Assets Flow

Terms of Service

Last Updated: August 6, 2026

HOUSE OF BRANDS NOTICE. These Terms cover two distinct products operated by the Company under separate brands and at separate domains: (i) the AssetsFlow portfolio tracker at assetsflow.work ("AssetsFlow"), and (ii) the Shield due-diligence information product at shield.assetsflow.work ("Shield"). By using either product, you agree to these Terms. Shield-specific Sections (3.4, 4.3, 4.4, 9, 10, 11.2, 12, 17.4, 18, 19.3, 20, 22, and 23) apply additionally to Shield users.

STATUS NOTICE — IN-HOUSE DRAFT FOR OUTSIDE-COUNSEL REVIEW. This is an in-house draft v3.0 prepared from the Shani review dated 2026-07-04 and the Shani V3.1 ruling dated 2026-08-06. Shield-specific clauses (FCRA Option B boundary, indemnification triggers, US arbitration, GDPR lawful basis, liability cap) require sign-off by outside counsel specializing in FCRA, US consumer-protection / arbitration law, EU data-protection law, and UK GDPR before being relied upon in commerce. Sections flagged [FOR COUNSEL REVIEW] are in-house best-efforts drafts that have not been reviewed by outside counsel.

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1. Acceptance of Terms

By accessing or using AssetsFlow, Shield, the Company's mobile applications, or any of the Company's websites (collectively, the "Service"), you ("User," "you," or "your") agree to be bound by these Terms of Service (these "Terms"). If you do not agree to these Terms, you may not use the Service.

The Service is operated by Assets Flow Ltd., a company registered in the State of Israel. These Terms constitute a legally binding agreement between you and the Company.

Acceptance mechanics differ by product surface:

• AssetsFlow users accept these Terms by creating an account or by continued use after a material change as described in Section 20.
• Shield paid-product purchasers (Quick Shield, Sponsor Shield, Structure Shield, World Shield) must affirmatively accept these Terms at Paddle checkout via clickwrap. Continued-use acceptance does not apply to one-time purchases.
• Shield Free Scan ("Rung 0") users must affirmatively accept these Terms before each scan. No account is required for the Free Scan, but the clickwrap acceptance is mandatory per scan.

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2. Definitions

In these Terms:

• "AssetsFlow" means the Company's portfolio tracker product at assetsflow.work, including project tracking, payment recording, currency exchange tools, and the I-SCAN source.
• "Shield" means the Company's due-diligence information product at shield.assetsflow.work, including the Free Scan ("Rung 0") and the paid Shield Reports (Quick Shield, Sponsor Shield, Structure Shield, World Shield).
• "Shield Report" means a written or displayed aggregation of sourced public-record data delivered by Shield to a purchaser. A Shield Report is a compilation of public-record citations, not a consumer report, not a recommendation, and not an opinion.
• "Free Scan" or "Rung 0" means the free Shield product described in Section 4.3.
• "Information-Only" means a product architecture in which Shield presents sourced public-record data without recommendations, risk grades, scores, classifications, suitability assessments, advice, or opinions of any kind. Every datum in a Shield Report or Free Scan result links to a public source URL.
• "Public Records" means records published by a public authority (for example: the United States Securities and Exchange Commission EDGAR database, CourtListener federal court records, OFAC sanctions lists, the United Kingdom Companies House registry, the United Kingdom Insolvency Service, the London Gazette, the United Kingdom Financial Conduct Authority warnings list, state corporate registries, IOSCO and member-regulator public warnings, and other sources listed on the Methodology Page).
• "Director Network Data" means names, roles, and other publicly-filed identifiers of officers, directors, principals, or authorized persons of a sponsor entity, as published in Public Records.
• "Paddle" means Paddle.com Market Limited, the Merchant of Record for Shield purchases as described in Section 8.
• "Methodology Page" means the public web page at https://shield.assetsflow.work/methodology that lists every Public Record source Shield checks, the known gaps, and the limitations. The Methodology Page is incorporated into these Terms by reference.
• "Content" means any data, information, projects, or materials you upload to AssetsFlow.
• "User" means any individual or entity who accesses or uses the Service.
• "Premium Features" means paid features or subscriptions offered through AssetsFlow.

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3. Eligibility and Permitted Use

3.1 Age Requirements

• You must be at least 18 years old (or the age of majority in your jurisdiction) to use the Service.
• Users between 16 and 18 may use AssetsFlow only with parental consent.
• The Service is not intended for children under 16.
• The age requirement applies to Shield Free Scan users identically to paid Shield Report purchasers.

3.2 Account Requirements

• You must provide accurate and complete registration information where an account is created.
• You are responsible for maintaining the confidentiality of your account credentials.
• You may not create multiple accounts to circumvent restrictions.
• One account per individual or business entity.

3.3 Restricted Users

You may NOT use the Service if you:

• Are located in a country subject to Israeli, United States, United Kingdom, or international sanctions;
• Are prohibited from using the Service under applicable law;
• Have been previously banned from the Service.

3.4 FCRA Permissible-Purpose Prohibition — Shield [FOR COUNSEL REVIEW]

This Section 3.4 applies to all Shield users (Free Scan and paid Reports).

You agree that you will not use Shield Reports, Free Scan results, Director Network Data, or any data derived from Shield for:

• (a) Employment, promotion, suspension, or termination decisions about any individual;
• (b) Tenant, residential, or housing screening of any individual;
• (c) Credit, insurance, or underwriting decisions;
• (d) Any purpose covered by the Fair Credit Reporting Act of the United States (FCRA), 15 U.S.C. § 1681 et seq., or by any equivalent consumer-reporting law of any state, federal, or international jurisdiction;
• (e) Stalking, harassment, intimidation, or vigilante research of any individual;
• (f) Any lawful or unlawful purpose that would treat Shield data as a "consumer report" under any applicable law.

A breach of this Section 3.4 is a material breach of these Terms and triggers the indemnification obligations in Section 18.

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4. Description of the Service

4.1 AssetsFlow — Portfolio Tracker

AssetsFlow is an information management product for tracking personal investment portfolios. AssetsFlow provides:

• Investment project tracking and management;
• Payment recording and financial planning tools;
• Company discovery and information services;
• Currency exchange rate comparisons (FX Calculator);
• Aggregation of regulatory warnings through the I-SCAN source.

4.2 Shield — Due-Diligence Information Product

Shield is a due-diligence information product that aggregates sourced Public Records about investment sponsors, principals, contracts, and related entities. Shield is described fully in Sections 4.3, 4.4, and 9.

4.3 Shield Product Catalog

Shield is offered in five product tiers, with current availability and per-tier source scope as published on the Shield Methodology Page. The Methodology Page is the canonical source-of-truth for which sources are live in each tier; in the event of any inconsistency between this Section and the Methodology Page, the Methodology Page prevails.

Information-Only architecture (all tiers): Shield examines Public Record sources and presents their contents without characterization. Higher tiers examine more sources and/or add analyst review; they do not produce characterizations, recommendations, or opinions about the sponsor. See §4.4 for the full Information-Only warranty.

Tier availability disclosure. Only Quick Shield (Tier 1) is currently live. Tiers 2–4 are described for planning purposes and are not yet available for purchase. Purchasers will not be charged for Tiers 2–4 until those tiers ship. If a higher-tier source is later added to Quick Shield, Quick Shield purchasers do not retroactively receive the expanded report. See §8.5 for the Process Guarantee that activates when Sponsor Shield ships.

Prices may change. Pricing-change notice rules are in Section 8.3.

4.4 Shield Is Information-Only — NOT a Consumer Report [FOR COUNSEL REVIEW]

This Section applies to all Shield products, including the Free Scan.

• Shield is NOT a "consumer reporting agency" as defined by the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq.
• Shield Reports and Free Scan results are NOT "consumer reports" as defined by 15 U.S.C. § 1681a(d).
• Shield does not assemble or evaluate information for the purpose of serving as a factor in establishing a consumer's eligibility for credit, insurance, employment, housing, government benefits, or any other transaction covered by the FCRA.
• Shield does not provide: (a) recommendations to invest, not invest, or divest; (b) risk grades, scores, or classifications; (c) suitability assessments for any sponsor, investment, or individual; (d) legal opinions, attorney-client advice, or attorney work product; (e) assertions that any sponsor, principal, or entity has committed misconduct, fraud, or any unlawful act.
• Every datum in a Shield Report or Free Scan result links to a public source URL. Shield presents that sourced data without characterization.
• Shield does not assert the truth of any datum. Shield links to the Public Record source, and you evaluate the source independently.
• If a datum cannot be sourced, it is not included. If a source URL becomes unavailable after publication, Shield will note the unavailability but will not remove the citation.

4.4.1 Tier-to-Tier Upsell Disclosure — Information-Only Tie-Back

When the Company markets a higher Shield tier as examining more sources than a lower tier, the marketing language is an "examines N sources" representation — a representation about the Company's search process across tiers, not about what the sources conclude. Every tier-to-tier comparison must tie back to this §4.4: Shield examines sources and presents their Public Record contents without characterization. Higher tiers examine more sources and/or add analyst review; they do not produce characterizations, recommendations, or opinions about the sponsor.

4.4.2 Principal-Identity Resolution — Scope and Limit

"Sponsor Shield" tier and above include principal-identity resolution: the Company identifies the named officers, directors, and registered agents of the sponsor entity as listed in Public Record entity filings (SEC EDGAR, state corporate registries, IAPD Form ADV Schedule A/B). Principal-identity resolution surfaces the affiliation between a named person and the sponsor entity (e.g., "Jane Doe is listed as CEO of Acme LLC"). It does not assess, characterize, or score the person's character, reputation, or conduct. Assessing a natural person's character or reputation would implicate FCRA prong-2 (character/reputation content) and is outside Shield's Information-Only architecture.

4.5 NOT Investment, Legal, Tax, or Financial Advice

Neither AssetsFlow nor Shield is:

• A registered investment advisor;
• A financial advisory service;
• A brokerage or trading platform;
• A bank or financial institution;
• A law firm or a substitute for an attorney;
• A consumer reporting agency under the FCRA.

Neither product provides personalized investment recommendations, suitability assessments, financial planning advice, tax advice, or legal advice. All information is provided for general informational purposes only.

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5. FCRA Notice — Cornerstone Option B Clause [FOR COUNSEL REVIEW]

This Section applies to all Shield users (Free Scan and paid Reports).

Shield is not a "consumer reporting agency" as defined by the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq., and Shield Reports and Free Scan results are not "consumer reports" as defined by 15 U.S.C. § 1681a(d). Shield does not assemble or evaluate information for the purpose of serving as a factor in establishing eligibility for credit, insurance, employment, housing, government benefits, or any other FCRA-covered transaction.

Shield is a due-diligence information product that aggregates sourced public-record data for investor-informative purposes. Any use of Shield data for FCRA-covered purposes is strictly prohibited under Sections 3.4 and 11.2 and constitutes a material breach of these Terms.

Nothing in these Terms limits any non-waivable statutory right you have under the FCRA or under any other consumer-protection law of your jurisdiction.

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6. User Accounts

6.1 Account Creation

• AssetsFlow accounts are created via email/password or Google authentication.
• Shield paid-product purchases do not require an account at checkout. Paddle handles checkout. An account is optional and may be created after purchase.
• The Shield Free Scan does not require an account.

6.2 Account Termination

By you (AssetsFlow users):

• You may close your AssetsFlow account at any time via the product settings.
• Upon closure: (i) Shield search history (the entity names you investigated) is deleted within 30 days; (ii) account-authentication data (email, uid) is deleted within 90 days; (iii) purchased Shield Report content and source URLs are retained per the Shield retention carve-out in §6.4.
• Some data may be retained as required by law.

By the Company:

• We may suspend or terminate your account for: violation of these Terms; fraudulent or illegal activity; abuse of the Service or other users; extended inactivity (12+ months) for AssetsFlow accounts.

6.3 Account Security

• Use a strong, unique password.
• Enable two-factor authentication where available.
• Do not share your credentials.
• Log out from shared or public devices.

6.4 Shield Retention, Cross-User Prohibition, and Deletion Workflow [FOR COUNSEL REVIEW]

6.4.1 Retention Schedule

For Shield Report purchasers, the Company retains:

• (a) The delivered Shield Report and its source URLs for the longer of: seven (7) years from delivery (not purchase), or the period required to defend potential defamation, FCRA, or consumer-protection claims under the applicable statutes of limitation in Israel, the United States, and the United Kingdom. If a defamation, FCRA, or consumer-protection claim is asserted, the retention clock for the relevant Report extends until final resolution of the claim plus the underlying limitations period;
• (b) The payment record for the period required by Israeli tax law (currently seven years);
• (c) Consent records (clickwrap acceptances, opt-ins, opt-outs) indefinitely (contract-formation proof);
• (d) Account-authentication data (email, uid) until 90 days after account closure;
• (e) Shield search history (entity names the customer investigated) until 30 days after account closure — the highest-sensitivity datum in the system.

Personal data not covered by these categories is deleted within 30 days (search history) or 90 days (other personal data) of account closure or purchase. Shield Reports themselves are public-record aggregations; they are not "personal data" of the purchaser for retention purposes.

6.4.2 Cross-User Prohibition — Confidentiality of Customer Data

Shield customer data is confidential. The Company does not share, sell, rent, or barter Shield customer identities, contact information, search history, or purchased Report contents with any third party, including: (a) the sponsors or entities investigated by Shield customers; (b) other Shield customers; (c) investment companies, financial advisors, syndicators, or solicitors; (d) marketing partners, ad networks, or data brokers; (e) affiliates or subsidiaries of the Company for cross-marketing purposes.

Shield customer data is retained solely for: (1) delivering the purchased Report to the purchasing customer; (2) the defense-retention purposes in §6.4.1 (Report content, source URLs, payment, consent); (3) the operational cache described in §6.4.3. No other use, derivative dataset, or aggregate analytics on Shield customer data is permitted.

6.4.3 Operational Cache — Public-Record Data (Not Customer Data)

The Company maintains an operational cache of Public Record query results (the shieldExternalCache store) so that a public-source query by one customer can be reused, where the source's terms permit, to serve the same query by another customer. The cache contains only Public Record data that the source's terms permit to cache and republish. The cache contains no Shield customer data — no customer identities, no search history, no "customer X searched entity Y" attribution. Cache entries are not attributable to any Shield customer. Cache TTL: 7 days default (varies per source; some sources override per their ToS).

6.4.4 Deletion Workflow

(a) Request intake. A deletion request is submitted via privacy@assetsflow.work with the requesting user's email and (where available) uid.

(b) Acknowledgment and clock. Within five (5) business days, the Company acknowledges the request in writing. The forty-five (45) day clock under CCPA §1798.105(d) / GDPR Art. 17(3) starts on the date of the user's request (not the acknowledgment date). The clock may be extended by an additional forty-five (45) days where reasonably necessary, with notice to the user within the initial 45-day window, as permitted by CCPA §1798.105(d)(2).

(c) At-collection notice (GDPR Art. 13/14). For users identified post-V3.1 deployment, the sign-up flow and clickwrap ToS acceptance already disclose the retention categories and bases in this §6.4. For users identified pre-V3.1, the deletion-request acknowledgment email (§6.4.4(d)) serves as the Art. 13/14 notice in respect of the retained categories.

(d) At-deletion notice. The acknowledgment email lists what will be deleted (search history, account-auth data) and what will be retained (delivered Reports, payment records, consent records) with the statutory basis for each retained category.

(e) Verification — Non-Reidentification Check. Within 30 days of completing a deletion request, the Company verifies that retained data (Reports, payment records) cannot be re-identified back to the requesting user. Verification mechanism: payment records are keyed by Paddle order ID (not by user email); delivered Reports are keyed by report ID (not by user email); the engineering trip-wire no-reidentification.spec.ts is the verification mechanism. If re-identification is possible, the Company takes additional steps (key rotation, anonymization) until re-identification is no longer possible, and documents the additional steps.

6.4.5 What Survives Deletion

The following survive a deletion request (with notice to the user under §6.4.4(d)): (i) delivered Shield Report content (for the §6.4.1(a) defense-retention period); (ii) payment records (for the §6.4.1(b) tax-retention period); (iii) consent records (indefinite, §6.4.1(c)); (iv) anonymized aggregate analytics that contain no Shield customer data (none currently collected — see §6.4.2 carve-back).

7. User Content and Data (AssetsFlow)

7.1 Data Ownership

• You retain ownership of your Content and investment data uploaded to AssetsFlow.
• By using AssetsFlow, you grant us a limited license to process your data as described in the Privacy Policy.
• You represent that you have the right to upload and share any Content you provide.

7.2 Data Classification

7.3 Data Backup

• You are responsible for maintaining backup copies of any Content you upload to AssetsFlow.
• We are not liable for any data loss affecting AssetsFlow Content.
• For Shield, the Company retains delivered Reports per Section 6.4.

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8. Payments, Subscriptions, and Paddle

8.1 Product Catalog

The Service offers paid products through:

• AssetsFlow Premium — recurring subscription (annual).
• Shield Quick Shield — one-time purchase.
• Shield Sponsor Shield — one-time purchase.
• Shield Structure Shield — one-time purchase.
• Shield World Shield — one-time purchase.

The Shield Free Scan (Rung 0) is free, permanently, with no expiration and no credit card required.

8.2 Paddle as Merchant of Record — Shield [FOR COUNSEL REVIEW]

For Shield purchases, Paddle.com Market Limited ("Paddle") is the Merchant of Record. Paddle is the legal seller of Shield products; Assets Flow Ltd. is the supplier of the digital goods.

• Payment is processed by Paddle under Paddle's terms and conditions, available at https://www.paddle.com/legal.
• Paddle handles all tax compliance (VAT, GST, sales tax), refunds within the cooling-off period, chargebacks, and consumer-protection rights.
• Your payment data is processed by Paddle under Paddle's privacy policy. AssetsFlow does not store your payment card details.
• Paddle's buyer terms (including the EU/UK 14-day cooling-off right) are incorporated into the purchase contract between you and Paddle.

8.3 Pricing

• All prices are displayed in USD. Local-currency conversion, if any, is handled by Paddle.
• Shield one-time prices may change at any time without notice. The price in effect at the moment of checkout governs the transaction.
• AssetsFlow Premium recurring subscription prices may change with 30 days' notice by email to existing paid subscribers. Continued use after the 30-day window constitutes acceptance of the new price.
• The 30-day notice does not apply to one-time Shield purchases.

8.4 Refund Policy

See the Cancellation and Refund Policy for full details. Summary:

• Shield one-time purchases: 14-day full refund window from delivery (Paddle consumer-protection standard, aligned with EU/UK cooling-off rights). After 14 days, no refund for one-time Shield Reports post-delivery (industry standard for due-diligence reports).
• AssetsFlow Premium annual subscription: 14-day full refund; pro-rata refund after 14 days for the unused portion of the subscription.
• Beta-tester transition (Premium → Free): see Section 8.6.

8.5 Shield Sponsor Shield — Process Guarantee and Covered Source Match Refund

This Section applies to Sponsor Shield (Tier 2, $247), Structure Shield (Tier 3, $347), and World Shield (Tier 4, $497) purchases only. It activates automatically on the public launch date of Sponsor Shield (the "Process Guarantee Effective Date"), as announced on the Shield Methodology Page. Prior to the Process Guarantee Effective Date, this §8.5 has no effect and no Shield product is sold under its terms. Purchasers of Quick Shield (Tier 1) are not covered by this §8.5; Quick Shield is sold under the general refund policy in §8.4.

8.5.1 The Process Guarantee

Within forty-eight (48) hours of a purchaser's cleared payment, the Company will initiate a search of each of the Public Record sources in the "covered floor list" published on the Methodology Page as of the date of purchase. As of the Process Guarantee Effective Date, the covered floor list consists of the following seven (7) sources:

1. U.S. Securities and Exchange Commission EDGAR;
2. U.S. Treasury Office of Foreign Assets Control (OFAC) sanctions lists;
3. U.S. Securities and Exchange Commission Investment Adviser Public Disclosure (IAPD) database;
4. U.S. International Trade Administration Consolidated Screening List (CSL);
5. Global Database of Events, Language, and Tone (GDELT), entity-mention index;
6. Programmable Search Engine (CSE) over the Company's curated domain list;
7. CourtListener RECAP docket index, entity-named parties.

The covered floor list may be expanded as additional sources go live; the Methodology Page is the canonical source-of-truth for which sources are in the floor list as of any date of purchase. Sources listed on the Methodology Page as "Soon" or otherwise not yet live are not part of the covered floor list.

The Process Guarantee is a commitment about the Company's search process — that each listed source is queried within the 48-hour window. It is not a commitment that every Public Record item that exists about the sponsor will be found. The Company does not warrant source completeness, source availability, surname-collision disambiguation, jurisdictional variant spellings, or matches in sources not on the above list.

8.5.2 Refund Trigger — Covered Source Match

A purchaser is entitled to a full refund of the Sponsor Shield, Structure Shield, or World Shield purchase price if all four of the following conditions are met:

(a) The purchaser identifies, in writing to service@assetsflow.work within ninety (90) days of Report delivery, a specific Public Record item that names the sponsor entity directly (not a principal, officer, director, or affiliated person);

(b) The identified item is located in one of the sources in the covered floor list (§8.5.1) as of the date of the Report's delivery;

(c) The identified item was publicly available and queryable through the source's public interface at the time of the Report's delivery;

(d) The identified item does not appear in the delivered Report, and the purchaser provides the source URL that supports each of (a) through (c).

Non-characterization. The Company makes no representation as to whether a Covered Source Match is "adverse," "material," "negative," or any other characterization. The refund is processed because the Company's search did not surface an item that the listed source contained — not because the item has any particular substantive character.

8.5.3 Statutory Cooling-Off Right Preserved

Nothing in this Section limits the purchaser's non-waivable statutory cooling-off right under EU/UK consumer-protection law (fourteen (14) days from purchase) or any other non-waivable consumer-protection right of the purchaser's jurisdiction.

8.5.4 Verification and Good Faith

The Company will verify each Covered Source Match claim in good faith by re-querying the identified source against the identified item. If the Company confirms that all four conditions in §8.5.2 are satisfied, the Company will process the refund via Paddle to the original payment method within fourteen (14) business days. Frivolous, bad-faith, or pattern-of-abuse refund claims may be contested under Paddle's chargeback and refund-dispute policy.

8.5.5 Relationship to §8.4 General Refund Policy

This Section 8.5 supplements, and does not replace, the general refund policy in §8.4. The §8.4 14-day cooling-off right applies to all Shield purchases; the §8.5 Covered Source Match refund is an additional contractual remedy available for 90 days from delivery specifically for Sponsor Shield, Structure Shield, and World Shield purchases.

8.6 Free Trials and the Free Scan (Rung 0)

• The Shield Free Scan (Rung 0) is a permanent free product, not a trial.
• No expiration, no credit card required, no login required.
• The Information-Only disclaimers in Sections 4.4 and 5 apply identically to the Free Scan.
• AssetsFlow may offer time-limited free trials of Premium Features at the Company's discretion. Trials convert to paid subscriptions unless cancelled before the trial ends. One free trial per user.

8.7 Beta-Tester Migration (Premium → Free)

Users who purchased AssetsFlow Premium subscriptions prior to the Shield launch date and whose accounts are being migrated to the Free tier as part of the Shield product pivot will receive:

• (a) Email notice of the migration at least 30 days before it takes effect;
• (b) A pro-rata refund of the unused portion of their subscription per Paddle's consumer-protection terms;
• (c) The right to cancel and receive a full refund if they do not agree to the migration, exercisable within 30 days of the migration notice;
• (d) Continued access to their AssetsFlow data after migration. Migration does not delete user data.

Affected users may contact service@assetsflow.work to exercise the cancellation right under (c).

8.8 Beta-Tester Acknowledgment

Beta testers who tested AssetsFlow Premium features prior to the Shield pivot acknowledge that their feedback, suggestions, and bug reports are licensed to the Company irrevocably and royalty-free under Section 12.5 (Feedback).

8.9 Subscription Tier Changes

If your AssetsFlow Premium subscription tier changes (upgrade, downgrade, or transition to Free), the change takes effect at the start of your next billing cycle. Refunds, if any, are governed by Section 8.4 and the Cancellation and Refund Policy.

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9. I-SCAN — Public-Record Aggregation Source

9.1 Service Description

I-SCAN is a public-record aggregation source that surfaces regulatory warnings from public databases, including:

• The International Organization of Securities Commissions (IOSCO) public alert database;
• Participating financial-regulator public warning lists;
• Other public warning lists published by government authorities.

I-SCAN aggregates these public warnings, presents them with source URLs, and does not assess, grade, score, classify, or recommend. I-SCAN is one of the sources surfaced inside Shield Reports. [SHANI REVIEW: I-SCAN/IOSCO currently unavailable at launch — see methodology page. Number of sources is dynamic; reference the methodology page for the current verified-source list rather than hardcoding a count here.]

9.2 DISCLAIMER — No Guarantee

By using a product that includes I-SCAN data, you acknowledge:

1. I-SCAN does not guarantee that any investment, sponsor, or entity is legitimate, safe, or suitable;
2. The absence of a regulatory warning does not mean that a sponsor is trustworthy or financially sound;
3. I-SCAN may not detect all adverse information about a sponsor;
4. Public regulatory databases may be incomplete, lagging, or outdated;
5. New adverse information may emerge that has not yet been flagged.

9.3 Your Responsibility

You are solely responsible for:

• Conducting independent due diligence from multiple sources;
• Verifying sponsor registration and legitimacy with primary regulators;
• Consulting licensed financial, legal, and tax advisors;
• Making informed decisions based on the totality of available information.

THE COMPANY IS NOT LIABLE for any losses resulting from reliance on I-SCAN data.

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10. Shield — Source-URL Discipline and Methodology

10.1 Source-URL Discipline

Every datum in a Shield Report or Free Scan result links to a public source URL. This is enforced in code and committed to in these Terms.

• If a datum cannot be sourced, it is not included.
• If a source URL becomes unavailable after publication, Shield notes the unavailability but does not remove the citation.
• Shield does not assert the truth of any datum; Shield links to the Public Record source, and you evaluate the source independently.

10.2 Methodology Page — Incorporated by Reference

Shield's methodology, including the full list of Public Record sources checked, the known gaps, and the limitations, is published at https://shield.assetsflow.work/methodology (the "Methodology Page") and is incorporated into these Terms by reference. Changes to the Methodology Page are material changes to these Terms under Section 20.

10.3 Disclaimers Specific to Shield [FOR COUNSEL REVIEW]

• (a) The Company does not warrant that the underlying Public Record sources are accurate, complete, or current. Each Public Record source has its own accuracy disclaimers; Shield passes through those disclaimers.
• (b) Shield checks multiple public-record sources. The current verified-source count and any temporarily-unavailable sources are disclosed on the Methodology Page. Coverage is not exhaustive. A sponsor may have adverse information in a source Shield does not check. [SHANI REVIEW: replaced hardcoded "17" with dynamic reference to methodology page. Confirm phrasing is sufficient for "no specific count" ToS posture.]
• (c) Public records may lag real-world events. A sponsor may have filed for bankruptcy yesterday; the public record may take days or weeks to reflect it.
• (d) Source availability fluctuates. Some Public Record sources may be temporarily unavailable, producing incomplete Shield results.
• (e) The bankruptcy chapter classifier (Chapter 7 / 11 / 13 of the United States Bankruptcy Code, UK administration, IL, and EU equivalents) and the director-matching algorithm are LLM-assisted classifications of public-record data, not legal determinations. They are derived classifications, not assertions by the Company.
• (f) Shield Reports have no legal, regulatory, or evidentiary status. They are pointers to Public Records, not legal opinions, investigative findings, or assertions of fact by the Company.

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10.4 Canada Coverage — Data Provenance [SHANI APPROVED WORDING 2026-08-19 — VERBATIM]

Canada coverage is derived from the Corporations Canada open-data bulk records, licensed under the Open Government Licence – Canada 2.0. Contains information licensed under the Open Government Licence – Canada. We maintain an internal search index built from these records; each report shows the index build date ("data as of"), and if the index is stale or unavailable the Canada check is reported as unresolved rather than clear. Coverage is limited to federal corporations; provincial/territorial and financial-sector corporations are excluded, so a "no match" is not an all-Canada clearance. AssetFlow is not affiliated with, and is not endorsed by, the Government of Canada.

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11. Prohibited Conduct

11.1 General Prohibitions

You agree NOT to:

• Use the Service for illegal purposes;
• Upload malicious code or content;
• Attempt to breach Service security;
• Access other users' data without authorization;
• Create automated bots or scrapers against the Service without permission;
• Impersonate other users or entities;
• Distribute spam or unsolicited communications;
• Violate any applicable laws or regulations;
• Circumvent access controls or usage limits;
• Use the Service to facilitate fraud.

11.2 Prohibited Uses of Shield [FOR COUNSEL REVIEW]

In addition to Section 3.4, you agree that you will not:

• (a) Redistribute, republish, or publicly post any Shield Report, Free Scan result, or derivative of them, in whole or in part, on any forum, social media platform, website, mailing list, or public channel;
• (b) Use Shield data as a consumer report for any FCRA-covered purpose, including employment, tenancy, credit, insurance, or underwriting decisions;
• (c) Use Shield to harass, stalk, intimidate, or threaten any individual named in or derivable from Shield data;
• (d) Use Shield data in any legal proceeding without independently verifying the underlying Public Record sources through their primary authorities;
• (e) Scrape, mirror, or systematically query the Shield website, the Methodology Page, or any Shield data feed;
• (f) Resell, sublicense, or white-label any Shield Report.

A breach of this Section 11.2 is a material breach of these Terms and triggers the indemnification obligations in Section 18.

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12. Intellectual Property

12.1 Service IP

The Service, including its software, code, algorithms, design, logos, branding, content, documentation, and databases, is the exclusive property of the Company and is protected by intellectual-property laws.

12.2 Shield Reports — Compilation Copyright

Shield Reports are compilations of Public Record data. The Company claims copyright in the selection, arrangement, annotation, and presentation of Shield Reports, not in the underlying Public Record facts, which remain the property of their respective public authorities.

12.3 House of Brands

The "AssetsFlow" name, logo, and product specifications, and the "Shield" name, logo, methodology page, and product specifications, are the exclusive property of Assets Flow Ltd.

12.4 User License

The Company grants you a limited, non-exclusive, non-transferable, non-sublicensable license to use the Service for its intended purposes, subject to these Terms.

12.5 Feedback

If you provide feedback, suggestions, or ideas about the Service, you grant the Company an irrevocable, royalty-free, worldwide license to use, modify, and implement such feedback.

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13. Disclaimers

13.1 "AS IS" Basis

THE SERVICE AND ALL OUTPUTS ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED.

13.2 No Warranties

We do NOT warrant that:

• The Service will be uninterrupted or error-free;
• All defects will be corrected;
• The Service is free of viruses or harmful components;
• The Service meets your specific requirements;
• Information provided is accurate, complete, or reliable.

13.3 Third-Party Content

The Service may contain links to third-party websites and databases. We are not responsible for third-party content, accuracy, or privacy practices.

13.4 Shield-Specific Disclaimers

See Section 10.3 for Shield-specific disclaimers about the accuracy, completeness, currency, and classification of underlying Public Records.

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14. Lead Sharing and Referrals — AssetsFlow Only

14.1 Lead Sharing Program

With your explicit opt-in consent, the Company may share your contact information (name and email only) with investment companies, property developers, or financial service providers.

14.2 Consent Requirements

Lead sharing under Section 14.1 occurs ONLY when you:

• Explicitly opt-in to receive partner communications;
• Express interest in a specific investment opportunity;
• Use the AssetsFlow referral or sharing features;
• Submit a project for public listing.

14.3 Partner Obligations

Partner companies are contractually obligated to:

• Use shared information only for legitimate business outreach;
• Comply with applicable privacy laws;
• Provide opt-out mechanisms in communications;
• Not resell or transfer your information.

14.4 Opt-Out

You may opt-out of AssetsFlow lead sharing at any time via product settings, by email to service@assetsflow.work, or via unsubscribe links in partner communications.

14.5 SHIELD CARVE-OUT — NO LEAD SHARING FOR SHIELD CUSTOMERS

Lead sharing under this Section 14 does NOT apply to Shield customers. The Company does not share Shield customer identities, contact information, search history, or purchase history with any third party, including the sponsors they investigate, investment companies, financial service providers, or any marketing partner.

Shield customer data is retained solely for: (a) delivering the purchased Report; (b) the legal-defense retention under Section 6.4; (c) aggregate, anonymized analytics that do not identify the customer.

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15. FX Calculator

15.1 Informational Purpose

The AssetsFlow FX Calculator provides estimated currency exchange rates, transfer-fee comparisons, and cost estimates between financial institutions.

15.2 DISCLAIMER — Estimates Only

All FX Calculator information:

• May change without notice;
• May not reflect actual transaction costs;
• Is provided as estimates only;
• Does not constitute financial advice.

15.3 Verification Required

Before any transaction, you MUST verify current rates, all terms and conditions, and the complete fee structure with the relevant financial institution. THE COMPANY IS NOT LIABLE for any losses based on FX Calculator estimates.

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16. Privacy and Data Processing

16.1 Privacy Policy

The Company's Privacy Policy (at https://assetsflow.work/privacy) describes how the Company handles personal data. The Privacy Policy is incorporated into these Terms by reference.

16.2 GDPR Lawful Basis — Director Network Data [FOR COUNSEL REVIEW — DPA-LEVEL]

For Director Network Data processed by Shield, the Company's lawful basis under Article 6(1)(f) of the UK GDPR and EU GDPR is legitimate interest: the Company has a legitimate interest in providing investor-informative due-diligence information based on Public Records.

• The Company has conducted a legitimate-interest balancing test weighing (i) the user's interest in due-diligence information, (ii) the data subject's interest in their Public Record data being presented in context, and (iii) the data subject's reasonable expectations.
• Director Network Data is sourced exclusively from Public Records (e.g., SEC EDGAR, Companies House, state corporate registries).
• Director Network Data is not special category data under Article 9 GDPR. If special category data is inadvertently surfaced, the Company will remove it on notice.

16.3 Cross-Border Transfer [FOR COUNSEL REVIEW]

Personal data may be transferred between Israel, the United States, the United Kingdom, and the European Economic Area. The transfer mechanisms are:

• EU/UK → Israel: Israel was recognized as adequate by the European Commission in 2023 and by the UK Government. The Company relies on this adequacy decision for EU/UK → Israel transfers.
• Israel → United States: the Company relies on Standard Contractual Clauses or other lawful transfer mechanisms for any transfer that is not covered by an adequacy decision.

16.4 Data Subject Rights

If you are a sponsor, director, officer, principal, or other individual named in a Shield Report, you have the right to:

• (a) Request access to the personal data the Company has processed about you;
• (b) Request rectification of inaccurate data — note that the Company mirrors Public Records; rectification requests must be directed to the underlying public authority (e.g., SEC, CourtListener, Companies House) before the Company can mirror the corrected data;
• (c) Object to processing under GDPR Article 21 — the Company will consider objections but may continue processing based on legitimate interest;
• (d) Request erasure of your personal data from the Company's database — note that the Company does not delete underlying Public Records, only its mirror of them; the public authority's record remains the canonical source;
• (e) Lodge a complaint with the competent supervisory authority.

Direct requests to privacy@assetsflow.work. The Company will respond within 30 days.

16.5 Israeli Database Registration

The Company is in the process of registering its database with the Israeli Privacy Protection Authority per the Israeli Privacy Protection Law 5741-1981 and the Database Law. The registration status is published on the Company's privacy page when finalized.

16.6 US State Privacy Rights

For US residents, the Company provides notice at collection, the right to know, the right to delete, and the right to opt out of sale. The Company does not sell personal data. California Consumer Privacy Act (CCPA/CPRA), Virginia VCDPA, Colorado CPA, and equivalent state-law rights apply as set forth in the Privacy Policy.

16.7 Retention Period for Director Network Data

Director Network Data is retained linked to the source's retention — mirrored only while the public source hosts it. If a public authority removes the underlying record, the Company updates its mirror accordingly.

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17. Limitation of Liability

17.1 General Liability Cap [FOR COUNSEL REVIEW — DRAFTED IN-HOUSE, REQUIRES US/IL/UK CONSUMER-PROTECTION REVIEW]

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE COMPANY, ITS OWNERS, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, AND AFFILIATES SHALL NOT BE LIABLE FOR:

• Indirect, incidental, special, consequential, or punitive damages;
• Loss of profits, revenue, or business opportunities;
• Loss of data or business interruption;
• Investment losses or financial damages;
• Damages from fraud, scams, or third-party misconduct;
• Damages from reliance on Service information.

17.2 Cap Amount — Recurring Subscriptions (AssetsFlow)

If liability is found for an AssetsFlow recurring subscription, the Company's total liability shall not exceed the greater of:

• The amount you paid the Company in the 12 months preceding the claim; or
• USD $100.

17.3 Cap Amount — One-Time Shield Purchases [FOR COUNSEL REVIEW]

For one-time Shield Report purchases, the Company's total liability shall not exceed the greater of:

• The amount you paid the Company for the specific Shield Report that is the subject of the claim; or
• USD $500.

This higher floor reflects the Company's good-faith recognition that a $247–$497 due-diligence product carries a different risk profile than a recurring subscription, and provides courts in Israel, the United States, and the United Kingdom with a more enforceable number than the legacy $100 cap.

17.4 Reasonable Reliance Covenant

You acknowledge that Shield is one input among many in a due-diligence process. No investment, divestment, or financial decision should be based solely on a Shield Report. You are responsible for combining Shield data with independent verification, professional advice, and your own judgment.

17.5 Exceptions

This Section 17 does not apply to:

• Gross negligence or willful misconduct by the Company;
• Personal injury or death caused by the Company's negligence;
• Fraud or fraudulent misrepresentation;
• Any liability that cannot be excluded or limited under applicable law (including non-waivable statutory consumer-protection rights in Israel, the EU, the UK, and US states where you reside).

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18. Indemnification

18.1 General Indemnification

You agree to indemnify and hold harmless the Company, its owners, directors, officers, employees, and agents from any claims, damages, losses, or expenses (including reasonable legal fees) arising from:

• Your use of the Service;
• Your violation of these Terms;
• Your violation of any third-party rights;
• Content you upload or share;
• Your investment decisions.

18.2 Shield-Specific Indemnification Triggers [FOR COUNSEL REVIEW]

You agree to specifically indemnify and hold harmless the Company from any claims, damages, losses, or expenses (including reasonable legal fees) arising from:

• (a) Your redistribution, republication, or public posting of any Shield Report, Free Scan result, or derivative of them, in breach of Section 11.2;
• (b) Your use of Shield data for any FCRA-covered purpose, in breach of Sections 3.4 and 11.2;
• (c) Your reliance on Shield data for any investment, divestment, or financial decision, contrary to the reasonable-reliance covenant in Section 17.4;
• (d) Your use of Shield to harass, stalk, or intimidate any individual;
• (e) Your use of Shield data in legal proceedings without independent verification of the underlying Public Record sources;
• (f) Your scraping, mirroring, or systematic querying of the Shield website or data feed.

18.3 Notice and Defense

The Company will give you prompt written notice of any claim for which indemnification is sought, will permit you to control the defense (subject to the Company's right to participate with its own counsel at its own expense), and will reasonably cooperate in the defense. The Company will not settle any claim that imposes a non-indemnified obligation on you without your consent.

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19. Dispute Resolution

19.1 Governing Law — Israel (Primary)

These Terms shall be governed by and construed in accordance with the laws of the State of Israel, without regard to conflict-of-law principles.

19.2 Jurisdiction — Israel (Primary)

Subject to Sections 19.3, 19.4, and 19.5, any dispute shall be resolved exclusively in the courts of Tel Aviv, Israel, and you consent to the personal jurisdiction of such courts.

19.3 Jurisdictional Carve-Out — United States Shield Customers [FOR COUNSEL REVIEW]

For Shield customers located in the United States:

• (a) FCRA claims, if any are brought, are heard in United States federal court as provided by the FCRA. Nothing in these Terms purports to override US federal jurisdiction over FCRA claims.
• (b) State consumer-protection laws in your state of residence may provide rights that cannot be waived by this choice-of-law clause. California, New York, and other states have strong public-policy exceptions to choice-of-law clauses in consumer contracts.
• (c) Nothing in these Terms limits any non-waivable statutory consumer right you have under the laws of your jurisdiction.

19.4 Jurisdictional Carve-Out — United Kingdom Shield Customers [FOR COUNSEL REVIEW]

For Shield customers located in the United Kingdom:

• (a) UK consumer-protection law (including the Consumer Rights Act 2015) applies to any transaction that qualifies as a consumer transaction.
• (b) UK GDPR and the Data Protection Act 2018 govern any processing of personal data of UK data subjects.
• (c) Nothing in these Terms limits any non-waivable statutory consumer right you have under UK law.

19.5 Class-Action Waiver and Arbitration — US Shield Customers [FOR COUNSEL REVIEW — REQUIRES US CONSUMER-PROTECTION / ARBITRATION COUNSEL]

For Shield customers in the United States, any dispute will be resolved by binding individual arbitration administered by the American Arbitration Association (AAA) or JAMS, in the customer's state of residence, under the chosen organization's consumer arbitration rules then in effect.

• Class arbitration is waived. The arbitrator may not consolidate more than one person's claims.
• The Company will pay the arbitration fees for claims under USD $10,000 to ensure enforceability, subject to the arbitrator's authority to allocate fees under applicable rules.
• This Section 19.5 does not apply to claims that cannot be subject to arbitration as a matter of law (including small-claims court actions within the jurisdictional limit, and certain statutory consumer-protection claims).
• Either party may opt out of this arbitration clause within 30 days of purchase by written notice to legal@assetsflow.work.

19.6 Israeli Class Actions

For Israeli customers, class actions are governed by the Israeli Class Actions Law 5766-2006. Nothing in these Terms waives any non-waivable right to participate in class actions under Israeli consumer-protection law.

19.7 Arbitration — General

For all other Shield disputes not covered by Section 19.5, either party may elect binding arbitration under the Israeli Arbitration Law 5728-1968. The election is mutual, not at the Company's sole discretion.

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20. Changes to These Terms

20.1 Modification Rights

The Company reserves the right to modify these Terms at any time. All modifications take effect as described in this Section 20.

20.2 Notice Periods

• Material changes affecting existing AssetsFlow paid subscribers will be notified at least 30 days before taking effect by email, in-product notification, and prominent notice on the Service.
• Beta-tester migration (Premium → Free) requires individual direct email notice at least 30 days before the migration.
• For one-time Shield purchasers, the ToS in effect at the time of purchase governs the transaction. Material changes do not retroactively apply to one-time purchases already completed.
• For Shield Free Scan users, the ToS must be affirmatively accepted at each scan; continued-use acceptance does not apply.

20.3 Acceptance Mechanics

• For AssetsFlow recurring subscribers: continued use of the Service after the 30-day notice window constitutes acceptance of the modified Terms. If you disagree, you may cancel your subscription and receive any refund owed under Section 8.4.
• For Shield paid purchases: affirmative clickwrap acceptance at Paddle checkout is required. Continued-use acceptance does not apply.
• For Shield Free Scan users: affirmative clickwrap acceptance before each scan is required.

20.4 Methodology Page Changes

Changes to the Shield Methodology Page (Section 10.2) are material changes to these Terms and follow the notice rules in Section 20.2.

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21. Force Majeure

The Company shall not be liable for any failure or delay in performance due to circumstances beyond its reasonable control, including: natural disasters; war, terrorism, or civil unrest; government actions or regulations; internet outages or cyber attacks; pandemics or public health emergencies; or outages of upstream Public Record sources on which Shield depends.

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22. Contact Information

Assets Flow Ltd. Israel

General customer service: service@assetsflow.work Shield customer service: service@assetsflow.work Defamation, correction, or takedown requests: legal@assetsflow.work Privacy, GDPR, right-to-erasure, and data subject requests: privacy@assetsflow.work Website: https://assetsflow.work Shield: https://shield.assetsflow.work

For EU/UK data subjects, the Company will designate an EU representative under GDPR Article 27 if and when Shield targets EU/UK customers. Until then, EU/UK data subjects may contact the Company directly at privacy@assetsflow.work.

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23. Miscellaneous

23.1 Severability

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect. The invalid provision will be modified to the minimum extent necessary to make it enforceable while preserving the parties' original intent.

23.2 Entire Agreement

These Terms, together with the Privacy Policy, the Cancellation and Refund Policy, and the Methodology Page, constitute the entire agreement between you and the Company regarding the Service.

23.3 Assignment

You may not assign these Terms without the Company's prior written consent. The Company may assign these Terms in connection with a merger, acquisition, or sale of all or substantially all of its assets.

23.4 No Waiver

No failure or delay by the Company in exercising any right under these Terms shall operate as a waiver of that right.

23.5 Headings and Construction

Section headings are for convenience only and do not affect interpretation. The words "include," "includes," and "including" are deemed to be followed by "without limitation."

23.6 Language

These Terms are drafted in English and translated into Hebrew for the convenience of Israeli customers. In the event of a conflict between the English and Hebrew versions, the English version governs, except where Israeli consumer-protection law requires the Hebrew version to govern. The Company takes active measures to maintain section-by-section parity between the two versions.

23.7 Acknowledgment

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

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Last Updated: August 19, 2026 Effective Date: August 19, 2026 Version: 3.2