Finance90 Terms of Service

These Terms of Service (the “Terms”) govern the provision of Finance90 by SAPIENSQ, Inc., a Delaware corporation (“SAPIENSQ”, “we”, “us”), to the person or entity using it (“you”).

“Finance90” or the “Service” means the Finance90 Financial Simulator at finance90.ai, its applications, interfaces, reports and documentation, and the FOMC simulation pages published at sapiensq.com/fomc.

These Terms replace, for Finance90, the SAPIENSQ Terms of Service published at sapiensq.com/terms, which no longer govern Finance90.

You accept these Terms by selecting the acceptance control during registration, purchasing a Plan or using the Service. If you do not accept them, you must not use the Service.

If you accept these Terms on behalf of an entity, you represent that you have authority to bind that entity. In that case, “you” means that entity and each authorised person using its Workspace.

A signed agreement, order form or other written agreement between the parties prevails over these Terms to the extent of any conflict. These Terms govern matters that the signed agreement or order form does not address.

The version in force is stated at the beginning of these Terms. We may record the version accepted, the time of acceptance and technical information reasonably necessary to evidence acceptance and protect the Service.

In these Terms:

• “Workspace” means the account created for you on the Service, including its authorised users, stored material and activity records.
• “Run” means one complete simulated meeting; “Experiment” means a set of Runs of one configuration launched together; and “Published Forecast” means the Experiment we publish for an upcoming meeting.
• “Output” means material generated by the Service for you, including distributions, committee splits, simulated deliberations, transcripts, reports and scores.
• “Customer Material” means any material you submit or supply to the Service, including documents, scenarios, positions, prompts, configurations and messages.
• “Plan” means the subscription or access tier applying to your Workspace.
• “Credits” means the units consumed when a chargeable operation is launched.
• “Documentation” means the methodology, product documentation, validation material and definitions published or linked by the Service.
• “Consumer” means an individual acting wholly or mainly outside that individual’s trade, business, profession or other commercial activity.
• “Privacy Policy” means the privacy policy published at sapiensq.com/privacy.

You must be at least 18 years old and have legal capacity to enter into these Terms. The Service is not directed to children.

Registration information must be accurate and kept current. You must use an email address that you control. We may refuse, suspend or close a Workspace registered using materially inaccurate information.

Access is licensed by seat in the number permitted by your Plan. Credentials are personal to the authorised user and must not be shared or transferred. An invitation link or similar access token is personal in the same way.

You are responsible for activity under your Workspace to the extent reasonably within your control, and must notify us without undue delay if you suspect unauthorised access.

Where an organisation provisions Workspaces for its members, that organisation is responsible for who it admits, for the roles it grants them and for the lawfulness of the access it arranges.

We may request reasonable evidence that you meet the eligibility requirements for a Plan, including that an institutional Plan is used by the institution it names.

We may decline a registration or limit self-service registration where reasonably necessary for legal, security, capacity or business reasons.

You may not use the Service where doing so would violate applicable sanctions, export-control or trade-control laws. You must not export, re-export or otherwise make the Service or Output available in violation of applicable law.

Finance90 is a research and analytical tool built on simulation. It simulates deliberation by modelled Federal Open Market Committee participants and reports distributions, committee splits, deliberation records and scores over a stated number of Runs.

A modelled participant is a simulation. Nothing attributed to one is a statement by the corresponding real person, and nothing produced by the Service is a factual account of what a real person, committee or institution has said, decided or would decide.

The Service does not provide:

• investment, financial, tax or accounting advice;
• a personal recommendation concerning any financial instrument;
• advice on buying, selling, subscribing for, exchanging, redeeming, holding or underwriting a financial instrument;
• a recommendation concerning an investment strategy, allocation, position, duration or hedge;
• an assessment of your financial circumstances, investment objectives, knowledge, experience or tolerance for risk; or
• legal advice or a legal conclusion.

These are statements of what the Service does, not disclaimers of what it does. Output does not contain positioning or strategy language, and we do not offer to add it.

SAPIENSQ is not authorised or registered as an investment adviser, broker-dealer, investment firm or financial investment business. No advisory, fiduciary, professional or agency relationship arises solely from your use of the Service.

You remain responsible for decisions you take or do not take, and for obtaining professional advice where appropriate. You must not represent Output to a third party as personalised professional advice or as a statement of certainty.

Finance90 is not published by, endorsed by or affiliated with the Board of Governors of the Federal Reserve System, any Federal Reserve Bank, the Federal Open Market Committee, or any exchange, index provider, market-data vendor or statistical agency whose public record it models.

Features identified as beta, preview, pilot, experimental, research or similar are provided for evaluation, may change materially and may be withdrawn.

Finance90 is available to Consumers as well as to professional users. Nothing in these Terms limits a Consumer’s statutory rights, and the absence of a personal recommendation applies to every user equally.

A Published Forecast is produced on a common basis and is identical for every Workspace. Output produced in Scenario Lab is conditional on the macroeconomic or analytical premise supplied for the relevant Experiment, and is a statement about that premise rather than about you.

Book values positions you enter across the outcomes of a meeting. Every figure it shows is arithmetic on the numbers you enter, under the distribution you select; none of it is a view on what to do with a position.

Market-implied figures shown by Finance90 are calculated by us from publicly available information unless expressly identified otherwise. They are not the official output of any exchange, index provider, benchmark administrator or central bank, and must not be presented as such. Where a figure sourced from a public institution is displayed, it is attributed and it measures what that institution publishes, which may be a different quantity from the meeting-level figure shown beside it.

Each Output states the number of Runs, a 95% confidence interval and an evidence grade as defined in the Documentation. A share of Runs produced by Finance90 must not be distributed as a point estimate or as a probability of a real decision. Where you quote one, the number of Runs and the confidence interval must travel with it in the same sentence, table, caption or footnote.

Academic citation is permitted for non-commercial research and teaching, provided that you comply with the paragraph above, state the evidence grade, and include the report’s permanent identifier and a reference to the methodology. Commercial redistribution, including inclusion in paid research sold to your own clients, is governed by your Plan and by Output Rights and Attribution.

The Service uses artificial-intelligence models together with statistical and software-based methods. Users are informed within the Service that they are interacting with an artificial intelligence system, and AI-generated Output is identified as such in the interface or in the associated report metadata.

Output is a model-based estimate under the inputs, assumptions, methodology and information cutoff applicable to the Run that produced it. It does not state or guarantee what any real person or body will decide or do.

Each Run has an information cutoff. Information first published or supplied after that cutoff is not reflected in that Run unless expressly stated otherwise.

Output may contain errors, omissions, inconsistencies, bias or outdated information. You are responsible for reviewing and, where appropriate, independently verifying Output before relying on it, publishing it or distributing it.

Where Output is accompanied by a number of Runs, confidence interval, evidence grade or similar qualifier defined in the Documentation, you must not describe that Output with a degree of confidence the qualifier does not support. A result drawn from fewer than 20 Runs on one scenario shows a direction only.

Where required by law or reasonably necessary to avoid deception, you must disclose that material generated through the Service is AI-generated or simulated. You must not present Output as human-authored, as an authentic record of a real exchange, as official, or as verified or endorsed by a real person or institution, unless that is true and authorised.

You must not remove, obscure, alter or defeat an AI disclosure, provenance marking, machine-readable marker, watermark or methodology reference that the Service applies to Output, except to the extent applicable law expressly permits.

Output is not necessarily unique. Similar inputs or conditions may produce identical or materially similar Output for different users.

You retain your rights in Customer Material. You grant us a non-exclusive, worldwide, royalty-free licence to host, store, copy, transmit, display and process Customer Material only as reasonably necessary to provide, secure, maintain and support the Service for you.

We do not use Customer Material to train or fine-tune a model for the benefit of other customers unless you separately and expressly agree to that use, or the material has been aggregated or de-identified so that it no longer relates to an identifiable person or customer.

You must not submit:

• material that you do not have the right to provide, or whose processing by us in accordance with these Terms you have no lawful basis to authorise;
• personal data about another person, except where you have a lawful basis to provide it;
• special categories of personal data, health records, biometric data, government identifiers, payment-card numbers or financial account numbers;
• non-public material identifying portfolio positions, holdings, order flow, trading records or the investment situation of any other person;
• material licensed to you without the right to have it processed by a third-party service, or market data whose redistribution or derivative use is restricted by its provider;
• material subject to a confidentiality obligation owed to a third party that you are not authorised to disclose;
• unlawful, infringing, harassing or abusive material; or
• malicious code or material intended to compromise the Service.

You represent that you have the rights, permissions and lawful basis necessary for us to process Customer Material in accordance with these Terms.

Customer Material is processed only as an input to the Experiment or tool you direct it to. We do not use it to assess your personal circumstances or anyone’s investment situation.

We may block, remove or delete Customer Material that we reasonably believe violates these Terms or presents a legal, security or operational risk. Where appropriate and practicable, we will notify you.

You are responsible for maintaining your own copies of Customer Material. The Service is not a system of record or a backup service.

Subject to your compliance with these Terms and payment of Plan fees, we grant you a non-exclusive, worldwide licence to use Output for the business, research and educational purposes permitted by your Plan.

All rights in the Service, including its software, models, persona and corpus frameworks, methodologies, validation data, interfaces, Documentation, trademarks and logos, remain with us or our licensors. Except for the rights expressly granted in these Terms, no licence is granted and all rights are reserved.

When you externally distribute a quantitative figure derived from Output, you must provide sufficient nearby context for the recipient to understand its basis. Where the relevant report supplies them, that context must include:

• the number of Runs on which the figure is based;
• the applicable confidence interval;
• the evidence grade;
• the report’s permanent identifier; and
• attribution to Finance90.

This information may appear in the same sentence, table, figure caption, footnote or other reasonably proximate location.

Individual Plans (Observer, Light and Pro) license Output for your own use and for academic citation. Institutional Plans (Analyst, Desk and Institution) also license Output for deliverables provided to your named clients. Broader commercial redistribution, syndication, resale or the creation of a competing data product from Output requires our prior written consent.

Except where we expressly permit it in writing, you must not systematically use Output, Documentation or access to the Service to train or fine-tune a competing model, or to build a derived dataset offered to third parties. Nothing in this paragraph restricts a right that cannot lawfully be restricted.

We may use feedback and suggestions you voluntarily provide about the Service without restriction or payment, provided that doing so gives us no rights in your Customer Material or confidential information.

You must not:

• access the Service through unauthorised interfaces, or systematically scrape, crawl or harvest it;
• reverse engineer, decompile or disassemble protected elements of the Service, except to the extent applicable law expressly permits;
• circumvent Credits, Run limits, seat restrictions, upload limits, rate limits, tenancy boundaries or access controls, including by opening further Workspaces to obtain an offer again;
• resell, sublicense, rent, lease or provide unauthorised shared access to the Service;
• probe or test security vulnerabilities without our prior written permission;
• create, distribute or amplify fraud, scams, deceptive impersonation, market manipulation or harmful misinformation;
• use Output as the sole basis for a decision described in Nature of the Service; or
• use the Service in violation of applicable law or third-party rights.

We may apply reasonable technical limits, and may restrict activity that threatens the security, stability or integrity of the Service or materially interferes with its use by others.

You are responsible for compliance with the laws that apply to your use, including financial, securities, privacy, data-protection, consumer-protection, intellectual property, export-control and AI transparency laws.

Each Plan includes the Credits, seats, per-scenario Run ceiling and features stated on finance90.ai/pricing or in an applicable order form. Those limits may be enforced technically.

Every self-service Plan is a monthly subscription, billed in advance at the start of each monthly period, and renews automatically each month until you cancel it.

You may cancel at any time in Settings. Cancellation takes effect at the end of the current monthly period: you keep your Plan until then, and no further charge is made.

Moving to a higher Plan takes effect immediately. A new monthly period starts that day, and the price of the new Plan is reduced by the value of the monthly Credits you had not used on your previous Plan. Moving to a lower Plan takes effect at the next renewal.

One Run uses 100 Credits. Reading a document into a scenario uses 2 Credits per text page and 10 Credits per scanned page. Monthly Credits are granted at the start of each period and expire at its end. Credits bought in a credit pack do not expire while your Workspace exists. Credits have no cash value and are not transferable or redeemable. If a Run fails for a reason on our side, the Credits it held are returned.

Fees are those displayed when you purchase a Plan or stated in an applicable order form. Applicable taxes may be added where required by law.

We may change Plan pricing on at least 30 days’ notice. A price change applies from your next renewal after the notice period, and you may cancel before the new price applies.

For Plans purchased by invoice, payment is due within the period stated on the invoice or order form.

Payment-card transactions are processed by Stripe. We do not receive or store complete payment-card numbers.

Observer’s free first month. A Workspace that has never had a subscription may start Observer with a free first month of 30 days, once per person and once per Workspace.

• A payment method is required to start it.
• At the end of the free month the subscription converts to Observer at its then-current monthly price and renews monthly, unless you cancel before the free month ends.
• We send a reminder at least 7 days before the free month ends.
• Starting another Plan during the free month ends it.

Half-price first month. The first monthly invoice for Light or Pro is 50% off, once per Workspace on the individual Plans, and the first monthly invoice for Analyst, Desk or Institution is 50% off, once per Workspace on the institutional Plans. The discount does not apply to later months.

We may modify or withdraw these offers for the future. A change does not affect an offer already started.

Except as required by law or stated in an order form, we do not refund the unused part of a monthly period or Credits that have been consumed.

Nothing in these Terms limits a mandatory cancellation, withdrawal, refund or other right available to a Consumer under applicable law. In particular:

• a Consumer in the European Economic Area or the United Kingdom may withdraw within 14 days of the contract, and we treat a subscription to the Service as a digital service rather than as digital content;
• a Consumer in the Republic of Korea may withdraw within 7 days of the contract, as provided by the Act on the Consumer Protection in Electronic Commerce, subject to the exceptions that law provides.

Where you expressly request that we begin supplying the Service during the withdrawal period and you then withdraw, we may charge an amount proportionate to what was supplied up to the moment you told us, to the extent applicable law permits. To withdraw, write to finance90@sapiensq.com or cancel in Settings.

If you dispute a charge with your payment provider, we may refund it and close the subscription rather than contest the dispute, may temporarily suspend the affected paid features while it is investigated, and may decline future self-service purchases from an account with a history of disputes. This does not limit any right available to a Consumer under applicable law.

Unless an order form expressly provides otherwise, self-service Plans do not include a service-level commitment.

We may interrupt the Service for maintenance, security or operational reasons, and will use reasonable efforts to give advance notice of planned material interruptions.

We may add, modify or discontinue features. If a change materially reduces the core functionality of a paid Plan during a paid period, we will provide reasonable notice and, where appropriate, an opportunity to cancel and receive a refund for the affected unused paid period.

Interruptions attributable to third-party infrastructure, connectivity or model providers do not by themselves constitute a breach of these Terms, although we remain responsible for obligations that applicable law does not permit us to exclude.

You may cancel a subscription at any time, and may request closure of your Workspace.

When a subscription ends, the Workspace remains, with its members, Customer Material and history. The features that require a Plan are unavailable until a Plan is chosen again.

We may suspend access where reasonably necessary because of a material breach, overdue payment following notice, a legal or security risk, suspected misuse or a binding requirement from a competent authority. Where lawful and practicable we will notify you, and we will restore access when the reason for suspension has been resolved.

We may terminate these Terms where you materially breach them and fail to remedy a remediable breach within 14 days after notice. We may terminate immediately where a material breach cannot reasonably be remedied or where law requires it.

Following termination or Workspace closure, Customer Material and history may remain available for export for up to 30 days where technically and legally practicable. They will then be deleted, anonymised or retained only where required or permitted by applicable law or a separate agreement.

Provisions that by their nature should continue after termination, including those concerning intellectual property, confidentiality, personal data, warranties, liability, disputes and accrued payment obligations, survive termination.

Each party will use the other party’s confidential information only as necessary to perform or exercise rights under these Terms, protect it using reasonable safeguards, and disclose it only to personnel, professional advisers and contractors who have a legitimate need to know and appropriate confidentiality obligations. Customer Material and non-public configurations are your confidential information. Non-public technical, commercial and operational information concerning the Service is ours.

Confidentiality obligations do not apply to information that the receiving party can demonstrate:

• is public other than through breach of an obligation;
• was lawfully known without restriction;
• was independently developed without use of the confidential information; or
• was lawfully obtained from another source without a confidentiality obligation.

A disclosure required by law or by a competent authority is permitted. Where lawful and practicable, the receiving party will give advance notice.

The Privacy Policy describes how personal information is collected, used, disclosed and protected, and forms part of these Terms.

Where Customer Material contains personal data that we process on your behalf, the parties’ respective roles and obligations are determined by applicable data-protection law and, where applicable, by a data processing addendum, available to institutional customers on request.

We use service providers and sub-processors, including cloud infrastructure, database, email, payment and artificial-intelligence providers, subject to contractual and legal safeguards appropriate to the processing involved.

The Service is hosted in the United States and is developed and operated from the Republic of Korea by SAPIENSQ Inc., our service provider for the Service. It also relies on service providers located in other countries. International transfers of personal data are made only on a basis permitted by applicable law.

We do not sell personal data, and we do not use Customer Material for third-party advertising.

The Service may rely on, link to or interoperate with third-party services, infrastructure, identity providers, data sources or websites. We are not responsible for third-party content, policies, availability or practices, and your use of a third-party service may be governed by that provider’s own terms.

Where you connect a third-party account to a Workspace, such as a calendar, you authorise us to exchange with that provider the information necessary to operate the connection, and you remain responsible for your relationship with that provider.

We will provide the Service with reasonable skill and care and materially in accordance with the Documentation, subject to the limitations stated in these Terms.

Except for the express warranty above and rights that cannot lawfully be excluded, the Service and Output are provided on an “as is” and “as available” basis.

We do not warrant that:

• Output will be accurate, complete, unbiased or current;
• a simulation will correspond to an actual decision, vote, market price or other event;
• the Service will operate without interruption or error; or
• use of the Service will produce a particular commercial, research or investment result.

Nothing in these Terms excludes or limits a right or warranty that applicable law does not permit us to exclude or limit.

Nothing in these Terms excludes or limits liability for fraud, fraudulent misrepresentation, wilful misconduct, gross negligence, death or personal injury caused by negligence where such liability cannot lawfully be excluded, or any other liability that cannot lawfully be limited or excluded.

If you are not a Consumer, and subject to the first paragraph of this section, neither party is liable for indirect or consequential loss, or for loss of profit, anticipated savings, revenue, business opportunity, data or goodwill, except to the extent expressly provided in an applicable order form.

If you are not a Consumer, and subject to the first paragraph of this section, we are not liable for trading, investment, hedging or funding losses, or for losses resulting from a decision taken or not taken in reliance on Output.

If you are not a Consumer, and subject to the first paragraph of this section, our total aggregate liability arising out of or in connection with these Terms is limited to the greater of:

• the fees paid or payable to us for the Service during the twelve months preceding the event giving rise to the claim; and
• USD 100.

A different cap may be specified in an applicable order form.

If you are a Consumer, the limitations in this section apply only to the extent permitted by mandatory law, and your statutory rights remain unaffected.

If you use the Service in the course of a business, you will indemnify us against third-party claims, losses and reasonable external costs arising from:

• Customer Material that infringes a third party’s rights or was unlawfully supplied by you;
• your material breach of these Terms;
• your unlawful distribution or material misrepresentation of Output; or
• your unlawful use of the Service,

in each case to the extent caused by your act or omission.

We will notify you without undue delay of an indemnified third-party claim, allow you reasonable control of the defence where appropriate, provide reasonable assistance at your cost, and not agree to a settlement imposing a non-monetary obligation on you without your consent.

This section does not impose a contractual indemnity obligation on a Consumer except to the extent expressly permitted by applicable mandatory law.

We may amend these Terms where reasonably necessary to reflect changes in the Service, our business, security requirements or applicable law.

A material amendment that adversely affects existing paid users takes effect no earlier than 30 days after notice by email or through the Service, unless earlier implementation is required by law, by security circumstances or by a competent authority. Other amendments may take effect on publication where permitted by law.

You may terminate an affected paid Plan before a materially adverse amendment takes effect and receive any refund required by these Terms or applicable law. Continued use after an amendment takes effect constitutes acceptance to the extent permitted by applicable law.

These Terms and disputes arising from them are governed by the laws of the State of Delaware, United States, without regard to conflict-of-law principles. The United Nations Convention on Contracts for the International Sale of Goods does not apply.

Before commencing proceedings, each party will use reasonable efforts to notify the other of the dispute and to seek an amicable resolution for 30 days. This does not prevent either party from seeking urgent interim or injunctive relief.

For disputes between SAPIENSQ and users who are not Consumers, the state and federal courts located in the State of Delaware have exclusive jurisdiction, unless an applicable order form provides otherwise.

If you are a Consumer, nothing in these Terms deprives you of a mandatory protection or jurisdictional right available under the law of the country where you live.

We may seek appropriate relief from any court of competent jurisdiction where reasonably necessary to protect intellectual property, confidential information or the security of the Service.

You may not assign these Terms without our written consent, except where applicable law provides otherwise. We may assign them to an affiliate, or in connection with a merger, reorganisation, financing or sale of the relevant business or assets, subject to applicable law.

We may use subcontractors and service providers to perform our obligations, and remain responsible for our contractual obligations to the extent provided by applicable law.

Neither party is liable for delay or failure caused by circumstances beyond its reasonable control. The affected party will use reasonable efforts to mitigate the effects and resume performance.

If any provision is invalid or unenforceable, it will be modified only to the minimum extent necessary or, if modification is not possible, severed. The remainder of these Terms remains in effect.

A delay or failure to enforce a provision does not waive that provision.

These Terms, together with the Privacy Policy, any applicable order form and any executed addendum, constitute the agreement between the parties concerning the Service and supersede prior communications on the same subject. Nothing in this paragraph limits liability for fraud or fraudulent misrepresentation.

Notices to you may be delivered to the email address associated with your Workspace or through the Service. Formal notices to us may be sent using the contact details under Company Information.

Nothing in these Terms creates a partnership, joint venture, employment, fiduciary or agency relationship between the parties.

These Terms may be made available in Korean and other languages. To the extent permitted by applicable law, the English version governs in the event of inconsistency.

Finance90 is supplied by SAPIENSQ, Inc., the party to these Terms.

• Legal name: SAPIENSQ, Inc.
• Place of incorporation: Delaware, United States
• Email: finance90@sapiensq.com

Finance90 is developed and operated by SAPIENSQ Inc. (주식회사 사피엔스큐), a company incorporated in the Republic of Korea, as SAPIENSQ, Inc.’s service provider.

Legal notices under these Terms and questions concerning the Service may be sent to the email address above.