The terms of using Carlo.

You must be at least 18 years old and capable of forming a binding contract to use the Service. By using Carlo, you represent that you meet these requirements.

You are responsible for maintaining the confidentiality of your account credentials and for all activity that occurs under your account. You agree to:

• Provide accurate and complete information when creating your account.
• Notify us promptly at support@carlo.finance if you suspect unauthorized access to your account.
• Not share your account credentials with any third party.

We reserve the right to suspend or terminate accounts that violate these Terms.

Carlo is a financial decision simulator and planning tool. It uses data you provide — including information from connected financial accounts — to run projections, model scenarios, and help you think through financial decisions.

Carlo is not a registered investment adviser, broker-dealer, or financial planner. Nothing in the Service constitutes a recommendation to buy, sell, or hold any financial instrument.

Carlo uses third-party large language models (“AI Models”) through Vercel AI Gateway, Carlo’s AI provider layer, to interpret natural-language requests, structure your inputs, and explain projection outputs. When you type a question, describe a goal, or ask Carlo to model a scenario, the relevant content of that request — which may include financial figures and goal text drawn from your profile or your connected accounts — is sent from Carlo’s servers to AI Gateway, which routes it to the selected AI Model for processing.

AI Models are tools used inside the Service. They do not provide financial advice, do not exercise judgment on your behalf, and their outputs are simulations governed by the same disclaimers as the rest of the Service. You are responsible for reviewing AI-generated outputs before relying on them.

Carlo configures every AI Gateway request with zero data retention enforcement. Under ZDR, Gateway and routed model infrastructure process prompts and outputs transiently for inference and do not retain them after the request. Carlo stores the product copy you see in your account according to its retention policy. For details on data retention and subprocessor disclosure, see our Privacy Policy and Data Retention Policy.

Carlo uses Plaid to connect to your financial accounts. When you connect an account:

• You authorize Plaid to access your account data on our behalf, including balances, transactions, and account details.
• You represent that you are authorized to connect the accounts you link.
• You can disconnect any account at any time through Carlo or directly through your financial institution.

Your use of Plaid is also subject to Plaid’s End User Services Agreement.

You agree not to:

• Use the Service for any unlawful purpose or in violation of any applicable laws or regulations.
• Attempt to gain unauthorized access to the Service, other accounts, or any systems or networks connected to the Service.
• Reverse engineer, decompile, or disassemble any part of the Service.
• Use automated means (bots, scrapers, crawlers) to access the Service without our written permission.
• Interfere with or disrupt the integrity or performance of the Service.
• Misrepresent your identity or impersonate any person.

The Service, including its design, text, graphics, interfaces, and underlying code, is owned by Carlo Finance and protected by intellectual property laws. You may not copy, modify, distribute, or create derivative works from any part of the Service without our written permission.

Your data remains yours. You retain all ownership rights to the financial data and personal information you provide to Carlo. We do not claim any ownership over your data. See our Privacy Policy for details on how we handle your data.

The Service is provided “as is” and “as available” without warranties of any kind, either express or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

Without limiting the foregoing, Carlo does not warrant that:

• The Service will be uninterrupted, timely, secure, or error-free.
• Projections, simulations, or scenarios will be accurate, complete, or reliable.
• Data received from connected financial accounts via Plaid will be accurate or current.
• AI-generated explanations, summaries, or suggestions will be accurate, complete, or appropriate to your situation.
• Any errors in the Service will be corrected.

You acknowledge that financial projections are inherently uncertain and that actual results may differ materially from any simulation.

AI-generated outputs may contain inaccurate, incomplete, or invented information (sometimes called “hallucinations”). They are not a substitute for review by you or a qualified professional.

To the maximum extent permitted by law, Carlo Finance and its officers, directors, employees, and agents shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits, revenue, data, or use, arising out of or related to your use of the Service, whether based on warranty, contract, tort (including negligence), or any other legal theory.

In no event shall our total liability to you for all claims arising out of or related to the Service exceed the amount you paid us in the twelve (12) months preceding the claim, or one hundred dollars ($100), whichever is greater.

Carlo is not liable for any financial decisions you make based on information provided by the Service, including any losses resulting from reliance on projections or simulations.

You agree to indemnify and hold harmless Carlo Finance and its officers, directors, employees, and agents from any claims, damages, losses, liabilities, and expenses (including reasonable attorneys’ fees) arising out of or related to your use of the Service, your violation of these Terms, or your violation of any rights of a third party.

You may stop using the Service and delete your account at any time. We may suspend or terminate your access to the Service at any time, with or without cause, and with or without notice.

Upon termination, your right to use the Service ceases immediately. Sections that by their nature should survive termination — including disclaimers, limitation of liability, indemnification, and governing law — will survive.

For details on what happens to your data when you delete your account, see our Privacy Policy and Data Retention Policy.

These Terms are governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law provisions.

Any dispute arising from these Terms or the Service shall first be attempted to be resolved through good-faith negotiation. If the dispute cannot be resolved within 30 days, either party may pursue binding arbitration administered by JAMS under its Streamlined Arbitration Rules. The arbitration shall take place in Delaware, and the arbitrator’s decision shall be final and binding.

You agree to resolve disputes on an individual basis. You waive any right to participate in a class action, class arbitration, or representative proceeding.

We may update these Terms from time to time. When we make material changes:

• We will update the “Last updated” date at the top of this page.
• We will notify you by email or through the Service at least 30 days before material changes take effect.
• Your continued use of the Service after changes become effective constitutes acceptance of the updated Terms.

If you have questions about these Terms: