE, OR THAT ANY OUTPUTS WILL BE ACCURATE, COMPLETE, OR RELIABLE. WE DO NOT WARRANT THAT THE SERVICE WILL SATISFY ANY SPECIFIC REGULATORY OR COMPLIANCE REQUIREMENTS APPLICABLE TO YOUR PRACTICE.

Limitation of Liability

Subject to the carve-outs below, each party's aggregate liability arising out of or related to these Terms shall not exceed the greater of (a) the fees paid or payable by Customer in the twelve (12) months preceding the event giving rise to the claim or (b) fifty thousand dollars ($50,000).

Notwithstanding the foregoing, each party's aggregate liability for (i) breach of confidentiality or data security obligations, (ii) indemnification obligations under § 13, or (iii) violation of applicable privacy law shall not exceed three (3) times the fees paid or payable by Customer in the twelve (12) months preceding the claim.

Nothing in this Section limits liability for (x) gross negligence or willful misconduct, (y) a party's payment obligations, or (z) liability that cannot be limited as a matter of law.

In no event shall either party be liable for indirect, incidental, consequential, special, punitive, or exemplary damages, including lost profits, lost data, or business interruption, even if advised of the possibility of such damages.

Indemnification

By Customer. Customer shall defend, indemnify, and hold harmless Briefly from any third-party claim arising out of (a) Customer Data or Client Data, including any claim that Customer lacked the rights or consents necessary to upload such data, (b) Customer's use of Outputs in violation of these Terms or applicable law, or (c) Customer's breach of these Terms.

By Briefly. Briefly shall defend, indemnify, and hold harmless Customer from any third-party claim alleging that Customer's authorized use of the Service or Outputs (excluding modifications by Customer or combinations with non-Briefly materials) infringes any U.S. patent, copyright, trademark, or trade secret, and shall pay damages and reasonable attorneys' fees finally awarded or agreed in settlement. Briefly's obligations under this Section shall not apply to claims to the extent arising from (a) Customer Data, (b) Customer's modification of Outputs, or (c) Customer's use of the Service in violation of these Terms.

Procedure. The indemnified party shall promptly notify the indemnifying party of any claim, give the indemnifying party sole control of the defense and settlement (provided that no settlement shall require the indemnified party to admit liability or pay any sum without its prior written consent), and reasonably cooperate at the indemnifying party's expense.

Modifications to the Service and Terms

We reserve the right to modify, suspend, or discontinue the Service, or any part thereof, at any time with or without notice.

Modifications to these Terms. Briefly will provide at least thirty (30) days' advance notice of any material change to these Terms by email to Customer's administrative contact and by posting the updated Terms with a new "Last updated" date. If Customer objects in writing within that period, the prior Terms shall continue to apply through the end of the then-current Subscription Term, after which Customer may terminate without further obligation.

Governing Law and Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of the State of Illinois, without regard to its conflict of law principles. Any dispute arising out of or relating to these Terms or the Service shall be resolved exclusively in the state or federal courts located in Cook County, Illinois, and you consent to the personal jurisdiction of such courts.

General Provisions

These Terms, together with the Privacy Policy and any other agreements referenced herein, constitute the entire agreement between you and Brieflywealth regarding the Service. If any provision of these Terms is found to be unenforceable, the remaining provisions will continue in full force and effect. Our failure to enforce any right or provision of these Terms shall not constitute a waiver of that right or provision. You may not assign or transfer your rights under these Terms without our prior written consent. We may assign our rights and obligations under these Terms without restriction.

Contact Us

If you have any questions about these Terms, please contact us at: