Terms of Service

Current operator for review purposes: Jake Capps and Simon Capps, jointly. When GuardRail forms a legal entity, these Terms will be updated to identify that entity.

Plain-English summary

GuardRail is a financial-accountability and early-warning service. In the standard adult flow, a Member age 18 or older creates a GuardRail account, agrees to the applicable information-sharing terms, and connects an eligible financial account the Member owns or is legally authorized to connect. The Member then invites an Accountability Partner, who accepts the invitation. Nothing is shared until the Member chooses to invite someone. In the Minor Family Feature, a parent or legal guardian creates the Family Account and serves as the Accountability Partner. The Minor Participant, who must be age 13 through 17, receives a separate plain- language notice and must affirmatively agree before monitoring begins. The parent or guardian completes the Quiltt bank connection only for an eligible financial account or card account jointly owned by the parent or guardian and the Minor Participant and remains responsible for the financial connection. GuardRail analyzes permitted financial data, which may include up to 12 months of available transaction activity from before the connection date, together with optional onboarding context to create Risk Information. Risk Information may include an initial baseline and historical assessment, a Risk Score, Green/Yellow/Red Risk Status, trends, warning categories, explanations, weekly summaries, qualifying alerts, and monitoring-status information. GuardRail may show limited transaction details only for a transaction it classifies as a possible gambling-related purchase. It does not provide an unrestricted feed of ordinary transactions to an Accountability Partner.

Important limitations

GuardRail cannot see bank passwords, move money, block or reverse transactions, freeze an account, diagnose gambling addiction, guarantee that gambling will be detected, or guarantee that an alert will arrive before harm occurs. Risk Information and historical assessments may be delayed, incomplete, misclassified, or wrong, and older activity does not necessarily indicate current risk.

1. Agreement and scope

These Terms of Service ("Terms") form a legally binding agreement between each adult who accepts them and GuardRail, currently operated jointly by Jake Capps and Simon Capps ("GuardRail," "we," "us," or "our"), concerning access to and use of the GuardRail mobile application, website, secure invitation and consent pages, dashboards, alerts, reports, and related services (collectively, the "Service"). When GuardRail forms a legal entity, that entity will replace the current operator description in these Terms. The Privacy Policy is incorporated into these Terms and explains how GuardRail collects, receives, derives, uses, shares, retains, and protects personal information, including onboarding information and available historical transaction information. Product screens, invitation notices, consent and assent screens, purchase disclosures, and applicable addenda may provide additional terms for a specific feature. If a specific disclosure conflicts with these Terms, the more specific disclosure controls for that feature to the extent of the conflict. GuardRail is designed to support accountability and informed conversations about transaction-based indicators of gambling-related financial risk. GuardRail is not a bank, money transmitter, payment processor, gambling operator, lender, credit-reporting agency, financial adviser, healthcare provider, treatment provider, emergency- monitoring service, or substitute for professional care.

2. Key roles and definitions

Term Meaning

Term Meaning Member A person age 18 or older who accepts an invitation from an Accountability Partner and whose selected financial activity GuardRail analyzes. In the standard adult flow, the Member completes the Quiltt bank connection. Accountability Partner A person age 18 or older who initiates or participates in a GuardRail relationship and is permitted to receive only the limited Risk Information described in these Terms, the Privacy Policy, and the applicable invitation and permission screens. In the Minor Family Feature, the Accountability Partner must be the Minor Participant's parent or legal guardian. Minor Participant A person who is at least 13 but younger than 18 and participates through the parent- or legal-guardian-led Minor Family Feature. Family Account The GuardRail relationship connecting a Minor Participant with the parent or legal guardian serving as the Accountability Partner. Connected Account An eligible financial account or card account connected through Quiltt and selected for the permitted GuardRail analysis. In the standard adult flow, the Member owns or is legally authorized to connect the account. In the Minor Family Feature, the account or card account must be jointly owned by the parent or legal guardian and the Minor Participant. Risk Information The initial baseline or historical assessment, Risk Score, Green/Yellow/Red Risk Status, score change, trend, warning categories, explanations, weekly summaries, qualifying alerts, selected supporting details, and monitoring-status information created by GuardRail. Possible gambling-related purchase A transaction GuardRail classifies, with the applicable confidence level, as involving a merchant, app, website, or service associated with gambling, wagering, prize-based play, prediction markets, event contracts, or a similar risk category. This is a GuardRail product classification, not a legal determination.

3. Eligibility and acceptance

3.1 Adults

Only a person age 18 or older may create an adult GuardRail account, purchase a subscription, initiate a GuardRail relationship, participate as a Member or Accountability Partner, or complete the Quiltt bank connection. By performing any of those actions, the adult represents that they are legally able to enter these Terms and that the information they provide is accurate to the best of their knowledge. An adult accepts these Terms by creating an account, accepting an invitation, inviting a Member, agreeing to an information-sharing relationship, providing parent or legal guardian authorization, completing the Quiltt bank connection, purchasing a subscription, or otherwise using the Service after being presented with these Terms.

3.2 Minor Participants

A person age 13 through 17 may participate only through the Minor Family Feature. The parent or legal guardian accepts these Terms in the adult's own capacity, confirms the parental or guardianship relationship, provides the required adult authorization, and is responsible for the subscription and the jointly owned Connected Account. The Minor Participant receives a separate plain-language notice and must affirmatively agree before monitoring begins. The Minor Participant does not purchase the Service, complete the Quiltt bank connection, or enter financial-institution credentials through GuardRail.

3.3 No users under 13

GuardRail is not available to children under 13, even with parental permission. A child under 13 must not create a profile, accept an invitation, submit personal information, or participate. If GuardRail learns that a child under 13 submitted information, GuardRail may stop the registration or monitoring process and delete the information, except for a minimal record reasonably necessary for security, legal compliance, fraud prevention, or documentation of the incident.

3.4 Age-18 transition

Monitoring does not automatically end when a Minor Participant turns 18. At or shortly after age 18, GuardRail may ask the individual to accept the Terms and Privacy Policy applicable to Members and confirm whether the existing Accountability Partner relationship should continue. GuardRail may provide a reasonable transition period. If the individual does not confirm continued participation, GuardRail may stop creating and sharing new Risk Information and notify the former Accountability Partner only that monitoring has ended.

4. How GuardRail works

4.1 Standard adult flow

• The Member creates a GuardRail account, confirms that they are at least 18, and accepts these Terms, the Privacy Policy, and the applicable information-sharing disclosures.
• The Member connects an eligible account the Member owns or is legally authorized to connect, through the Quiltt bank connection, and selects the account or card activity designated for analysis.
• The Member invites an Accountability Partner to join the GuardRail relationship. No Risk Information is shared with anyone until the Member does this.
• The Accountability Partner accepts the invitation and the applicable information-sharing disclosures.
• When available, GuardRail may analyze up to 12 months of transaction activity from before the connection date to establish an initial baseline, identify historical patterns or changes over time, and compare later activity with the Member's prior activity. The amount and completeness of available history varies by financial institution and account.
• Sharing with the Accountability Partner begins only after the Member's eligible financial connection is active and the Accountability Partner has accepted the invitation. The Member receives the applicable dashboard and controls; the Accountability Partner receives only the limited Risk Information authorized by the Service.

4.2 Minor Family Feature flow

• The parent or legal guardian creates the Family Account, serves as the Accountability Partner, identifies the Minor Participant, confirms the relationship, and provides the required adult authorization.
• The Minor Participant receives a separate plain-language notice explaining the designated activity, Risk Score, information-sharing rules, limitations, controls, and age-18 transition, and must affirmatively agree before monitoring begins.
• The parent or legal guardian completes the Quiltt bank connection only for an eligible financial account or card account jointly owned by the parent or legal guardian and the Minor Participant. The Minor Participant does not complete the Quiltt bank connection or provide financial-institution credentials.
• When available for the eligible connection, GuardRail may analyze up to 12 months of transaction activity from before the connection date to establish an initial baseline and identify historical patterns or changes over time.
• Monitoring begins only after adult authorization, Minor Participant assent, and an eligible financial connection are complete.

4.3 Features

Depending on the plan, institution support, device, settings, development stage, and Quiltt and Finicity approval, GuardRail may provide:

• secure invitation, acceptance, consent, assent, and relationship-management workflows;
• optional onboarding and profile questions for Members, Accountability Partners, and age-appropriate Minor Participant flows;
• read-only financial-account connection through Quiltt;
• transaction ingestion, up to 12 months of available pre-connection historical analysis when approved, merchant classification, recurring-pattern detection, and behavioral trend analysis;
• an initial baseline and historical assessment showing the period of available pre-connection activity analyzed, when sufficient history is available;
• a Risk Score from 0 to 100, Green/Yellow/Red Risk Status, trend views, warning categories, and explanations of meaningful changes;

• weekly Risk Score summaries when enabled;
• Risk Status change alerts, qualifying gambling-related or material-escalation alerts, and monitoring-integrity alerts;
• limited details for transactions classified as possible gambling-related purchases, while ordinary and unrelated transaction details remain hidden from Accountability Partner views;
• connection status, last successful refresh, partner status, alert history, correction requests, monitoring controls, disconnection, and deletion controls; and
• general prompts such as continue monitoring, schedule a conversation, or seek qualified help. These prompts are not professional advice. GuardRail may test, add, modify, limit, suspend, or discontinue features. Material changes to the categories of financial data used, the purpose of the analysis, or information shared with another participant will be accompanied by updated notice and renewed authorization or assent when required.

5. Accounts, invitations, and security

• You must provide accurate, current, and complete information and update it when it changes.
• You are responsible for protecting your GuardRail credentials, one-time codes, devices, and authenticated sessions and for activity through your account unless caused by GuardRail's breach of a legal duty.
• You must promptly notify GuardRail of suspected unauthorized access, a compromised device, an incorrect age or relationship, or an invitation sent to the wrong person.
• You may not share a login or access code in a way that bypasses role-based permissions or allows an unauthorized person to receive Risk Information.
• GuardRail may require email, mobile, device, identity, age, relationship, parental or guardianship authority, or account-authority verification before enabling a feature or responding to a request.
• GuardRail may reject, suspend, or reverse an invitation, account connection, role assignment, or monitoring relationship if information cannot be verified or appears unauthorized, misleading, abusive, or inconsistent with the approved product flow. A Minor Participant is not required to have a personal email address, mobile number, personal device, or app installation. GuardRail may provide the Minor Participant notice and later access through a secure browser page, shared-device session, one-time code, or separate access identifier.

6. Minor Family Feature

6.1 Parent or legal guardian responsibilities

The parent or legal guardian serving as the Accountability Partner must:

• be at least 18 and legally authorized to act as the Minor Participant's parent or legal guardian;
• provide accurate age, identity, and relationship information and notify GuardRail if the relationship or authority changes;
• create the Family Account and accept these Terms, the Privacy Policy, and the applicable notices;
• complete the Quiltt bank connection only for an eligible financial account or card account jointly owned by the parent or legal guardian and the Minor Participant and for which the adult has lawful authority to access and disclose the data for the GuardRail purpose;
• identify the account, card, or activity intended for the Minor Participant and avoid presenting uncertain shared- account activity as belonging to the Minor Participant;
• review the information and notification permissions shown during onboarding; and
• use GuardRail only for supportive financial accountability and not for harassment, coercion, humiliation, retaliation, discrimination, financial exploitation, or unlawful surveillance.

6.2 Minor notice and assent

Before GuardRail begins creating Risk Information associated with a Minor Participant, GuardRail will provide a separate plain-language notice that identifies the parent or guardian, describes the designated jointly owned account or card activity, explains the Risk Score and analyzed signals, states that available transaction activity from before the GuardRail connection date may be included in the initial analysis, describes what the

Accountability Partner may and may not receive, explains the limitations of classification and attribution, describes how monitoring can be stopped, and explains the age-18 transition. The Minor Participant must affirmatively agree before monitoring begins. GuardRail may record the notice version, date, time, access method, acknowledgement choices, and assent status. A material expansion of the designated account, purpose, or information shared may require a new notice and assent.

6.3 Joint accounts and attribution

The Minor Family Feature is intended only for an eligible financial account or card account jointly owned by the parent or legal guardian and the Minor Participant. The parent or guardian must have lawful account authority and lawful authority to access and disclose the data for the GuardRail purpose. The exact joint-account structures supported in production depend on Quiltt and financial-institution coverage and approval. A transaction record may relate to more than one person. If the institution does not provide a reliable card, subaccount, authorized-user, or similar identifier, GuardRail will not state that a particular shared-account transaction was completed by the Minor Participant. GuardRail may label the activity as shared or account-level activity, reduce the confidence assigned to the signal, request clarification, exclude the activity, or decline to create a Minor Participant-specific score.

6.4 Minor Participant controls

A Minor Participant may use an available GuardRail control or contact GuardRail to stop monitoring associated with the Minor Participant profile. After the request is processed, GuardRail will stop using newly received activity to create or share new Risk Information about that Minor Participant and will notify the parent or legal guardian that monitoring is no longer active. This control does not disconnect, close, or otherwise control the underlying jointly owned financial account or card account.

7. Connected financial accounts

7.1 Who completes the bank connection

In the standard adult flow, the Member completes the Quiltt bank connection. In the Minor Family Feature, the parent or legal guardian serving as the Accountability Partner completes the Quiltt bank connection. A Minor Participant does not independently complete the Quiltt bank connection or provide financial-institution credentials through GuardRail.

7.2 Account-authority certification

In the standard adult flow, by connecting a financial account or card account, the Member represents and warrants that the Member owns the account or is otherwise expressly and lawfully authorized to access the account and disclose the information for the GuardRail purposes described in these Terms and the Privacy Policy. In the Minor Family Feature, the parent or legal guardian represents and warrants that the Connected Account is jointly owned by the adult and the Minor Participant and that the adult has lawful authority to access and disclose the information for the GuardRail purpose. No person may use another person's credentials or connect an account without lawful authority. GuardRail may request information reasonably necessary to confirm account authority and may reject, limit, or disconnect a connection if authority is disputed, cannot be verified, or is inconsistent with Quiltt, financial- institution, legal, or contractual requirements.

7.3 Read-only connection and credentials

Quiltt, Finicity, and the connected financial institution handle financial authentication. GuardRail does not receive or store the bank password, one-time code, or similar credential entered in the Quiltt bank connection. GuardRail receives permitted financial account and transaction information through a read-only connection. GuardRail cannot transfer money, freeze an account, block a merchant, approve or decline a transaction, reverse a payment, or change financial- institution settings.

7.4 Account selection and data availability

The person completing the Quiltt bank connection must select only accounts and cards appropriate for the disclosed monitoring relationship. Not all institutions, account types, card structures, balances, transactions, merchant details, recurring indicators, or authorized-user fields are available. Data may be delayed, incomplete, duplicated, corrected, reversed, removed, stale, or unavailable. GuardRail may require reauthentication or may discontinue a connection that is no longer supported.

7.5 Historical transaction information

When an eligible Connected Account is first connected, GuardRail may request and analyze up to 12 months of available transaction information from before the connection date, together with transaction information received after connection. GuardRail may use this information to establish an initial baseline, identify historical patterns and changes over time, generate initial Risk Information, and compare subsequent activity with prior activity. The amount and completeness of historical information depends on the financial institution, account, Quiltt coverage, and other factors. Historical information may cover less than the requested period, may be incomplete, or may be unavailable. GuardRail may display an analyzing state until the available historical update has been received and processed and will not represent that the available history is a complete record of the participant's financial or gambling-related activity.

7.6 Quiltt, Finicity, and financial-institution terms

Use of Quiltt, Finicity, and a connected financial institution may be subject to separate terms and privacy notices from Quiltt, Finicity, and the institution. GuardRail does not control those services. Quiltt, Finicity, or the institution may change, limit, or terminate access, require reauthentication, or provide privacy controls. GuardRail will use connected data only for the approved GuardRail use case and as described in the Privacy Policy.

8. Risk Information, scoring, and alerts

8.1 Purpose and score ranges

Risk Information is intended to summarize transaction-based warning patterns and changes over time. Where sufficient historical information is available, GuardRail may generate an initial baseline and historical assessment using up to 12 months of available transaction activity from before the connection date. Historical activity may be weighted differently based on its age, relevance, completeness, and relationship to more recent activity. Older activity may provide context without necessarily indicating the Member's or Minor Participant's current level of risk. The current Risk Score ranges are generally Green 0-29, Yellow 30-59, and Red 60-100. GuardRail may adjust thresholds or methodology to improve accuracy, reduce false alerts, or respond to changes in available data. Monitoring Off, Data Stale, Reauthentication Required, or Coverage Interrupted are operational states, not gambling-risk findings.

8.2 Signals

Signals may include possible gambling-related merchants, a new gambling merchant, gambling transaction amount and frequency, repeated or recurring gambling-related payments, escalation, persistence, timing, merchant diversity, peer-to-peer and cash patterns when supported by stronger signals, ATM or cash-advance activity, financial-stress indicators where enabled, and monitoring integrity. Peer-to-peer transfers, ATM withdrawals, cash activity, balance pressure, and similar lower-confidence activity may have many legitimate explanations. They are not proof of gambling and generally should not create a direct gambling alert by themselves.

8.3 Gambling-related product classification

For GuardRail's product classification only, a possible gambling-related merchant may include a sportsbook, casino, lottery or sweepstakes service, real-money poker or card-game service, fantasy-wagering service,

gamified or video-game wagering service, prize-based or wager-to-win app, prediction market, or event-contract platform. This classification is not a legal determination that a merchant or activity constitutes gambling under any particular law. Traditional investment and brokerage platforms are not classified as gambling merchants solely because investing involves risk or possible loss. GuardRail may revise merchant classifications as information changes and may allow participants to request a review.

8.4 Transaction details shown

For a transaction on the Connected Account that GuardRail classifies as a possible gambling-related purchase, GuardRail may display the merchant or app, amount, date, time when available, number of qualifying purchases, total amount, relevant period, and general Risk Score impact. GuardRail does not display transaction details for ordinary or unrelated purchases in Accountability Partner views. Peer-to-peer, ATM, cash-related, balance, or other lower-confidence patterns may influence the Risk Score or appear as a general warning category, but GuardRail does not display the underlying recipient, note, ordinary merchant, amount, date, time, or other transaction details unless the transaction itself is classified as a possible gambling-related purchase.

8.5 Alerts and timing

• Weekly Risk Summary. Optional and sent only when enabled.
• Risk Status change. May be sent when the status changes between Green, Yellow, and Red in either direction, including improvement.
• Gambling-related or material-escalation alert. May be sent when confidence, thresholds, and notification settings are satisfied. GuardRail does not promise an alert for every transaction.
• Monitoring-integrity alert. May be sent when monitoring is disabled, the connection is stale or disconnected, reauthentication is required, the account is deleted, a Minor Participant stops monitoring, or a required relationship ends.
• App-status notice. May be sent on a best-effort basis when a registered device appears unable to receive required notifications. This signal does not prove that the app was uninstalled. Data timing GuardRail can generate an alert only after it receives and processes updated information. Financial institutions and Quiltt or Finicity may provide updates on a delay. GuardRail is not a real-time bank feed, and notification delivery is not guaranteed. When historical transaction information is requested, GuardRail may display an analyzing state until the available historical update has been received and processed.

8.6 Limitations and corrections

Risk Information may be affected by delayed or missing transactions, incorrect merchant names or categories, pending or reversed charges, shared accounts, cash activity, unconnected accounts, payment-app limitations, financial-institution outages, Quiltt and Finicity coverage, onboarding information, historical-data availability, and changes to GuardRail's methodology. Historical transaction information may cover less than the requested period, may be incomplete, and may be unavailable for some institutions or accounts. GuardRail may miss gambling activity and may incorrectly flag lawful or unrelated activity. GuardRail will describe the period of available history analyzed when presenting an initial historical assessment and will not represent that the historical information is complete. An initial historical assessment is an estimate based only on available information and is not a diagnosis or proof of current gambling behavior. A participant may ask GuardRail to review a merchant classification, transaction attribution, or displayed item. A request does not automatically remove an alert or lower a Risk Score. GuardRail may correct future scoring when appropriate and may notify an affected Accountability Partner if a material prior alert was incorrect. Correction requests are reviewed by GuardRail and are not a private messaging channel between participants.

GuardRail does not use Risk Information for credit, insurance, employment, housing, education-admission, or similar eligibility decisions and does not automatically punish, block, or restrict a person based on a score.

9. Accountability Partner access and responsibilities

9.1 Information an Accountability Partner may receive

• an initial historical assessment showing the period of available pre-connection activity analyzed, the initial baseline, and relevant trend context, when sufficient history is available;
• the current Risk Score and Green, Yellow, or Red Risk Status;
• score change, trend direction, meaningful warning categories, and a general explanation of why the score changed;
• an optional weekly summary and notifications when the Risk Status changes;
• qualifying gambling-related or material-escalation alerts;
• monitoring-integrity and best-effort app-status notices;
• limited supporting details for a transaction classified as a possible gambling-related purchase; and
• connection status, last successful refresh, partner status, and last alert sent.

9.2 Information an Accountability Partner does not receive

• financial-institution usernames, passwords, one-time codes, or similar credentials;
• full account or card numbers;
• the ability to move, freeze, block, reverse, approve, or decline money or transactions;
• an unrestricted feed of every transaction, every ordinary merchant, every transfer, or every unrelated purchase;
• transaction-level details for ordinary or unrelated activity;
• a statement that a specific person completed a shared-account transaction when available data does not reasonably support that conclusion;
• the exact proprietary scoring formula; or
• a diagnosis or guarantee that a person is or is not gambling.

9.3 Accountability Partner duties

An Accountability Partner must use Risk Information only for the supportive accountability purpose presented in GuardRail, keep the information reasonably confidential, respect the Member's or Minor Participant's dignity and safety, and avoid using the Service or Risk Information to harass, threaten, discriminate against, exploit, publicly shame, retaliate against, or unlawfully control another person. An Accountability Partner must not use Risk Information for employment, housing, education, credit, insurance, medical, legal, law-enforcement, or other eligibility or punitive decisions. GuardRail may suspend or terminate access when it reasonably believes Risk Information is being misused.

9.4 Previously delivered information

Removing an Accountability Partner, ending monitoring, or deleting an account stops future access after the change is processed. GuardRail cannot necessarily recall information already delivered, viewed, copied, photographed, forwarded, downloaded, or stored outside GuardRail.

10. Onboarding and profile information

10.1 Separate perspectives

GuardRail may separately ask a Member and an Accountability Partner to provide onboarding or profile information. Questions may concern observed financial behavior, gambling-related concerns or history, typical spending patterns, requests for money, financial stress, goals, preferences, known risk factors, or other context relevant to the GuardRail purpose. In the Minor Family Feature, GuardRail may ask the parent or legal guardian

questions appropriate to the permitted family flow and may provide the Minor Participant with separate age- appropriate questions or choices. GuardRail may identify or internally record whether information was provided by the Member, the Accountability Partner, the parent or legal guardian, or another authorized participant. Information provided by one participant is not necessarily independently verified and should not be treated as an agreed fact merely because it was submitted through the Service.

10.2 Accuracy and respectful use

Each adult agrees to provide information that is accurate to the best of their knowledge and not knowingly false, misleading, harassing, or defamatory. A participant must distinguish personal observations from assumptions when reasonably possible. A disagreement between participants does not by itself prove dishonesty, gambling, or wrongdoing.

10.3 How onboarding information may be used

GuardRail may use onboarding and profile information, together with connected financial data, to establish an initial baseline, provide context for transaction analysis, personalize Risk Information, tailor alerts and explanations, identify differences between reported and observed activity, support corrections, and operate or improve the Service as described in the Privacy Policy. Onboarding information may influence Risk Information, but partner-provided statements alone should not be treated as a confirmed gambling transaction or automatically create a Red Risk Status. GuardRail may change the specific questions as the Service develops. GuardRail will provide additional notice and obtain renewed authorization or assent when required before collecting a materially different category of information or using information for a materially different purpose.

11. Monitoring controls, disconnection, and deletion

11.1 Standard adult flow controls

The Member controls the Member's GuardRail account, Connected Account, available monitoring settings, and account-deletion request. Depending on the plan, the Member or Accountability Partner may end the relationship through available controls. GuardRail may notify the other participant that monitoring or sharing is no longer active, without disclosing additional private details.

11.2 Minor Family Feature controls

The parent or legal guardian serving as the Accountability Partner controls the financial connection for the jointly owned Connected Account and may disconnect it or request deletion of the Family Account. The Minor Participant may stop monitoring associated with the Minor Participant profile. GuardRail will notify the parent or guardian that monitoring ended. The Minor Participant's GuardRail control does not close, disconnect, or alter the underlying financial account or card account.

11.3 Disconnection and reauthentication

Disconnecting a Connected Account stops new data collection after the request is processed. A connection may also stop or become stale because of a financial-institution change, a Quiltt or Finicity control, revoked permission, expired authorization, or required reauthentication. GuardRail may preserve the last Risk Score as historical and label it no longer current rather than treating lack of data as a new risk finding.

11.4 Deleting the app versus deleting the account

Removing the GuardRail app from a device does not necessarily close the GuardRail account or disconnect Quiltt. If the account and connection remain active, permitted monitoring and alerts may continue. GuardRail may

provide a best-effort notice when a registered device appears unable to receive notifications, but GuardRail cannot reliably prove that an app was uninstalled.

11.5 Account deletion

When a verified account-deletion request is processed, GuardRail will stop new monitoring, end future participant access, and handle retained information as described in the Privacy Policy. GuardRail may notify an active Accountability Partner only that coverage ended. Deletion does not necessarily recall information previously delivered outside GuardRail and may be subject to legal, security, fraud, dispute, backup, and consent-record exceptions.

12. Fees, subscriptions, cancellation, and refunds

Publication placeholders Before publication, GuardRail must insert the final legal entity, effective date, contact information, price, billing interval, trial terms, automatic-renewal disclosure, cancellation method, refund policy, taxes, payment provider, governing law, venue, arbitration contact, and any app-store-specific terms. The purchase screen, Privacy Policy, and these Terms must match the production Service.

12.1 Adult purchaser

Only an adult may purchase a GuardRail subscription. The adult purchaser is responsible for all disclosed fees, applicable taxes, payment-method accuracy, and cancellation. A Minor Participant is not responsible for payment.

12.2 Subscription terms

The price, included features, billing period, trial or promotional period, and renewal terms will be disclosed before purchase. Unless the purchase disclosure states otherwise, a paid subscription may automatically renew until canceled. By purchasing, the adult authorizes GuardRail or its payment provider to charge the selected payment method according to the disclosed schedule.

12.3 Cancellation and effect

The adult purchaser may cancel through the method shown at purchase or in account settings. Cancellation generally prevents future renewal and does not automatically disconnect a Connected Account, end an accountability relationship, or delete information unless the product screen expressly states otherwise. GuardRail will clearly identify any monitoring consequence associated with plan expiration or cancellation.

12.4 Refunds and price changes

Refund eligibility will be governed by the purchase disclosure, applicable law, and any app-store or payment- provider rules. GuardRail may change prices or plan features prospectively with notice required by law. A price change will not apply retroactively to a completed billing period.

13. Electronic communications

By creating an adult account or providing contact information, you consent to receive electronic records and communications relating to the Service, including invitations, consent and assent records, account and security notices, billing notices, legal notices, Risk Information, optional summaries, and monitoring-integrity messages, through the app, push notification, email, SMS, or another disclosed channel.

Optional promotional communications, if any, will be handled separately from required operational messages. Participants may turn off optional reports and nonessential notifications, but GuardRail may continue to send security, account, billing, legal, consent, and monitoring-integrity notices necessary to operate the Service or document a change in monitoring. Carrier message and data rates may apply to SMS. Where available, replying STOP may opt out of optional SMS, and replying HELP may provide assistance. Opting out of a communication channel may limit features that depend on that channel. Electronic delivery is not guaranteed and may be delayed by device, carrier, provider, or network conditions.

14. Acceptable use

You may use the Service only for lawful, personal, supportive financial-accountability purposes consistent with the approved GuardRail use case. You must not:

• connect or attempt to connect a financial account without lawful authority;
• impersonate another person, misrepresent age, identity, guardianship, relationship, account authority, or consent, or create a false monitoring relationship;
• use Risk Information to harass, threaten, discriminate against, shame, exploit, retaliate against, stalk, or unlawfully control another person;
• use the Service for credit, insurance, employment, housing, education-admission, law-enforcement, medical, legal, or similar eligibility or punitive decisions;
• sell, rent, publish, broker, or commercially exploit Risk Information or connected financial data;
• attempt to bypass role-based permissions, security controls, consent screens, monitoring controls, rate limits, or technical restrictions;
• upload malware, interfere with the Service, scan or test systems without written authorization, or attempt unauthorized access;
• reverse engineer, decompile, disassemble, copy, scrape, or create a substitute for the Service except to the limited extent applicable law does not permit restriction;
• use automated means to access the Service except through an interface GuardRail expressly authorizes;
• submit unlawful, infringing, threatening, deceptive, defamatory, abusive, or intentionally false content; or
• use Quiltt, a financial institution, or connected data in a manner prohibited by their terms, GuardRail's agreement with Quiltt, or applicable law.

15. Third-party services

The Service may depend on Quiltt, financial institutions, app stores, payment processors, hosting providers, communications providers, identity or authentication providers, and other third parties. Their services, availability, terms, privacy practices, and decisions are outside GuardRail's control. GuardRail is not responsible for third- party outages, data errors, account restrictions, authentication failures, delayed updates, or changes in coverage, except to the extent liability cannot lawfully be excluded. A link or integration does not imply that GuardRail controls, endorses, or is responsible for the third party. Participants must comply with applicable third-party terms. GuardRail may modify or discontinue a feature if a third-party service changes or ends.

16. Ownership and license

16.1 GuardRail materials

GuardRail and its licensors own the Service and its software, designs, interfaces, text, graphics, trademarks, logos, scoring methods, classifications, documentation, and other materials, excluding personal information and raw data belonging to participants or third parties. Subject to these Terms, GuardRail grants you a limited, personal, revocable, nonexclusive, nontransferable license to use the Service for its intended purpose.

16.2 Participant content and feedback

You retain any rights you have in information you submit. You grant GuardRail the rights reasonably necessary to host, process, analyze, display, and transmit that information to operate the Service as described in these Terms and the Privacy Policy. You represent that you have the rights and authority necessary to provide the information. If you provide feedback, suggestions, or ideas about the Service, GuardRail may use them without restriction or compensation, provided that GuardRail does not publicly identify you without permission and continues to handle personal information under the Privacy Policy.

17. Disclaimers and no professional advice

Read this section carefully Risk Information is an estimate, not proof. GuardRail is designed to support conversation and earlier awareness, not to replace personal judgment, professional care, financial controls, or emergency assistance.

TO THE FULLEST EXTENT PERMITTED BY LAW, THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE." GUARDRAIL DOES NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, COMPLETE, SECURE, ACCURATE, OR AVAILABLE AT ANY PARTICULAR TIME; THAT EVERY TRANSACTION WILL BE RECEIVED OR CORRECTLY CLASSIFIED; THAT ALL REQUESTED HISTORICAL INFORMATION WILL BE AVAILABLE; THAT EVERY ALERT WILL BE DELIVERED; THAT A TRANSACTION WILL BE CORRECTLY ATTRIBUTED TO A PERSON; OR THAT GAMBLING HARM WILL BE IDENTIFIED, PREVENTED, OR REDUCED. Any initial baseline or historical assessment is limited to the Connected Account data GuardRail actually receives. It may omit other accounts, cash activity, payment-app activity, or unavailable periods and does not establish a diagnosis, complete financial history, or current level of gambling harm. GuardRail does not provide medical, mental-health, addiction-treatment, legal, tax, accounting, investment, credit, or other professional advice. A Green status does not prove that no gambling occurred. A Red status does not prove that a person has a gambling disorder or committed wrongdoing. Recommended actions are general prompts and do not replace professional judgment. GuardRail is not an emergency service and does not monitor for self-harm, violence, medical emergencies, or immediate danger. In an emergency or immediate danger, contact local emergency services or an appropriate qualified professional rather than relying on GuardRail.

18. Limitation of liability

TO THE FULLEST EXTENT PERMITTED BY LAW, GUARDRAIL AND ITS OPERATORS, AFFILIATES, PERSONNEL, CONTRACTORS, LICENSORS, AND SERVICE PROVIDERS WILL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OPPORTUNITY, OR SAVINGS, ARISING FROM OR RELATED TO THE SERVICE, EVEN IF ADVISED OF THE POSSIBILITY OF THOSE DAMAGES. TO THE FULLEST EXTENT PERMITTED BY LAW, GUARDRAIL'S TOTAL LIABILITY FOR ALL CLAIMS ARISING FROM OR RELATED TO THE SERVICE WILL NOT EXCEED THE GREATER OF (A) THE AMOUNT THE ADULT PURCHASER PAID TO GUARDRAIL FOR THE SERVICE DURING THE 12 MONTHS BEFORE THE EVENT GIVING RISE TO THE CLAIM OR (B) $100. THESE LIMITATIONS DO NOT APPLY TO LIABILITY THAT CANNOT LEGALLY BE LIMITED, INCLUDING ANY RIGHTS THAT APPLICABLE CONSUMER LAW DOES NOT PERMIT A PERSON TO WAIVE.

19. Indemnification

To the fullest extent permitted by law, each adult agrees to defend, indemnify, and hold harmless GuardRail and its operators, affiliates, personnel, contractors, licensors, and service providers from third-party claims, losses, liabilities, costs, and reasonable attorneys' fees arising from that adult's unlawful or unauthorized use of the Service, breach of these Terms, violation of another person's rights, unauthorized financial-account connection, false representation of authority, or misuse or unlawful disclosure of Risk Information. This provision does not require a consumer to indemnify GuardRail for GuardRail's own unlawful conduct where prohibited by law.

20. Suspension and termination

GuardRail may restrict, suspend, or terminate an account, role, invitation, relationship, financial connection, or feature when reasonably necessary to address suspected fraud, unauthorized access, inaccurate age or authority information, participant abuse, security risk, nonpayment, legal or contractual requirements, a Quiltt or financial-institution direction, or a material breach of these Terms. GuardRail may act immediately where reasonably necessary to protect participants, data, GuardRail, Quiltt, a financial institution, or the Service. An adult may stop using the Service, cancel a subscription, end an accountability relationship, disconnect a Connected Account, or request deletion through the available controls. A Minor Participant may stop monitoring associated with the Minor Participant profile as described in Section 6.4. Sections that by their nature should survive termination - including ownership, previously delivered information, disclaimers, liability limits, indemnification, dispute resolution, and lawful retention - survive termination.

21. Dispute resolution and class-action waiver

Counsel review required - not final for publication The following is a proposed consumer dispute framework. Qualified counsel must confirm the governing law, arbitration provider and rules, fee allocation, opt-out method, treatment of claims involving a Minor Participant, public-injunctive-relief exceptions, and state-specific requirements before publication.

21.1 Informal resolution

Before filing a lawsuit or arbitration, the party raising a dispute must send an individual written notice describing the facts, legal basis, requested relief, and relevant adult account contact information to [LEGAL NOTICE EMAIL / MAILING ADDRESS]. The parties will attempt in good faith to resolve the dispute for at least 30 days after a complete notice is received. Either party may seek temporary relief when reasonably necessary to prevent immediate harm or unauthorized access.

21.2 Individual arbitration

Except for disputes eligible for small claims court, requests for public injunctive relief that cannot lawfully be arbitrated, and claims concerning intellectual-property ownership or unauthorized access, disputes arising from or relating to the Service or these Terms will be resolved by binding individual arbitration administered by the American Arbitration Association under its applicable Consumer Arbitration Rules, to the extent enforceable. Arbitration uses a neutral arbitrator instead of a judge or jury, and court review is limited.

21.3 Class-action waiver

To the fullest extent permitted by law, disputes must be brought only in an individual capacity and not as a class, collective, consolidated, mass, or representative action. If this waiver is unenforceable for a particular claim or remedy, that claim or remedy will proceed only in the forum and manner required by law.

21.4 Thirty-day arbitration opt-out

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