Terms of Service — v1

Effective date: May 15, 2026 Provided by: 16Wells LLC

1. Acceptance of Terms

By accessing or using this compliance pre-screening service ("Service"), you agree to be bound by these Terms of Service on behalf of yourself and your firm. If you do not agree, do not use the Service.

Your acceptance is recorded with the date, time, IP address, and username at the moment you click "Accept." This record is retained permanently for legal and audit purposes.

2. Description of Service

The Service provides AI-assisted pre-screening of marketing materials against NFA, CFTC, FINRA, and SEC regulatory standards. It is designed to help compliance teams identify potential issues before materials are submitted to a registered principal for formal review.

3. Not Legal Advice — Not Principal Approval

THE SERVICE IS NOT LEGAL ADVICE. Output from this Service does not constitute legal advice, compliance advice, or a legal opinion of any kind.

THE SERVICE DOES NOT SUBSTITUTE FOR REGISTERED PRINCIPAL REVIEW. A pre-screen result — regardless of score — is not a formal approval of marketing material under NFA Compliance Rule 2-29(e), FINRA Rule 2210(b), or any other applicable regulatory rule. All marketing materials must still be reviewed and approved by your firm's designated supervisory personnel (registered principal) before use or dissemination, as required by applicable rules.

16Wells LLC makes no representation that any material reviewed by this Service complies with any regulatory requirement.

4. Authorized Use

You may use the Service only for your firm's internal compliance pre-screening purposes. You may not:

Use the Service for any illegal purpose or in violation of any regulation
Submit material belonging to another firm without that firm's authorization
Attempt to reverse-engineer, scrape, or otherwise extract the underlying AI models or prompts
Resell, sublicense, or provide access to the Service to third parties outside your firm

5. Data and Confidentiality

Your submitted materials: Marketing materials you submit for review are processed by AI models to generate the pre-screen output. Submitted content is retained for 12 months to support your firm's recordkeeping obligations, then deleted unless you have configured extended retention. 16Wells treats all submitted materials as confidential and does not use them to train AI models or share them with third parties.

Audit records: Workflow records (who submitted, who reviewed, who approved, with timestamps and IP addresses) are retained for a minimum of 3 years in support of regulatory recordkeeping requirements.

AI providers: The Service uses Anthropic's Claude API to process submissions. Anthropic's data handling policies apply to AI processing. We do not send identifiable firm information to Anthropic beyond what is necessary to perform the review.

6. Fees and Payment

Fees are charged as described on the pricing page at the time of your subscription or pay-per-review purchase. All fees are in USD. Subscriptions renew automatically until cancelled. You may cancel at any time; cancellation takes effect at the end of the current billing period.

7. Intellectual Property

The Service, including all software, prompts, workflows, and output formats, is owned by 16Wells LLC. Review outputs generated by the Service for your firm's submitted materials are yours to use for your firm's internal purposes.

8. Disclaimer of Warranties

THE SERVICE IS PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND. 16WELLS LLC DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE SERVICE WILL BE ERROR-FREE, UNINTERRUPTED, OR THAT AI-GENERATED FINDINGS WILL BE ACCURATE OR COMPLETE.

9. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, 16WELLS LLC SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICE. OUR TOTAL LIABILITY SHALL NOT EXCEED THE FEES YOU PAID IN THE TWELVE MONTHS PRECEDING THE CLAIM.

10. Governing Law

These Terms are governed by the laws of the State of [State], without regard to conflict of law principles.

11. Changes to Terms

We may update these Terms from time to time. When we make material changes, we will notify you and require your re-acceptance before you can continue using the Service. Your continued use after re-acceptance constitutes agreement to the updated Terms.

12. Contact

Questions about these Terms: skip@16wells.com

16Wells LLC 3250 Bonita Beach Road, Suite 205-309 Bonita Springs, FL 34134