PLEASE READ THIS AGREEMENT CAREFULLY BEFORE USING THE CURTER PLATFORM. BY CLICKING "I AGREE," CREATING AN ACCOUNT, OR ACCESSING THE SERVICE, YOU AGREE TO BE BOUND BY ALL TERMS HEREIN.

1. Introduction & Acceptance

This User Agreement ("Agreement") is a legally binding contract between you ("User," "you," or "your") and Curter, Inc. ("Curter," "Company," "we," "us," or "our"), governing your access to and use of the Curter software platform, including all features, tools, APIs, data outputs, and related services available at curter.ai (collectively, the "Service").

BY CREATING AN ACCOUNT, CLICKING "I AGREE," OR OTHERWISE ACCESSING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS AGREEMENT IN ITS ENTIRETY. IF YOU DO NOT AGREE, YOU MAY NOT ACCESS OR USE THE SERVICE.

This Agreement is intended to comply with all applicable federal laws and regulations of the United States. In the event of any conflict between this Agreement and any applicable federal law, the federal law shall govern.

If you are accessing the Service on behalf of a financial institution, bank, lender, or other organization, you represent and warrant that you have authority to bind that organization to this Agreement.

We reserve the right to update or modify this Agreement at any time. Continued use of the Service following notice of any changes constitutes your acceptance of the revised terms.

2. Definitions

As used in this Agreement, the following terms have the meanings set forth below:

• "Service" means the Curter software platform, including all tools for SBA loan brief generation, refinancing opportunity identification, client data analysis, document automation, and any related features or functionality.
• "User Data" means any data, information, or content submitted, uploaded, or processed through the Service by you or on your behalf, including but not limited to borrower information, loan data, financial records, and client communications.
• "Output" means any documents, briefs, analyses, summaries, or other materials generated by the Service based on User Data.
• "Authorized User" means any individual employee, contractor, or agent of your organization who accesses the Service under your account with your authorization.
• "SBA" means the U.S. Small Business Administration.
• "Applicable Laws" means all federal, state, and local laws, rules, and regulations applicable to your use of the Service, including but not limited to the Gramm-Leach-Bliley Act, Fair Credit Reporting Act, Bank Secrecy Act, anti-money laundering laws, and all federal privacy and consumer protection laws.
• "Team Account" means any account type that allows a designated Team Leader to provision, manage, and oversee access for one or more Subordinate Users under a single billing relationship with Curter.
• "Team Leader" means the individual or entity who establishes or administers a Team Account and who is the designated billing responsible party for all usage and charges incurred by themselves and all Subordinate Users under that Team Account.
• "Subordinate User" means any Authorized User whose access to the Service is provisioned, managed, or sponsored by a Team Leader under a Team Account.
• "Overage" or "Overage Charges" means any fees, charges, or costs incurred above and beyond the usage limits, seat limits, or spending thresholds included in the applicable Subscription Terms for a given billing period.

3. Eligibility & Account Registration

3.1 Eligibility Requirements

The Service is intended exclusively for use by licensed financial professionals, SBA-approved lenders, banking institutions, and their authorized personnel. By using the Service, you represent and warrant that:

• You are at least 18 years of age;
• You are a licensed, registered, or otherwise legally authorized financial professional or institution under applicable federal and state law;
• Your use of the Service complies with all Applicable Laws, including all federal regulations governing SBA lending, financial services, and data privacy;
• You have obtained all necessary consents and authorizations to submit any borrower or third-party data to the Service;
• You are not prohibited from receiving services under U.S. law or regulations, including OFAC sanctions lists.

You further represent and warrant that you will not use the Service in any manner that would cause Curter to violate any Applicable Laws.

3.2 Account Security

You are solely responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You agree to:

• Use a strong, unique password;
• Immediately notify Curter of any unauthorized account access at [email protected];
• Ensure that Authorized Users comply with this Agreement.

Curter shall not be liable for any losses resulting from unauthorized account access caused by your failure to secure your credentials.

4. Description of Service & Permitted Use

4.1 Service Capabilities

Curter is a software tool designed to assist SBA lenders and banking professionals with: automated loan brief generation; identification of refinancing opportunities within existing loan portfolios; document preparation and summarization; and workflow automation for SBA lending processes.

4.2 Permitted Use

Subject to this Agreement, Curter grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Service solely for your internal business purposes in connection with lawful SBA lending and financial services activities, and in full compliance with all Applicable Laws. Permitted uses include:

• Generating loan briefs and summaries for SBA loan applications;
• Identifying refinancing opportunities for your existing borrower portfolio;
• Automating document preparation workflows within your organization;
• Training Authorized Users on the use of the Service.

4.3 Prohibited Uses

You may not use the Service for any of the following purposes:

• Violating any Applicable Laws, including any federal or state law, regulation, or SBA program rule;
• Submitting false, misleading, or fraudulent data, including misrepresenting borrower information in SBA loan applications;
• Circumventing or attempting to circumvent any SBA underwriting, eligibility, or compliance requirement;
• Reverse engineering, decompiling, disassembling, or attempting to derive the source code of the Service;
• Sublicensing, reselling, leasing, or commercially distributing the Service or Outputs to third parties without written authorization from Curter;
• Using the Service to develop a competing product or service;
• Uploading any data that infringes on third-party intellectual property rights;
• Transmitting viruses, malware, or other harmful code;
• Attempting to gain unauthorized access to Curter's systems, infrastructure, or other users' data;
• Using automated tools (scrapers, bots, crawlers) to extract data from the Service beyond normal permitted use;
• Circumventing, disabling, or attempting to exceed any rate limit, usage cap, or access control, including by registering or using multiple accounts to aggregate access or evade limits;
• Extracting, eliciting, or attempting to discover the Service's system prompts, model instructions, tool definitions, scoring or ranking logic, lending-calculation methodology, or other confidential internal workings, whether by prompt injection, social engineering of the AI assistant, or any other means.

Any violation of this section may result in immediate suspension or termination of your access to the Service.

5. User Data, Privacy & Data Security

5.1 Your Data

You retain all ownership rights to User Data you submit to the Service. By submitting User Data, you grant Curter a limited, non-exclusive license to process and use that data solely for the purpose of providing the Service to you.

5.2 Data Responsibility

You represent and warrant that:

• You have all necessary rights, consents, and authorizations to submit User Data to the Service, including any borrower or customer personal information;
• Your submission and processing of User Data complies with the Gramm-Leach-Bliley Act (GLBA), Fair Credit Reporting Act (FCRA), applicable state privacy laws, and any other Applicable Laws and data protection regulations;
• You have provided required privacy notices to borrowers and customers whose data you submit to the Service;
• User Data does not include any data subject to the Health Insurance Portability and Accountability Act (HIPAA), unless you have entered into a separate Business Associate Agreement (BAA) with Curter.

5.3 Curter's Data Practices

Curter processes User Data in accordance with its Privacy Policy. Curter implements commercially reasonable administrative, technical, and physical safeguards to protect User Data against unauthorized access, disclosure, and loss. Curter will not sell User Data to third parties. Curter will maintain policies and procedures designed to ensure compliance with all Applicable Laws, including the GLBA, FCRA, and other federal privacy and data security requirements.

5.4 Data Breach Notification

In the event of a confirmed data breach affecting your User Data, Curter will notify you within a commercially reasonable timeframe as required by Applicable Laws, and will cooperate with your incident response efforts.

5.5 Audit and Monitoring Rights

Curter reserves the right to conduct periodic reviews and audits of your use of the Service to verify compliance with this Agreement and all Applicable Laws. You agree to cooperate with any such audit and to promptly remediate any identified compliance issues.

6. Outputs, AI-Generated Content & Disclaimers

6.1 Nature of Outputs

The Service uses artificial intelligence and automated analysis tools to generate Outputs, including loan briefs, summaries, and refinancing opportunity reports. YOU ACKNOWLEDGE AND AGREE THAT:

• All Outputs are generated by software tools and are provided for informational and workflow assistance purposes only;
• Outputs do not constitute legal advice, financial advice, investment advice, or a recommendation to make any particular lending decision;
• Outputs are not a substitute for your own professional judgment, due diligence, underwriting review, or compliance analysis;
• AI-generated content may contain errors, inaccuracies, or omissions, and may not reflect the most current SBA regulations or guidelines;
• You are solely responsible for independently verifying all Outputs before relying on them for any lending decision, regulatory filing, or client communication.

6.2 No Guarantee of Accuracy or Regulatory Compliance

CURTER MAKES NO WARRANTY, EXPRESS OR IMPLIED, THAT ANY OUTPUT IS ACCURATE, COMPLETE, CURRENT, OR SUITABLE FOR ANY PARTICULAR PURPOSE. ALL OUTPUTS ARE PROVIDED "AS IS." YOU BEAR SOLE RESPONSIBILITY FOR ALL LENDING DECISIONS MADE USING THE SERVICE.

Curter does not guarantee that use of the Service or any Output will result in compliance with any particular law, regulation, or regulatory requirement.

6.3 Regulatory Compliance

You are solely responsible for ensuring that your use of the Service and all Outputs comply with all Applicable Laws, including SBA regulations, federal banking laws, state lending laws, and your institution's own compliance policies.

7. Intellectual Property

7.1 Curter IP

The Service, including all software, algorithms, models, interfaces, designs, trademarks, and documentation, is and remains the exclusive intellectual property of Curter, Inc. and its licensors. Nothing in this Agreement transfers any ownership interest in the Service to you.

7.2 Outputs

Subject to your compliance with this Agreement and full payment of applicable fees, Curter assigns to you all right, title, and interest in Outputs generated from your User Data. You are responsible for ensuring that Outputs do not infringe third-party rights.

7.3 License Restrictions

You may not:

• Copy, modify, adapt, translate, or create derivative works based on the Service;
• Reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code of the Service;
• Sublicense, lease, rent, sell, or otherwise transfer the Service or any Outputs to any third party except as expressly permitted by this Agreement;
• Remove, alter, or obscure any proprietary notices on the Service.

7.4 Feedback

If you provide feedback, suggestions, or ideas regarding the Service, you grant Curter an irrevocable, royalty-free, worldwide license to use such feedback for any purpose, including improving the Service, without any obligation of compensation to you.

8. Fees, Billing, Team Accounts & Overage Policy

8.1 General Fees & Subscription

Access to the Service may be subject to subscription fees, usage fees, or other charges as set forth in your order form, pricing page, or separate agreement with Curter ("Subscription Terms"). You agree to pay all fees in accordance with the Subscription Terms. All fees are non-refundable unless otherwise expressly stated. Curter reserves the right to modify pricing upon reasonable notice. Failure to pay fees may result in suspension or termination of your access to the Service.

8.2 Team Account Structure & Team Leader Responsibility

Where the Service is accessed through a Team Account, the Team Leader assumes full, unconditional financial and administrative responsibility for the Team Account, including:

• All subscription fees, usage fees, Overage Charges, and any other amounts billed to the Team Account, whether incurred directly by the Team Leader or by any Subordinate User under the Team Account;
• Ensuring that all Subordinate Users are aware of and comply with this Agreement, all applicable usage limits, and any spending thresholds established for the Team Account;
• Monitoring and controlling the usage activity of all Subordinate Users to prevent unauthorized or excessive usage;
• Promptly paying all invoices and charges billed to the Team Account by their due date, regardless of whether the Team Leader authorized each individual action taken by a Subordinate User.

The Team Leader is the sole billing responsible party for the entire Team Account. Curter will look exclusively to the Team Leader for payment of all charges associated with the Team Account, including all Overage Charges generated by Subordinate Users.

8.3 Overage Charges — Team Leader Liability

Team Leaders specifically acknowledge and agree that:

• Any usage by a Subordinate User that results in Overage Charges — including but not limited to exceeding seat limits, API call limits, document generation limits, data processing thresholds, or any other usage-based billing metric — constitutes usage for which the Team Leader is directly and personally liable;
• Overage Charges are automatically calculated at the end of each billing period (or in real time where applicable) and are billed directly to the Team Leader's payment method on file;
• The Team Leader's obligation to pay Overage Charges is not conditioned upon the Team Leader's advance approval, knowledge, or authorization of any specific Subordinate User action that caused the Overage;
• It is the Team Leader's sole responsibility to set, communicate, and enforce internal usage policies, spending controls, and authorization requirements for all Subordinate Users;
• Curter has no obligation to obtain pre-approval from the Team Leader before permitting Subordinate Users to access features or incur usage that may result in Overage Charges.

8.4 Overage Notifications

Curter will make commercially reasonable efforts to provide Team Leaders with usage notifications and alerts when the Team Account approaches or reaches applicable usage thresholds, through in-platform alerts, email notifications, or dashboard reporting. However, you acknowledge and agree that:

• Curter's failure to provide any particular notification or alert does not relieve the Team Leader of liability for any resulting Overage Charges;
• Delivery of notifications is subject to the accuracy of the contact information you provide and the proper functioning of third-party email and notification systems outside of Curter's control;
• It remains the Team Leader's independent obligation to monitor usage and manage Subordinate User activity proactively, and not to rely solely on Curter's notification systems for billing oversight.

8.5 Absolute No-Chargeback Policy

ALL OVERAGE CHARGES AND FEES BILLED TO A TEAM ACCOUNT ARE FINAL AND NON-DISPUTABLE ON THE BASIS OF SUBORDINATE USER USAGE. TEAM LEADERS EXPRESSLY AND IRREVOCABLY WAIVE ANY RIGHT TO INITIATE A CHARGEBACK, PAYMENT REVERSAL, OR DISPUTE WITH ANY PAYMENT PROCESSOR, CREDIT CARD ISSUER, BANK, OR FINANCIAL INSTITUTION WITH RESPECT TO ANY OVERAGE CHARGES OR FEES INCURRED THROUGH THE SERVICE.

Specifically, the Team Leader agrees that:

• No chargeback, reversal, dispute, or claim may be initiated or maintained on the basis that: (i) a Subordinate User exceeded their authorized usage limits; (ii) the Team Leader was unaware of or did not personally authorize the Subordinate User's actions; (iii) the Team Leader disputes internal allocation of costs among their team or organization; or (iv) the Team Leader believes a Subordinate User acted outside the scope of their authority;
• Any chargeback or payment reversal initiated by the Team Leader or their payment provider in violation of this Section constitutes a material breach of this Agreement and entitles Curter to immediately suspend or terminate the Team Account, pursue collection of all outstanding amounts, and seek recovery of all costs and attorneys' fees incurred in connection with the disputed charge;
• If Curter prevails in any dispute, chargeback proceeding, or collection action arising from a Team Leader's violation of this Section, Curter shall be entitled to recover the original disputed amount plus a chargeback processing fee of not less than $50.00 per disputed transaction, plus all reasonable attorneys' fees and collection costs;
• The Team Leader's sole remedy for any billing dispute relating to Subordinate User activity is to submit a written billing inquiry to Curter at [email protected] within thirty (30) days of the date of the disputed charge, subject to Curter's billing dispute review process.

8.6 Billing Disputes — Proper Process

If the Team Leader believes a specific charge is the result of a technical error (not Subordinate User usage), the Team Leader may submit a written billing dispute to [email protected] within thirty (30) days of the invoice date. Disputes submitted after this window are waived. Curter will review all properly submitted disputes in good faith and respond within fifteen (15) business days. Curter's determination on billing disputes is final. Pending resolution of any billing dispute, the Team Leader remains obligated to pay all undisputed amounts by their due date.

9. Term, Suspension & Termination

9.1 Term

This Agreement commences on the date you first access the Service and continues until terminated as set forth herein.

9.2 Termination by You

You may terminate your account at any time by contacting Curter at [email protected] and ceasing all use of the Service.

9.3 Termination or Suspension by Curter

Curter may suspend or terminate your access to the Service immediately, without prior notice, if:

• You materially breach this Agreement;
• Curter determines, in its sole discretion, that your use of the Service creates legal, regulatory, or reputational risk;
• You fail to pay applicable fees;
• Required by Applicable Laws or regulatory authority;
• Curter ceases to offer the Service.

9.4 Effect of Termination

Upon termination, your license to use the Service immediately terminates. Curter will retain User Data for the period required by Applicable Laws and its data retention policies, after which it will be deleted. Sections 6, 7, 10, 11, and 12 shall survive termination.

10. Limitation of Liability & Indemnification

10.1 Disclaimer of Warranties

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, NON-INFRINGEMENT, OR UNINTERRUPTED AVAILABILITY. CURTER DOES NOT WARRANT THAT THE SERVICE WILL BE ERROR-FREE OR THAT DEFECTS WILL BE CORRECTED.

10.2 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, CURTER SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICE, INCLUDING BUT NOT LIMITED TO LOST PROFITS, LOST DATA, REGULATORY PENALTIES, OR REPUTATIONAL HARM, EVEN IF CURTER HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

CURTER'S TOTAL CUMULATIVE LIABILITY ARISING FROM THIS AGREEMENT SHALL NOT EXCEED THE GREATER OF: (A) THE FEES PAID BY YOU IN THE THREE (3) MONTHS PRECEDING THE CLAIM, OR (B) ONE HUNDRED DOLLARS ($100.00).

10.3 Indemnification

You agree to defend, indemnify, and hold harmless Curter and its officers, directors, employees, and agents from and against any claims, liabilities, damages, fines, penalties, and expenses (including reasonable attorneys' fees) arising from:

• Your use of the Service;
• Any User Data you submit;
• Your violation of this Agreement;
• Your violation of any Applicable Laws, including any federal law or regulation;
• Any lending decision made in reliance on Outputs.

11. Regulatory Compliance Acknowledgments

Given that the Service is used in connection with SBA lending and financial services, you specifically acknowledge and agree to the following:

11.1 Compliance with Federal Laws

You are solely responsible for ensuring that your use of the Service and all Outputs comply with all Applicable Laws, including but not limited to:

• SBA Standard Operating Procedures (SOPs), regulations, and program guidelines;
• Gramm-Leach-Bliley Act (GLBA) and related privacy and safeguarding requirements;
• Fair Credit Reporting Act (FCRA);
• Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements;
• Office of Foreign Assets Control (OFAC) requirements;
• Equal Credit Opportunity Act (ECOA), Fair Housing Act, and other fair lending laws;
• Any other federal, state, or local law or regulation applicable to your use of the Service.

Curter is a software tool and is not an SBA-approved lender, agent, or representative.

11.2 No Guarantee of SBA Approval or Regulatory Outcome

Nothing in the Service or any Output constitutes a guarantee, representation, or warranty that any SBA loan application will be approved, that any refinancing opportunity will be successful, or that any particular transaction will meet SBA eligibility requirements or comply with any federal law or regulation.

11.3 Fair Lending

You agree to use the Service in compliance with all applicable fair lending laws, including the Equal Credit Opportunity Act (ECOA) and the Fair Housing Act. You will not use the Service in any manner that results in discriminatory lending practices.

11.4 Bank Secrecy Act / AML

You remain solely responsible for compliance with the Bank Secrecy Act, anti-money laundering (AML) requirements, and related regulations in connection with all transactions processed using the Service.

11.5 GLBA and Data Privacy Compliance

You acknowledge your independent obligation to comply with the Gramm-Leach-Bliley Act and all other federal privacy and data security laws with respect to all customer financial information processed through the Service, including maintaining appropriate safeguards under the FTC Safeguards Rule.

11.6 Audit, Monitoring, and Remediation

Curter reserves the right to monitor your use of the Service for compliance with this Agreement and all Applicable Laws. You agree to cooperate with any audit or review and to promptly remediate any identified compliance issues.

12. General Provisions

12.1 Governing Law

This Agreement shall be governed by and construed in accordance with the federal laws of the United States. To the extent federal law does not apply, the laws of the State of California shall govern, without regard to its conflict of law provisions. Any dispute arising from this Agreement shall be resolved exclusively in the state or federal courts located in Los Angeles County, California, and you consent to the personal jurisdiction of such courts.

12.2 Dispute Resolution

Prior to initiating any legal action, the parties agree to attempt to resolve any dispute through good-faith negotiation for a period of thirty (30) days following written notice of the dispute.

12.3 Class Action Waiver

YOU WAIVE ANY RIGHT TO PARTICIPATE IN A CLASS ACTION LAWSUIT OR CLASS-WIDE ARBITRATION AGAINST CURTER. ALL DISPUTES MUST BE BROUGHT IN YOUR INDIVIDUAL CAPACITY ONLY.

12.4 Entire Agreement

This Agreement, together with the Privacy Policy and any applicable Subscription Terms, constitutes the entire agreement between you and Curter with respect to the Service and supersedes all prior agreements and understandings.

12.5 Severability

If any provision of this Agreement is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

12.6 Waiver

Curter's failure to enforce any provision of this Agreement shall not constitute a waiver of its right to do so in the future.

12.7 Assignment

You may not assign or transfer this Agreement or any rights hereunder without Curter's prior written consent. Curter may assign this Agreement in connection with a merger, acquisition, or sale of substantially all of its assets.

12.8 Contact Information

For questions regarding this Agreement, please contact:

Curter, Inc.
Website: curter.ai
Email: [email protected]

BY USING THE CURTER SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO THIS USER AGREEMENT.

Effective: May 18, 2026 · Version 1.2 · curter.ai
© 2026 Curter, Inc.