# RevelFT — Consented Live Pilot Environment (CLPE)
## Participant Terms, Consent, and Release (Direct-to-Individual)

**Version:** Pilot v2.3
**Effective Date:** October 2, 2026
**Consent set:** `CONSENT_TEXT["v5-pilot"]` (9 checkboxes; see §17 and Appendix A).
**Model:** Direct-to-individual. Each participant is an individual who enrolls and consents for themselves. Results are shown only to that individual and, as described in the consent, to a small number of authorized RevelFT staff (read-only; every view recorded). **No partner organization and no third party receives any individual-level output.**

> These Terms have been prepared by RevelFT and have not been reviewed by outside counsel.

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## 1. About This Pilot

RevelFT, Inc. ("RevelFT," "we," "us") is developing **Stance**, a financial health intelligence platform. You ("you," "Participant") are invited to a **limited (fewer than 100 participants) design pilot** to help develop and validate the product using your own real financial data. This is an **experimental product-development pilot**, not a commercial financial service. Results are provided **to you, about you, for your own self-assessment.** Participation is voluntary.

## 2. What the Pilot Does

With your authorization, the Pilot accesses financial information about you from providers you connect (payroll and employment via Argyle; banking and investments via MX; credit-file information via Equifax under permissible use). RevelFT transforms this into a **proprietary financial representation** ("financial digital twin") and generates analytics, insights, and a **financial health score** from it. **These results are presented to you, and are visible read-only to authorized RevelFT staff as described in §13.**

**Updated results.** When you connect a new account, or when RevelFT improves how results are calculated, Stance may recalculate your earlier monthly results.

## 3. How Results Are Used — and Not Used

**We WILL:** show your score, analytics, and insights **to you** for self-assessment; let a small number of authorized RevelFT staff view your screens, read-only, to help you, fix problems, and check your results, with every view recorded; and use your data internally to develop and validate Stance.

**We WILL NOT, in this Pilot:** provide your score, insights, or any individual-level output **to any third party** (lender, employer, insurer, landlord, partner organization, or anyone else) for any eligibility, credit, underwriting, employment, insurance, tenant-screening, approval, or denial decision; make or facilitate any automated decision about you; provide third-party access through APIs, exports, portals, or reports; sell your personal information; or display raw provider reports or reuse a provider's score as our output. **Your financial health score is not used as a qualifying criterion for any product approval.** It is information for you.

## 4. Your Consent and Authorizations

You specifically authorize RevelFT to:

**(a)** access, through providers you connect, the financial data in §2 during your participation;

**(b)** process, normalize, validate, supplement, and transform that data into RevelFT's proprietary representation, and generate a score and analytics for your self-assessment and for RevelFT's product development;

**(c)** process your data using **AI-assisted development and engineering tools** under confidentiality and data-protection controls, including tools operated under commercial data-protection terms (for example, a Data Processing Agreement with zero data retention), in RevelFT's controlled environment;

**(d)** obtain and use **Equifax information through soft inquiries** (which do not affect your credit score) for as long as you remain enrolled: when you enroll, when you ask Stance to update your assessment, when Stance detects a change in your finances, and as needed to keep your assessment accurate and to confirm that Stance handles your information correctly. This is done under permissible use and your written instruction, as one input among many, without displaying Equifax reports or reusing Equifax scores;

**(e)** access, through **MX**, your connected **bank and investment account** data (including transaction-level data), limited to the minimum needed to generate your assessment; and

**(f)** access, through **Argyle**, your **payroll, employment, and income** data, limited to the minimum needed to generate your assessment.

Your consent is **informed, specific, voluntary, and revocable** (§12).

**Future or additional data sources.** RevelFT may, over time, add data sources to improve the assessment. **Before** any new source is used to retrieve or receive your data, RevelFT will **tell you about that specific source and obtain your separate, specific consent** for it. Your agreement here authorizes only that *process*. It does **not** authorize sharing your data with, or retrieving it from, any new source until you have given that separate consent.

## 5. What This Pilot Is Not

- **Not a consumer report; RevelFT is not a consumer reporting agency.** Results are a self-assessment tool shown to you (and to authorized RevelFT staff as described in §13) and are not furnished to third parties for decisions.
- **Not financial, legal, tax, investment, or credit-repair advice.**
- **Not a commercial product, and not a guarantee.** It is experimental; features may change, break, or end; results may be incomplete or inaccurate.
- **Not an eligibility, lending, or approval decision of any kind.**

## 6. Assumption of Risk (Experimental Pilot)

**You understand and voluntarily accept that this is an experimental pilot.** You acknowledge that: the software and models are under development and may contain errors; the financial health score, analytics, insights, and recommendations **may be inaccurate, incomplete, or unsuitable** for any particular purpose; data pulled from third-party providers may be wrong, out of date, or misattributed; outputs should **not** be relied on for any financial, credit, tax, legal, investment, or other decision; and any action you take based on Pilot outputs is taken **at your own risk and discretion.** You assume the risks inherent in taking part in an experimental financial-technology pilot.

## 7. Disclaimer of Warranties

To the maximum extent permitted by law, the Pilot, the outputs, and all related software and services are provided **"AS IS" and "AS AVAILABLE," without warranties of any kind**, express or implied, including any implied warranties of merchantability, fitness for a particular purpose, accuracy, or non-infringement, or that the Pilot will be uninterrupted, error-free, or secure, or that outputs will be accurate or reliable. No advice or information obtained from RevelFT creates any warranty not expressly stated here. Some jurisdictions limit warranty disclaimers; in those jurisdictions this section applies to the extent permitted.

## 8. Limitation of Liability

To the maximum extent permitted by law: **(a)** RevelFT and its officers, directors, employees, and agents will **not** be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages, or for lost profits, lost data, or business interruption, arising out of or relating to the Pilot, however caused and under any theory of liability, even if advised of the possibility; and **(b)** RevelFT's total aggregate liability arising out of or relating to the Pilot will not exceed **the greater of (i) the amounts you paid to RevelFT to participate (if any) or (ii) US $100**. **These limits do not apply** to liability that cannot be limited by law (which may include gross negligence, willful misconduct, fraud, or certain statutory violations).

## 9. Release

To the maximum extent permitted by law, in consideration of your participation, you **release and discharge** RevelFT and its officers, directors, employees, and agents from any claims, demands, or liabilities arising out of the **known and disclosed risks of participating in this experimental pilot** as described in §§5–7, including claims that Pilot outputs were inaccurate, incomplete, or unsuitable, or that you relied on them to your detriment. **This release does not extend to, and you do not waive:** claims arising from RevelFT's gross negligence, willful misconduct, or fraud; RevelFT's breach of its data-security or privacy obligations; or any rights that cannot be waived under applicable law (including certain rights under the Fair Credit Reporting Act and state privacy and consumer-protection laws).

## 10. Indemnification (Participant → RevelFT)

You agree to indemnify and hold harmless RevelFT and its officers, directors, employees, and agents from any third-party claims, damages, losses, and reasonable expenses (including reasonable attorneys' fees) arising out of: **(a)** your breach of these Terms; **(b)** your misuse of the Pilot or its outputs, including any use of an output for a purpose these Terms prohibit; **(c)** your violation of any law or third-party right in connection with the Pilot; or **(d)** data or authorizations you provided that you were not entitled to provide.

## 11. Intellectual Property, Confidentiality, and Restrictions

- **RevelFT ownership.** All models, algorithms, pipelines, the proprietary financial representation ("digital twin"), scoring methodology, analytics, software, user interfaces, and all related intellectual property, and all improvements to any of them, are and remain the **exclusive property of RevelFT**. Participation gives you **no license or ownership** in any of them, except a limited, revocable, non-transferable right to use the Pilot for your personal self-assessment during the Pilot.
- **Your data.** Your underlying personal data remains yours; these Terms govern only RevelFT's permitted use of it.
- **Confidentiality.** Any non-public information you observe about the Pilot — including methodologies, scoring logic, model behavior, screens, features, performance, or results architecture — is RevelFT's **Confidential Information**. You agree to keep it confidential and not disclose it to any third party, during the Pilot and for **three (3) years** after it ends.
- **No reverse engineering.** You will not reverse engineer, decompile, disassemble, probe, or attempt to derive the scoring methodology, models, formulas, or source code, or the structure of the proprietary representation, by any means.
- **No derivative works or scraping.** You will not copy, modify, create derivative works from, scrape, or extract the Pilot's outputs, models, or data beyond your own personal self-assessment use.
- **Feedback.** Any feedback, suggestions, or ideas you provide about the Pilot are assigned to RevelFT and may be used by RevelFT without restriction or compensation.
- **Injunctive relief.** A breach of this section may cause RevelFT irreparable harm for which money damages are inadequate, and RevelFT may seek injunctive relief in addition to other remedies.

## 12. Withdrawal, Deletion, and Retention

**Withdrawing.** You may withdraw at any time by email to **info@revelft.io** or **privacy@revelft.io**, or in writing to the address in §16. You may also withdraw a single data source. When we receive your withdrawal:
- we **stop** accessing and processing your data for the Pilot, and **no further Equifax inquiries** are made;
- we disconnect your MX and Argyle connections, within one business day; and
- withdrawal does not affect the lawfulness of processing before it.

**Leaving the Pilot.** If you leave, we delete your **identifiable** Pilot data **within 30 days**, except where the law or our provider agreements require us to keep it.

**What we keep.**
- **Consent records** (what you agreed to, when, and each version) and **records of Equifax inquiries** (dates and reference details, not the report content), for as long as the law and our provider agreements require.
- **Records of staff access to your screens** (§13), for the period in the Privacy Policy.
- **De-identified data.** Data changed so that it cannot reasonably be linked back to you may be kept, as described in the Privacy Policy, for RevelFT's internal research and product improvement only. It is never sold or shared outside RevelFT. You can ask us not to keep de-identified data from your participation (Privacy Policy §6.5).

**Equifax information.** Credit-report content received from Equifax is kept no longer than 30 days. What Stance derives from it for your assessment is part of your Stance record.

**MX deletion requests.** You may ask us at any time to delete the data we received through MX. We will promptly delete your identifiable MX data and tell MX, as our agreement with MX requires.

**Your rights.** You may also exercise access, correction, deletion, and other rights under applicable law and the Privacy Policy.

## 13. Data Handling, Security, and Staff Access

Your Pilot data is kept in a dedicated, access-controlled Pilot environment, separated from RevelFT's general production data. We apply data minimization, access controls, credential isolation, encryption of sensitive data, and audit logging, as described in the Privacy Policy. Each result is traceable to the data sources it was built from. No interface exists that provides your outputs to any third party.

**Staff access.** A small number of authorized RevelFT staff, bound by confidentiality, can view your Stance screens, exactly as you see them, to help you, fix problems, and check that your results are accurate. They can only view: they cannot change your information or act on your behalf. Staff access is available only once you have accepted the consent version that describes it. Every time staff view your screens, Stance records who viewed, when, and which pages.

Where these Terms and the Privacy Policy differ for the Pilot, the more protective term applies.

## 14. Dispute Resolution — Informal Resolution, Individual Arbitration, and Class-Action Waiver

**Please read this section carefully. It affects how disputes are resolved, including giving up a jury trial and class actions. You can opt out (§14.7).**

**14.1 Talk to us first.** Before starting any claim, you and RevelFT agree to try to resolve the dispute informally. Send a written description of the dispute and what you want to **info@revelft.io** (RevelFT will write to the email address on your account). If it isn't resolved within **60 days**, either of us may start arbitration or, where allowed, small-claims court.

**14.2 Binding individual arbitration.** Except as stated in §14.4, any dispute, claim, or controversy between you and RevelFT arising out of or relating to the Pilot, these Terms, or your data will be resolved by **binding individual arbitration** administered by the **American Arbitration Association (AAA)** under its **Consumer Arbitration Rules** then in effect, before a single arbitrator. The Federal Arbitration Act governs this section. The arbitrator decides all questions about the scope and enforceability of this section, except as stated in §14.6.

**14.3 Costs and location.** RevelFT will pay all AAA filing, administration, and arbitrator fees beyond the filing fee the Consumer Arbitration Rules assign to the consumer, and will reimburse that fee too if you win. Each side pays its own attorneys' fees unless the law or the arbitrator awards them. Hearings take place by video or phone, or in person in the county where you live, whichever you choose. The arbitrator may award any individual relief a court could award, but only for you individually.

**14.4 What is not covered.** Either of us may: (a) bring an individual claim in **small-claims court** if it qualifies; (b) ask a court for an injunction to stop misuse of intellectual property or Confidential Information (§11), or misuse of your personal data; and (c) bring a claim for public injunctive relief in court where the law does not allow it to be waived, after any arbitrable claims are decided.

**14.5 No class actions; no jury.** You and RevelFT each agree to bring claims **only individually**, not as a plaintiff or class member in any class, collective, or representative proceeding, and the arbitrator may not consolidate claims of different people. **You and RevelFT each give up the right to a jury trial.**

**14.6 If part of this section is unenforceable.** If the class-action waiver in §14.5 is found unenforceable for a claim, that claim goes to court, not arbitration, and the rest of this section still applies to other claims. A court, not the arbitrator, decides whether §14.5 is enforceable.

**14.7 Your right to opt out.** You may opt out of §§14.2–14.6 (arbitration, the class-action waiver, and the jury waiver) within **30 days** after you first accept these Terms, by emailing **info@revelft.io** or writing to the address in §16, with your name and the words "arbitration opt-out." We will confirm that we received it. Opting out does not affect anything else in these Terms or your participation, and we will not treat you differently for it. If you opt out, disputes are resolved in the state or federal courts located in Delaware, and §14.1 (talk to us first) still applies.

**14.8 Governing law and precedence.** Apart from the Federal Arbitration Act, these Terms are governed by the laws of the State of Delaware. For the Pilot, this §14 governs disputes and **replaces** the dispute provisions of the Stance Terms of Service (§12.1). This section survives the end of your participation.

## 15. Changes to the Pilot; Future Expansion

These Terms cover the current limited, consumer-facing, direct-to-individual pilot only. **Any expansion** — more users beyond the pilot's scope, provision of outputs to any third party or partner organization, any decisioning use, or use of your data to train models — is a **separate matter requiring new, specific consent** and is **not** authorized here. We will not repurpose your Pilot data for such uses without your separate consent. When these Terms or the consent change in a way that expands what we do with your data, we will ask for your consent again before doing it.

## 16. General

These Terms incorporate the Stance Terms of Service and Privacy Policy (v1.1) by reference; for the Pilot, the more protective term governs, except that §14 governs disputes. Governing law: Delaware. Written notices to RevelFT: **RevelFT, Inc., c/o Agents and Corporations, Inc., 1201 Orange Street, Suite 600, Wilmington, Delaware 19801**, or info@revelft.io. If any provision is unenforceable, the rest remains in effect, and that provision is limited to the minimum extent necessary.

## 17. Consent Acknowledgment (9 Checkboxes — `v5-pilot`)

At enrollment you affirm consent by ticking **all nine** checkboxes below; enrollment will not proceed otherwise. If you enrolled under an earlier version, you will be asked to review this version at your next login; you may decline, in which case your participation continues under the version you accepted, without staff access and without Equifax inquiries beyond those it covers. The **authoritative wording** of each checkbox is the versioned constant `CONSENT_TEXT["v5-pilot"]`, reproduced verbatim in **Appendix A**. A record of your acceptance — the consent version, a cryptographic checksum of the exact text shown, the date and time, your IP address or device, and the versions of these Terms and the Privacy Policy — is kept as evidence of your informed consent.

1. **`consent_data_access`** — access to your connected financial account data to analyze cashflow.
2. **`consent_equifax`** — soft Equifax inquiries while you are enrolled (they do not affect your credit score), as your written instruction under the Fair Credit Reporting Act.
3. **`consent_argyle`** — income and employment verification through Argyle.
4. **`consent_mx`** — bank and investment account data (transaction-level) through MX.
5. **`consent_landscape`** — matching your profile with relevant economic programs, benefits, and policy updates.
6. **`consent_future_sources`** — new data sources are each disclosed and separately consented before any data flows.
7. **`consent_all`** — agreement to these Terms and the Privacy Policy; the pilot is experimental; not a consumer report; results shown to you and to authorized staff as described, and never to third parties for decisions.
8. **`fcra_disclosure`** — Equifax information is an input to your personal assessment only.
9. **`consent_staff_access`** — read-only, recorded staff viewing of your screens.

By ticking all nine and continuing, you confirm your agreement and acknowledge that this is your electronic signature.

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## Appendix A — Canonical Consent Text (`CONSENT_TEXT["v5-pilot"]`)

The strings below reproduce the deployed constant, which is the single source of truth. On any change, the constant and this appendix move together to a new version.

**Canonical order:** `consent_data_access, consent_equifax, consent_argyle, consent_mx, consent_landscape, consent_future_sources, consent_all, fcra_disclosure, consent_staff_access`
**Checksum (SHA-256 over the raw strings in canonical order, separated by the ASCII record separator, UTF-8):** `d0f3888b56de1d657efa0f5c8802b4ef062ef243fa4dfa87ac96373e38c9e2b8`

- **consent_data_access:** "I authorize Stance to access my connected financial account data (balances and transactions) to analyze my cashflow, as described in the Stance Terms of Service."
- **consent_equifax:** "I authorize RevelFT (Stance) to obtain my consumer credit information from Equifax through soft inquiries, which do not affect my credit score, for as long as I remain enrolled: when I enroll, when I ask Stance to update my assessment, when Stance detects a change in my finances, and as needed to keep my assessment accurate and to confirm that Stance handles my information correctly. Stance uses this information to verify my identity, confirm my current obligations and payment history, and produce and check my personal financial assessment. This is my written instruction under the Fair Credit Reporting Act. I can withdraw it at any time, and no further inquiries will be made after I do."
- **consent_argyle:** "I authorize income and employment verification through Argyle, limited to the minimum information needed to generate my assessment."
- **consent_mx:** "I authorize Stance to access my bank and investment account data, including transaction-level activity, through MX, limited to the minimum needed to generate my assessment."
- **consent_landscape:** "I consent to Stance matching my profile with relevant economic programs, benefits, and policy updates."
- **consent_future_sources:** "I understand that Stance may add new data sources over time to improve my assessment. I agree that Stance will disclose each new source to me and obtain my separate, specific consent before any of my data is shared with or retrieved from it. I understand this does not authorize sharing my data with any new source until I have given that separate consent."
- **consent_all:** "I have read and agree to the Stance Terms of Service and Privacy Policy. I understand this is an experimental pilot: my results may be inaccurate or incomplete, are not financial, legal, tax, or investment advice, and I should not rely on them to make decisions — any action I take is at my own risk. I understand this is a self-assessment tool that is not a consumer report, and that RevelFT is not acting as a consumer reporting agency. I understand this is a self-assessment tool designed to provide information to me. My results are shown to me, and to a small number of authorized RevelFT staff only as described in this consent. They will not be provided to any third party for any decision."
- **fcra_disclosure:** "I understand that certain information used in my assessment may be obtained from a consumer reporting agency (Equifax) under permissible use and my authorization. This information is used as an input into my personal assessment and will not be presented as a consumer report nor provided to third parties for eligibility, credit, employment, insurance, or other decision-making purposes."
- **consent_staff_access:** "I understand that a small number of authorized RevelFT staff, bound by confidentiality, can view my Stance screens, exactly as I see them, to help me, fix problems, and check that my results are accurate. They can only view: they cannot change my information or act on my behalf. Every time staff view my screens, Stance records who viewed, when, and which pages, and keeps that record as described in the Privacy Policy."