Terms of Service.
We Made Them Readable. Sort Of.

This Terms of Service Agreement ("Agreement") is entered into between Truth Technologies, Inc. ("Provider," "we," "us," or "our"), a Florida corporation, and the entity or individual accessing or using our Services ("Subscriber" or "you"). By accessing or using the Sentinel™ platform and related services (collectively, the "Services"), you agree to be bound by this Agreement.

If you are entering into this Agreement on behalf of an organization, you represent that you have authority to bind that organization to these terms.

1.1 License Grant

Subject to the terms of this Agreement and payment of applicable fees, Provider grants Subscriber a non-exclusive, non-transferable, limited license to access and use the Services, including the Content and Data made available therein, solely for Subscriber's internal business compliance purposes during the subscription term.

1.2 Service Level

Provider will use commercially reasonable efforts to maintain platform availability as described in any applicable Service Level Agreement. Provider will offer email support through the Sentinel™ web portal. Support requests submitted during regular business hours will receive a response within one (1) business day.

1.3 Data Source Updates

Provider updates applicable data sources Monday through Friday. Subscriber acknowledges that the Services may be temporarily interrupted for scheduled maintenance, upgrades, or repairs. Scheduled interruptions not exceeding 24 hours during any consecutive 30-day period (excluding planned maintenance and data updates) shall not entitle Subscriber to any fee reduction.

2.1 Account Security

Subscriber is responsible for maintaining the confidentiality of account credentials and for all activities conducted under its account. Subscriber must notify Provider immediately of any unauthorized access or suspected security breach.

2.2 Authorized Users

Subscriber may permit its employees, contractors, and agents whose duties reasonably relate to the legitimate business purposes for which the Services are used to access the Services. Subscriber is responsible for their compliance with this Agreement. Account sharing between distinct users is prohibited. The number of authorized users shall not exceed the number of licensed seats specified in the applicable Order Form.

2.3 Acceptable Use

Subscriber agrees to use the Services, Content, and Data solely within the ordinary course of its legitimate compliance business purposes. Subscriber shall not:

• Use the Services for any unlawful purpose or in violation of applicable international, national, state, or local laws and regulations
• Use the Services outside the ordinary course of business, including for commercial publishing, information brokering or reselling, political or personal purposes, or media venue reporting
• Use the Services for consumer health insurance underwriting or any FCRA "permissible purpose" as defined in 15 U.S.C. § 1681b (except as permitted under Section 2.4 below)
• Access or use the Services in connection with public figures unless part of a legitimate business transaction with such person
• Reverse engineer, decompile, disassemble, or attempt to derive source code from any part of the Services
• Alter or modify the Content or Data
• Interfere with or disrupt the Services or introduce malicious code, viruses, or harmful components
• Sublicense, resell, transfer, or share access to the Services with competitors, information brokers, resellers, or media venues
• Use automated tools to scrape or extract data beyond normal use
• Attribute information from the Services to any source other than the original source cited in the Service output
• Represent that Subscriber is an authorized agent or representative of Provider

Provider may suspend access for violations of this section. Provider reserves the right to terminate this Agreement immediately, without refund, in the event of repeated violations or any single violation that Provider reasonably determines poses a material risk to Provider, its data sources, or third parties.

2.4 FCRA Restrictions

Subscriber shall not use information from the Services for any "permissible purpose" under the Fair Credit Reporting Act (15 U.S.C. § 1681b), including to establish consumer eligibility for credit, insurance, employment, government benefits or licenses, or to collect an account or determine whether a consumer continues to meet account terms. Notwithstanding the foregoing, Subscriber may use the Services in connection with a permitted employee investigation of suspected misconduct as described in 15 U.S.C. § 1681a(x), subject to the restrictions set forth therein. Subscriber shall certify compliance with these FCRA restrictions annually upon Provider's request.

2.5 Regulatory Compliance

Subscriber shall comply with all applicable laws governing its use of the Services, including the FCRA, the Gramm-Leach-Bliley Act (GLBA), the General Data Protection Regulation (GDPR) where applicable, and all applicable export and sanctions laws including the U.S. Export Administration Regulations (EAR) and OFAC sanctions programs. Subscriber represents that it is not located in, or a national or resident of, any country subject to U.S. trade sanctions, and is not on any U.S. government restricted party list.

2.6 Adverse Action

If Subscriber intends to take any adverse action against a person or entity based in whole or in part on Data obtained through the Services, Subscriber is solely responsible for independently verifying that Data prior to taking such action.

2.7 Subscriber Data

Subscriber retains ownership of all data and information it submits to the Services ("Subscriber Data"). Subscriber grants Provider a limited license to use Subscriber Data solely to provide the Services. Subscriber represents that it has all rights and authorizations to submit such data and that doing so complies with applicable laws, including applicable data protection regulations.

3.1 Fees

Fees are specified in the applicable Order Form or service agreement between the parties. All fees are in U.S. dollars. Fees are non-cancelable and non-refundable except as expressly provided in this Agreement or required by applicable law. Overdue amounts shall accrue interest at the rate of 1.5% per month (or the maximum rate permitted by applicable law, whichever is lower) from the due date until paid in full. Subscriber shall also reimburse Provider for all reasonable costs of collection, including attorneys' fees.

3.2 Payment Terms

Payment is due as specified in the applicable Order Form. Provider may suspend access for accounts more than 30 days past due. Suspension of access does not relieve Subscriber of its obligation to pay all fees due under this Agreement. Access will be restored upon payment of all outstanding amounts including any accrued interest and a reinstatement fee as determined by Provider at the time of restoration.

3.3 Taxes

Fees do not include taxes. Subscriber is responsible for all applicable sales, use, VAT, or similar taxes, excluding taxes based on Provider's net income.

4.1 Term

This Agreement begins on the start date specified in the applicable Order Form or service agreement and continues for the term specified therein.

4.2 Renewal

Unless otherwise specified in the Order Form, subscriptions automatically renew for successive one-year periods unless either party provides written notice of non-renewal at least 60 days before the end of the current term.

4.3 Termination for Cause

Either party may terminate this Agreement upon written notice if the other party materially breaches this Agreement and fails to cure such breach within 30 days of receiving written notice. Provider may terminate immediately, without refund, for Subscriber's material breach of Section 2 (Subscriber Responsibilities).

4.4 Effect of Termination

Upon termination or expiration, Subscriber's access to the Services ends immediately. Sections 2, 5, 6, 7, 8, 9, 10, and 11 survive termination. If Subscriber terminates due to Provider's uncured material breach, Provider will refund a pro-rata portion of prepaid fees for the unused subscription term. If Subscriber cancels or terminates this Agreement for any other reason, including convenience, no refunds shall be issued for any fees paid or prepaid.

5.1 Provider IP

Provider and its Information Providers retain all right, title, and interest in and to the Services, Content, Data, software, documentation, and improvements thereto under applicable contractual, copyright, patent, trademark, and other laws. Nothing in this Agreement transfers any ownership of Provider's intellectual property to Subscriber.

5.2 Restrictions on Transfer

Subscriber shall not sell, resell, license, sublicense, publish, reproduce, transmit, copy, or otherwise transfer any Content or Data received through the Services outside the ordinary course of its compliance business, except as required by applicable law or regulation or to respond to valid legal process.

5.3 Feedback

If Subscriber provides suggestions or feedback about the Services, Provider may use such feedback without obligation to Subscriber.

5.4 Aggregated Data

Provider may collect and use aggregated, anonymized data derived from use of the Services to improve its products and services. Such data will not identify Subscriber or any individual. This section does not apply to data derived from third-party licensed data sources where such use is restricted by the applicable data license agreement, including without limitation any data licensing agreement with third-party data providers.

6.1 Definition

"Confidential Information" means non-public information relating to a party, its business, assets, or clients that is disclosed by one party (the "Disclosing Party") to the other (the "Receiving Party") in connection with this Agreement. Subscriber Confidential Information includes personal information of Subscriber's customers, clients, vendors, contractors, and employees. Confidential Information does not include information that: (a) is or becomes publicly available without breach of this Agreement; (b) was known to the Receiving Party at the time of disclosure; (c) is received from a third party without a confidentiality obligation; or (d) was independently developed by the Receiving Party without use of the Disclosing Party's Confidential Information.

6.2 Obligations

Each party agrees to protect the other's Confidential Information with at least the same degree of care it uses to protect its own confidential information of similar sensitivity (and no less than reasonable care), to use Confidential Information solely in connection with this Agreement, and to restrict access to personnel with a need to know.

6.3 Compelled Disclosure

If a Receiving Party is legally required to disclose Confidential Information, it will provide prompt notice (unless prohibited by law) to allow the Disclosing Party to seek a protective order. The Receiving Party will disclose only the minimum required and will cooperate in seeking confidential treatment.

6.4 Security Breach Notification

If a Receiving Party becomes aware that Confidential Information in its control has been stolen, destroyed, altered, lost, or accessed by unauthorized persons, it shall promptly notify the Disclosing Party by telephone and in writing, and advise of steps being taken to prevent further breach.

6.5 Return or Destruction

Upon written request, the Receiving Party will promptly return or destroy all Confidential Information received from the Disclosing Party, except as required by applicable law or regulation, or with respect to aggregated, anonymized data that does not identify Subscriber or any individual as described in Section 5.4. In the event of destruction, the Receiving Party will provide written certification signed by an authorized officer.

6.6 Injunctive Relief

The parties acknowledge that any violation of this Section may cause immediate and irreparable harm for which monetary damages would be inadequate. Either party may seek injunctive or other equitable relief without bond in any court of competent jurisdiction, in addition to any other available remedies. The prevailing party in any such action is entitled to reasonable attorneys' fees and costs.

6.7 Non-Use of Provider Information

Subscriber shall not disclose, share, or otherwise make available any Provider Confidential Information (including without limitation Provider's pricing arrangements, contract terms, software, demos, proprietary workflows, or technology) to any third party, including Subscriber's other vendors, auditors, or competitors of Provider, for any purpose other than internal use of the Services, without the prior written consent of Provider. Subscriber shall not use such information to negotiate, solicit, or secure more favorable terms from any other party. This obligation survives termination of this Agreement.

Provider processes personal data in accordance with its Privacy Policy at truthtechnologies.com/privacy-policy. Where required by applicable law, including the GDPR, the parties shall enter into a separate Data Processing Agreement. Subscriber acknowledges that if either party identifies that an additional written agreement is necessary to comply with applicable data protection laws, it will promptly notify the other party, and Subscriber agrees to enter into such agreement.

8.1 Mutual Warranties

Each party represents and warrants that: (a) it has full authority to enter into this Agreement; (b) this Agreement constitutes a legal, valid, and binding obligation; and (c) its performance under this Agreement will comply with all applicable laws.

8.2 Subscriber Warranties

Subscriber additionally warrants that: (a) it has sufficient confidentiality procedures to protect the Content and Data; (b) it is not a media venue, information broker, or information reseller; (c) it has all rights and authorizations to submit Subscriber Data to the Services; and (d) it will comply with all restrictions set forth in Section 2.

8.3 Disclaimer

8.4 Informational Purposes Only

The information, articles, resources, and educational content published on the Truth Technologies, Inc. website, including but not limited to the Insights pages covering Know Your Customer (KYC) screening, Anti-Money Laundering (AML) screening, Politically Exposed Person (PEP) screening, OFAC compliance, sanctions screening, and counter-terrorism financing, are provided for general informational purposes only. This content is not intended to serve as a definitive or comprehensive statement of the law, regulatory requirements, or compliance obligations applicable to any individual, organization, or industry.

8.5 Not Legal Advice

Nothing on this website constitutes legal, regulatory, financial, or compliance advice, and no attorney-client relationship is formed by your access to or use of this website or its content. The information provided is not a substitute for advice from qualified legal counsel familiar with your specific circumstances, jurisdiction, and applicable regulatory requirements. Users should not act, or refrain from acting, on the basis of any content published on this website without first seeking independent professional guidance.

8.6 Jurisdictional Variation and Timeliness

Regulatory obligations vary significantly by industry, jurisdiction, and applicable law. They are subject to change, often without notice, and may be interpreted differently by different regulatory authorities. Truth Technologies, Inc. makes no representations or warranties, express or implied, regarding the completeness, accuracy, timeliness, or fitness for a particular purpose of any information published on this website. Regulatory information published here may not reflect the most current legal developments, guidance, or enforcement trends. Your use of or reliance on any content on this website is at your own risk.

8.7 Errors and Omissions

While Truth Technologies, Inc. makes reasonable efforts to ensure the accuracy of content published on this website, we expressly disclaim liability for any errors, omissions, or inaccuracies in any content, regardless of the cause. We reserve the right to update, modify, or remove any content at any time without notice.

8.8 Third-Party Links and Resources

This website may contain links to third-party websites, regulatory agencies, or external resources for informational convenience only. Truth Technologies, Inc. does not endorse, control, or guarantee the accuracy, completeness, or availability of any third-party content, and we accept no responsibility or liability for information found on external sites. Inclusion of any link does not imply endorsement or affiliation.

8.9 No Guarantee of Compliance

Use of the Sentinel™ platform or any Truth Technologies, Inc. product or service does not guarantee regulatory compliance or protection from enforcement action. Subscribers and website visitors remain solely responsible for understanding and meeting their own legal and regulatory obligations in their applicable jurisdictions. We strongly encourage all users to consult qualified legal counsel and to verify requirements with the relevant regulatory agencies before making any compliance-related decisions.

9.1 By Provider

Provider will indemnify, defend, and hold harmless Subscriber from and against third-party claims arising from: (a) a finding that the Services, as used in accordance with this Agreement, infringe a third party's intellectual property rights; (b) Provider's gross negligence or willful misconduct in violation of applicable law; or (c) unauthorized access to or disclosure of Subscriber Confidential Information caused directly by Provider's own acts or omissions. Provider shall have no indemnification obligation for any claim arising from: (i) Subscriber's misuse of the Services or use outside the scope of this Agreement; (ii) Subscriber's combination of the Services with third-party products or services not approved by Provider; (iii) modifications to the Services made by anyone other than Provider; or (iv) Subscriber's failure to comply with applicable law.

9.2 By Subscriber

Subscriber will indemnify, defend, and hold harmless Provider and its Information Providers from and against third-party claims arising from: (a) Subscriber's use of the Services outside the ordinary course of business; (b) Subscriber's violation of applicable law; or (c) unauthorized access to or disclosure of Provider's Confidential Information by Subscriber or its personnel, except to the extent caused by Provider's willful misconduct or gross negligence.

9.3 Conditions

Indemnification obligations require: (a) prompt written notice of the claim; (b) the indemnifying party having sole control of the defense, provided that any settlement requiring a non-monetary obligation or admission of liability by the indemnified party requires its prior written consent; and (c) reasonable cooperation by the indemnified party at the indemnifying party's expense.

11.1 Governing Law

This Agreement is governed by the laws of the State of Florida, without regard to its conflict of law provisions. Any disputes arising under this Agreement shall be resolved exclusively in the state or federal courts located in Collier County, Florida. Each party consents to personal jurisdiction in such courts.

11.2 Entire Agreement

This Agreement, together with any applicable Order Form, Service Level Agreement, and Data Processing Agreement, constitutes the entire agreement between the parties with respect to the Services and supersedes all prior agreements, representations, and understandings. In the event of a conflict between this Agreement and an Order Form, the Order Form shall control solely with respect to the specific terms addressed therein.

11.3 Amendments

Provider may update these Terms of Service from time to time. Material changes will be communicated to Subscriber by email or through the platform at least 30 days before taking effect. Continued use of the Services after the effective date constitutes acceptance of the updated terms.

11.4 Waiver and Severability

Failure to enforce any provision of this Agreement shall not constitute a waiver of future enforcement. If any provision is found invalid or unenforceable, the remaining provisions shall continue in full force and effect, and the invalid provision shall be modified to the minimum extent necessary to make it enforceable.

11.5 Assignment

Subscriber may not assign this Agreement or any rights hereunder without Provider's prior written consent. Provider may assign this Agreement in connection with a merger, acquisition, or sale of substantially all its assets without Subscriber's consent, provided that the assignee assumes all obligations under this Agreement. Any purported assignment in violation of this section is void.

11.6 Force Majeure

Neither party shall be liable for delays or failures in performance resulting from circumstances beyond its reasonable control, including natural disasters, acts of government, labor disputes, or internet service disruptions, provided the affected party gives prompt notice and uses reasonable efforts to resume performance.

11.7 Notices

All legal notices must be in writing and sent by email with confirmation of receipt, or by certified mail to the addresses specified in the applicable Order Form. Notices to Provider should be directed to legal@truthtechnologies.com.

11.8 Relationship of Parties

The parties are independent contractors. Nothing in this Agreement creates a partnership, joint venture, employment, or agency relationship between the parties.

11.9 Export Compliance

Subscriber shall comply with all applicable export control laws and regulations in connection with its use of the Services, including the U.S. Export Administration Regulations and OFAC sanctions programs.