Terms & Policies

Terms of Service

CIRCUIT & CHISEL, INC.

Effective date: August 7, 2026

These Terms of Service (“Terms”) are an agreement between Circuit & Chisel, Inc. (“Company,” “we,” “us,” or “our”) and the individual, company, or other entity agreeing to these Terms (“Customer,” “you,” or “your”). Company and Customer are each a “Party” and collectively the “Parties.” These Terms govern Customer’s access to and use of Company’s API platform, including the routing of requests to Third-Party Models via Customer-supplied credentials, and access to the Company’s proprietary model (collectively, the “Services”).

These Terms are effective on the earlier of: (a) the date Customer first electronically consents to a version of these Terms; or (b) the date Customer first accesses the Services (the “Effective Date”).

IMPORTANT. PLEASE READ CAREFULLY:

By clicking “I Agree,” creating an Account, or accessing or using the Services, Customer represents that: (1) it has read, understands, and agrees to be bound by these Terms; (2) Customer is lawfully able to enter into contracts; and (3) the individual accepting these Terms has the legal authority to bind Customer. If Customer does not agree to these Terms, Customer must not access or use the Services.

1. Definitions

Capitalized terms used in these Terms have the meanings set forth below or where they are otherwise defined in these Terms:

1. “Account” means the administrative account created by Customer to access and manage the Services.
2. “Affiliate” means, with respect to either Party, any entity that directly or indirectly controls, is controlled by, or is under common control with that Party.
3. “BYOK Credentials” or “Bring Your Own Key Credentials” means the API keys, authentication tokens, or other access credentials supplied by Customer to enable routing of requests to the applicable Third-Party Provider on Customer’s behalf.
4. “Comparative Analytics” means the periodic performance and cost comparison reports that Company provides to Customer, benchmarking Pareto against the Third-Party Model(s) Customer uses, based on Customer’s own traffic rather than generic or synthetic benchmarks. Comparative Analytics may incorporate the results of a Model-Graded Assessment.
5. “Confidential Information” means any business, technical, or financial information, materials, or other subject matter disclosed by the Discloser to the Recipient that is: (i) identified as confidential at the time of disclosure; or (ii) should reasonably be understood by the Recipient to be confidential under the circumstances. Confidential Information includes Customer Content.
6. “Credits” means the prepaid usage credits that Customer purchases, either on a self-serve basis or through a Company-assisted allocation process, which are applied against Fees incurred for Customer’s use of the Services.
7. “Customer Content” means, collectively, Inputs and Outputs.
8. “Documentation” means the technical documentation, API specifications, user guides, and other materials Company makes generally available to customers describing the features, functionality, and use of the Services.
9. “DPA” means the Data Processing Addendum, available upon request, which is incorporated into these Terms by reference.
10. “Discloser” means the Party disclosing Confidential Information under these Terms.
11. “Feedback” means any suggestions, enhancement requests, recommendations, comments, or other feedback provided by Customer to Company regarding the Services.
12. “Fees” means all amounts payable by Customer for use of the Services, as set forth on the Pricing Page or in an applicable Order Form.
13. “Inputs” means the prompts, queries, data, text, files, or other content submitted by Customer or its Users to the Services for processing.
14. “IP Rights” means all registered or unregistered intellectual property rights throughout the world, including rights in patents, copyrights, trademarks, trade secrets, designs, databases, domain names, and moral rights.
15. “Model-Graded Assessment” means the process by which Company asks the Third-Party Model that Customer already uses (accessed through Customer’s BYOK Credentials) to evaluate and score Outputs generated by Pareto, as one input to Comparative Analytics.
16. “Order Form” means any ordering document or online subscription page executed or accepted by the Parties that references these Terms and specifies the Services, Fees, and other commercial terms applicable to Customer’s use.
17. “Outputs” means the responses, completions, text, data, or other content generated by the Services (whether by Pareto or a Third-Party Model) in response to Customer’s Inputs.
18. “Pareto” means Company’s proprietary blended AI model (or such other name as Company may designate), which combines outputs from multiple underlying large language models (accessed through Company’s own arrangements with the relevant model providers, and not through Customer’s BYOK Credentials) and synthesizes such outputs into a single response, as further described in the Documentation.
19. “Pricing Page” means Company’s then-current pricing page available at https://unbiased.ai/?buy=credits.
20. “Quality Learnings” means the aggregate, cross-customer quality scores, comparison results, and verification data that Company accumulates over time from providing Comparative Analytics (including through Model-Graded Assessments) across its customer base, and uses to develop and improve Pareto and Company’s benchmarking methodology. Quality Learnings are derived data distinct from, and do not include, Customer Content.
21. “Recipient” means the Party receiving Confidential Information under these Terms.
22. “Routing Configuration” means the settings, parameters, or preferences that Customer establishes (or that apply by default) to control the proportion of Customer’s request traffic that Company routes to Pareto versus to Third-Party Models via BYOK Credentials, including any dynamic routing feature that directs individual requests to whichever model Company’s routing logic determines is best suited for that request.
23. “Services” means Company’s API platform and related tools, documentation, and services made available to Customer, including: (a) the routing infrastructure that transmits Customer’s authenticated requests to Third-Party Providers using BYOK Credentials; (b) access to Pareto; (c) the Comparative Analytics functionality; and (d) the Routing Configuration and dynamic routing functionality described in Section 2(f).
24. “Third-Party Model” means any large language model or artificial intelligence model operated by a Third-Party Provider and accessible through the Services via Customer’s BYOK Credentials.
25. “Third-Party Provider” means any third-party provider of AI models or related services (e.g., Anthropic, OpenAI) whose models Customer may access through the Services using BYOK Credentials.
26. “Usage Data” means metadata, telemetry, and aggregated or de-identified usage and performance statistics relating to Customer’s use of the Services, including request volumes, latency measurements, error rates, token consumption, model selection patterns, and cost data. Usage Data does not include Customer Content or any information from which specific Inputs or Outputs can be identified or reconstructed.
27. “Usage Policy” means Company’s Acceptable Use Policy available at unbiased.ai/usage-policy/, as updated from time to time.
28. “Users” means Customer’s employees, contractors, agents, or other individuals authorized by Customer to access or use the Services under Customer’s Account.

2. Services and License Grants

2(a) Overview of Services. Subject to Customer’s compliance with these Terms, Company grants Customer a non-exclusive, non-transferable, non-sublicensable right to access and use the Services during the Term.

2(b) BYOK Pass-Through. Company acts solely as a conduit, routing Customer’s authenticated API requests to Third-Party Providers using BYOK Credentials. Company is not a party to Customer’s agreements with Third-Party Providers and makes no representations regarding Third-Party Models. Customer is solely responsible for: (i) obtaining and maintaining valid BYOK Credentials; (ii) complying with all Third-Party Provider terms; (iii) all fees charged by Third-Party Providers; and (iv) confirming that its use of the Services is permitted under applicable Third-Party Provider terms. Company encrypts BYOK Credentials at rest, never retains BYOK Credentials in plaintext, and scopes access to BYOK Credentials solely to the active session in which they are used to route Customer’s requests to the applicable Third-Party Provider.

2(c) Pareto License. Company grants Customer a non-exclusive, non-transferable right to use Pareto through the Services during the Term, subject to any rate limits or restrictions in the Documentation. Company may update Pareto from time to time; if an update will materially reduce functionality, Company will provide Customer at least thirty (30) days’ prior notice before implementing the update. Customer acknowledges that Pareto blends outputs from multiple underlying models, and Company may modify the composition of underlying models without notice provided functionality is not materially reduced.

2(d) Account. Customer must create an Account to use the Services. Customer is responsible for: (i) maintaining the accuracy of its Account information; (ii) safeguarding its Account credentials and BYOK Credentials; (iii) all activity that occurs under its Account; and (iv) promptly notifying Company of any unauthorized access to or use of its Account.

2(e) Documentation. Company will make Documentation available describing the features, functionality, and technical requirements of the Services. Customer’s use of the Services is subject to any applicable technical limitations described in the Documentation.

2(f) Routing Configuration. Customer may configure, through its Account settings or an applicable Order Form, the Routing Configuration governing the proportion of Customer’s request traffic that Company routes to Pareto versus Third-Party Models via BYOK Credentials. Where Customer enables Company’s dynamic routing feature, Company may automatically direct individual requests to whichever available model Company’s routing logic determines is best suited for that request, based on factors such as historical performance, cost, and task type, and will identify to Customer through the Services which model processed a given request. Customer may adjust or disable dynamic routing at any time. Company’s routing decisions under this Section 2(f) do not affect Customer’s ownership of Outputs under Section 5(a) or Section 7(b), regardless of which model generated the Output.

3. Analysis

3(a) Comparative Analytics. Company will provide Customer with Comparative Analytics on an ongoing basis, using Customer’s own traffic rather than a generic or synthetic benchmark. Comparative Analytics are derived from Usage Data (not Customer Content), except to the extent Customer opts into a Model-Graded Assessment under Section 3(b), which evaluates Outputs, and are intended to help Customer evaluate Pareto’s performance and cost efficiency relative to the Third-Party Model(s) Customer uses.

3(b) Model-Graded Assessment. Where Customer opts in, Company may use Customer’s BYOK Credentials to have the Third-Party Model evaluate and score Pareto Outputs. Customer may disable this feature at any time. Because Model-Graded Assessment uses Customer’s Third-Party Provider account, Customer is responsible for confirming this use is permitted under the applicable Third-Party Provider’s terms.

3(c) Public Benchmark Data. Company may also publish general performance and cost benchmarks comparing Pareto to other models, based on Company’s own testing methodology and selected tasks. These published benchmarks reflect Company’s own test conditions and are not a guarantee of the results Customer will experience on its own workloads.

4. Acceptable Use

4(a) Compliance. Each Party will comply with all laws applicable to the provision (for Company) and use (for Customer) of the Services, including any applicable data privacy laws. Customer will ensure that its Users comply with these Terms and the Usage Policy.

4(b) Usage Policy. Customer and its Users may only use the Services in compliance with these Terms and the Usage Policy, which is incorporated into these Terms by reference. Company may update the Usage Policy from time to time with reasonable notice to Customer. Customer must cooperate with reasonable requests from Company to verify compliance with the Usage Policy.

4(c) Restrictions. Customer will not, and will not permit any User or third party to:

1. use the Services in a way that violates applicable laws or third parties’ rights;
2. access the Services to build a competing product or service, including to train competing artificial intelligence models, or resell the Services except as expressly approved by Company in writing;
3. reverse engineer, decompile, disassemble, or otherwise attempt to discover the source code, algorithms, or underlying components of the Services or Pareto, except to the extent such restrictions are prohibited by applicable law;
4. use Outputs to develop, train, or fine-tune any artificial intelligence or machine learning model that competes with Pareto or the Services;
5. extract data from the Services other than as permitted through the Services’ normal functionality;
6. interfere with or disrupt the Services, including circumventing any rate limits, usage quotas, or other restrictions or protective measures applied to the Services;
7. share, sell, transfer, or sublicense Account credentials to or with any third party;
8. use the Services to generate content that infringes, misappropriates, or otherwise violates any third party’s IP Rights;
9. send automated queries to the Services at a volume or frequency that exceeds the limits set forth in the Documentation or Order Form, or that degrades the Services for other customers; or
10. use the Services in connection with any application or system where the use or failure of the Services could reasonably be expected to result in physical harm, loss of life, or catastrophic damage.

4(d) Limitations of Outputs; No Reliance. It is Customer’s responsibility to evaluate whether Outputs are appropriate for Customer’s use case, including determining where human review is appropriate before using or sharing Outputs. Customer acknowledges that: (i) Outputs may not be unique and other customers may receive similar or identical content; (ii) factual assertions in Outputs should not be relied upon without independent verification, as they may be inaccurate, incomplete, or misleading; and (iii) Outputs do not constitute legal, financial, medical, or professional advice.

5. Customer Content and Data Retention

5(a) Ownership of Customer Content. As between the Parties, and to the extent permitted by applicable law: (i) Customer retains all ownership rights in Inputs; and (ii) Customer owns all Outputs. Company hereby assigns to Customer all right, title, and interest (if any) in and to Outputs. Customer acknowledges that, due to the nature of the Services and artificial intelligence generally, Output may not be unique, and other customers may receive similar content from the Services. Outputs generated for other customers are not considered Customer’s Output.

5(b) Customer Obligations. Customer represents and warrants that it has all rights, licenses, and permissions required to provide Inputs to the Services. Customer is solely responsible for all use of Outputs and for evaluating the accuracy and appropriateness of Outputs for Customer’s use case.

5(c) Data Use and Retention. Company will not retain Customer Content beyond the time reasonably necessary to process Customer’s request and return the applicable Output, except as required by law or as necessary for abuse prevention and security monitoring for a period not to exceed thirty (30) days. Company will not use Customer Content to train, fine-tune, or improve any model unless Customer provides explicit written consent.

5(d) Usage Data. Company may collect, retain, and use Usage Data to operate the Services, generate Comparative Analytics, and improve Company’s products. Usage Data does not include Customer Content or information that can identify specific Inputs or Outputs.

5(e) Third-Party Provider Data Practices. When Customer routes requests through the Services using BYOK Credentials, any data retention, training, or use practices applied by the Third-Party Provider are governed solely by that provider’s terms. Company has no control over Third-Party Provider data practices. Customer is solely responsible for reviewing and complying with applicable Third-Party Provider terms.

5(f) Data Privacy. If Customer uses the Services to process Personal Data (as defined in the DPA), Company and Customer will comply with the DPA, which is incorporated into these Terms by reference.

5(g) Beta Services. Company may make features or services available on a beta, preview, or early-access basis (“Beta Services”). Beta Services are provided “AS IS” without any warranty, service level commitment, or indemnification obligation. Beta Services may be modified or discontinued at any time without notice. Customer’s use of Beta Services is at Customer’s sole risk.

6. Fees, Billing, and Taxes

6(a) Fees. Customer will pay Company the applicable Fees for the Services at the rates specified on the Pricing Page or in an applicable Order Form. Fees are based on Customer’s actual usage of the Services (including API call volume and token consumption for Pareto) as calculated by Company’s metering systems, unless a different billing basis is specified in an Order Form. Fees are non-cancellable and non-refundable.

6(b) Invoicing and Payment. Company will invoice Customer as specified in Order Form, or at time of purchase. Customer will pay all undisputed invoices within 30 days of the invoice date. Customer will provide complete and accurate billing information and will promptly update such information as necessary.

6(c) Taxes. Fees are exclusive of all taxes, duties, or assessments that may be owed by Customer for use of the Services (“Taxes”), unless otherwise specified in the applicable invoice. Customer is responsible for remitting any necessary withholding Taxes to the relevant authority on a timely basis and providing Company with evidence of the same upon request. Where law provides for the reduction or elimination of withholding taxes, including via tax treaty, the Parties will collaborate in good faith to do so. If any deduction or withholding is required by law, Customer will increase the payment to Company so that Company receives the same total amount it would have received absent such withholding or reduction (a “Gross-up Payment”).

6(d) Invoice Disputes. To dispute an invoice, Customer must: (i) notify Company in writing at billing@unbiased.ai within thirty (30) days of the invoice date, specifying the disputed amount and the basis for the dispute in reasonable detail; and (ii) pay all undisputed amounts by the applicable due date. The Parties will work in good faith to resolve any disputed amounts. Overdue undisputed amounts may be subject to a finance charge of 1.5% per month (or the maximum rate permitted by law, whichever is less).

6(e) Suspension for Non-Payment. If Customer fails to pay undisputed Fees when due and such failure continues for more than fifteen (15) days after written notice from Company, Company may suspend Customer’s access to the Services until all outstanding amounts are paid in full. Suspension under this Section does not relieve Customer of its payment obligations.

6(f) Pricing Changes. Company may update Fees by posting updated pricing to the Pricing Page, to be effective the earlier of: (a) thirty (30) days after the update is posted; or (b) the date Customer receives written notice of the change. Pricing changes will not apply retroactively to usage incurred prior to the effective date of the change.

6(g) Credits. Customer may purchase Credits on a self-serve basis or through a Company-assisted allocation process sized to Customer’s expected usage volume. Credits are applied against Fees as Customer consumes the Services and are non-refundable and non-transferable except as required by law. Unless otherwise specified in an Order Form, Credits do not expire.

7. Intellectual Property

7(a) Reservation of Rights. Except as expressly set forth in these Terms, these Terms do not grant either Party any rights to the other’s content or intellectual property, by implication or otherwise. Customer obtains only a limited right to use the Services as described herein, and no ownership rights in the Services are transferred to Customer.

7(b) Customer Ownership of Content. As between the Parties: (i) Customer retains all IP Rights in Inputs; and (ii) Customer owns all IP Rights in Outputs. To the extent Company may hold any right, title, or interest in or to Outputs, Company hereby irrevocably assigns such rights to Customer. This assignment is subject to Customer’s compliance with these Terms and Customer’s payment of applicable Fees. For clarity, Customer’s ownership under this Section 7(b) is limited to Inputs and Outputs and does not extend to Quality Learnings, which are owned exclusively by Company as set forth in Section 7(f).

7(c) Limited License to Company. Customer grants Company a non-exclusive, worldwide, royalty-free license to use Customer Content solely to the extent necessary to: (i) provide, operate, and maintain the Services, including transmitting Inputs to the applicable model and delivering Outputs to Customer; (ii) enforce these Terms and the Usage Policy, including detecting and preventing abuse; (iii) comply with applicable law; and (iv) generate Usage Data, Comparative Analytics, and Quality Learnings in accordance with Section 5(d) and Section 7(f).

7(d) Company IP. Company retains all IP Rights in and to the Services, Pareto, the Comparative Analytics methodology, Usage Data, Quality Learnings, and all improvements, modifications, and derivative works thereof. Nothing in these Terms transfers ownership of any Company IP to Customer.

7(e) Feedback. If Customer provides Feedback to Company, Customer grants Company an irrevocable, perpetual, worldwide, royalty-free, fully sublicensable license to use, reproduce, modify, and incorporate such Feedback into Company’s products and services without restriction or obligation to Customer.

7(f) Ownership of Quality Learnings. As between the Parties, Company exclusively owns all Quality Learnings. Quality Learnings are derived data generated by Company’s scoring and benchmarking methodology and do not include, and may not be used to reconstruct, Customer’s Inputs, Outputs, or other Customer Content. Company’s generation of Quality Learnings is limited to scoring, benchmarking, and comparative evaluation of Outputs, and Company will not use Outputs generated by a Third-Party Model to train or fine-tune Pareto or any other model. Customer retains no ownership or license rights in Quality Learnings, and Company may use, retain, disclose in aggregated or de-identified form, and commercially exploit Quality Learnings without restriction and without further consent from or compensation to Customer, provided that Company will not disclose Quality Learnings in a manner that identifies Customer or reveals Customer’s Confidential Information.

8. Confidentiality

8(a) Obligations. The Recipient will: (i) use the Discloser’s Confidential Information only to exercise its rights and perform its obligations under these Terms; (ii) take reasonable measures to protect the Confidential Information from unauthorized use, access, or disclosure, using at least the same degree of care it uses to protect its own confidential information of similar nature (but no less than reasonable care); and (iii) not disclose the Confidential Information to any third party except as expressly permitted in these Terms.

8(b) Exceptions. Confidential Information does not include information that: (i) is or becomes publicly available through no fault of the Recipient; (ii) was in the Recipient’s possession or known by it prior to receipt from the Discloser, without breach of any obligation of confidentiality; (iii) is rightfully obtained by the Recipient from a third party without restriction on disclosure and without breach of the third party’s obligations of confidentiality; or (iv) is independently developed by the Recipient without use of or reference to the Discloser’s Confidential Information.

8(c) Permitted Disclosure. The Recipient may disclose Confidential Information to its employees, agents, contractors, and advisors who have a need to know such information and who are bound by obligations of confidentiality at least as protective as those provided in these Terms. The Recipient is responsible for all acts and omissions of such persons with respect to Confidential Information.

8(d) Compelled Disclosure. The Recipient may disclose Confidential Information to the extent required by applicable law, regulation, or court or administrative order, provided that the Recipient: (i) provides the Discloser with prompt written notice of such requirement (to the extent legally permitted); (ii) cooperates with the Discloser’s efforts to seek a protective order or other appropriate remedy; and (iii) discloses only that portion of the Confidential Information that is legally required.

8(e) Return or Destruction. Upon the Discloser’s written request or upon termination of these Terms, the Recipient will promptly destroy or return all copies of the Discloser’s Confidential Information in its possession or control, except: (i) copies retained in the Recipient’s automated back-up or archival systems, which will remain subject to the confidentiality obligations herein for so long as they are maintained; and (ii) copies required to be retained by applicable law. The Recipient will certify destruction in writing upon the Discloser’s reasonable request.

9. Warranties and Disclaimers

9(a) Mutual Warranties. Each Party represents and warrants that: (i) it is duly organized and validly existing under the laws of its jurisdiction; (ii) it has full power and authority to enter into these Terms; and (iii) these Terms constitute a valid and binding obligation of such Party.

9(b) Customer Warranties. Customer further represents and warrants that: (i) it has all rights and permissions required to provide Inputs to the Services; (ii) its use of the Services will comply with all applicable laws and the Usage Policy; and (iii) to the extent Customer provides BYOK Credentials, such provision does not violate Customer’s agreement with the applicable Third-Party Provider.

9(c) Limited Service Warranty. Company warrants that, during the Term, when used in accordance with these Terms, the Services will perform in all material respects in conformity with the Documentation. Customer’s sole remedy for breach of this warranty is, at Company’s option: (i) correction of the non-conformity; or (ii) if correction is not commercially practicable within thirty (30) days, termination of the affected Services and a pro-rata refund of prepaid Fees.

9(d) Disclaimers. EXCEPT AS EXPRESSLY SET FORTH IN THIS SECTION, THE SERVICES AND ALL OUTPUTS ARE PROVIDED “AS IS” WITHOUT WARRANTY OF ANY KIND. COMPANY DISCLAIMS ALL IMPLIED WARRANTIES, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. COMPANY DOES NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED, ERROR-FREE, OR THAT OUTPUTS WILL BE ACCURATE OR COMPLETE. COMPANY MAKES NO REPRESENTATIONS OR WARRANTIES REGARDING ANY THIRD-PARTY MODEL OR THIRD-PARTY PROVIDER. OUTPUTS MAY CONTAIN INACCURACIES AND SHOULD NOT BE RELIED UPON WITHOUT INDEPENDENT VERIFICATION. COMPANY’S PUBLISHED BENCHMARKS DO NOT GUARANTEE RESULTS FOR CUSTOMER’S WORKLOADS.

10. Indemnification

10(a) Indemnification by Company. Company will defend Customer and its officers, directors, employees, and agents from and against any third-party claim, suit, or proceeding (a “Customer Claim”) alleging that Customer’s authorized use of Pareto or Outputs generated by Pareto in accordance with these Terms infringes or misappropriates any third-party IP Right, and will indemnify Customer for any damages, costs, and reasonable attorneys’ fees finally awarded against Customer (or amounts agreed to in a Company-approved settlement) arising from such Customer Claim.

10(b) Exclusions from Company Indemnity. Company’s obligations under Section 10(a) will not apply to the extent a Customer Claim arises from: (i) modifications made by Customer to the Services or Outputs; (ii) the combination of the Services or Outputs with technology, content, or materials not provided by Company; (iii) Customer’s Inputs or other data provided by Customer; (iv) Customer’s use of the Services in violation of these Terms or the Documentation; (v) use of the Services after Company has notified Customer to cease such use due to an infringement claim; (vi) the practice of a patented invention contained in an Output; or (vii) use of a Third-Party Model (claims related to Third-Party Models are subject to the applicable Third-Party Provider’s terms).

10(c) Mitigation. If Company reasonably believes that the Services or any portion thereof may become the subject of an infringement claim, Company will, at its expense: (i) procure the right for Customer to continue using the Services in accordance with these Terms; (ii) replace or modify the allegedly infringing component so that it is non-infringing without materially reducing functionality; or (iii) if (i) and (ii) are not commercially practicable, terminate the affected Services upon written notice and refund any prepaid Fees for the unused portion of the then-current Term.

10(d) Indemnification by Customer. Customer will defend Company and its officers, directors, employees, and agents from and against any third-party claim, suit, or proceeding (a “Company Claim”) arising from or related to: (i) Customer’s Inputs or other content or data provided by Customer; (ii) Customer’s or its Users’ use of the Services in violation of these Terms, the Usage Policy, or applicable law; (iii) Customer’s BYOK Credentials or Customer’s relationship with any Third-Party Provider, including any claim by a Third-Party Provider that Customer’s provision of BYOK Credentials to Company, use of the Services, or enablement of Model-Graded Assessment violates Customer’s agreement with that Third-Party Provider; or (iv) any Customer application, product, or service that Customer builds using the Services and that causes harm to a third party. Customer will indemnify Company for any damages, costs, and reasonable attorneys’ fees finally awarded against Company (or amounts agreed to in a Customer-approved settlement) arising from such Company Claim.

10(e) Procedure. The indemnified party will: (i) provide the indemnifying party with prompt written notice of any Claim (provided that failure to provide timely notice will not relieve the indemnifying party of its obligations except to the extent it is materially prejudiced by such failure); and (ii) reasonably cooperate in the defense of the Claim. The indemnifying party will have sole control of the defense and settlement of any Claim, including the selection of counsel; provided that the indemnifying party may not enter into any settlement that requires the indemnified party to admit wrongdoing, make any payment, or subjects the indemnified party to an ongoing affirmative obligation, without the indemnified party’s prior written consent (not to be unreasonably withheld).

10(f) Sole Remedy. To the extent covered under this Section 10, indemnification is each Party’s sole and exclusive remedy under these Terms for any third-party claims covered by this Section.

11. Limitation of Liability

11(a) Exclusion of Indirect Damages. TO THE FULLEST EXTENT PERMITTED BY LAW, EXCEPT FOR: (A) A PARTY’S GROSS NEGLIGENCE OR WILLFUL MISCONDUCT; (B) A PARTY’S BREACH OF SECTION 8 (CONFIDENTIALITY); OR (C) CUSTOMER’S BREACH OF SECTION 4(c) (RESTRICTIONS); NEITHER PARTY NOR ITS AFFILIATES OR LICENSORS WILL BE LIABLE UNDER THESE TERMS FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING DAMAGES FOR LOST PROFITS, LOST REVENUE, LOSS OF BUSINESS, LOSS OF DATA, LOSS OF GOODWILL, BUSINESS INTERRUPTION, OR COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE), EVEN IF THE PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES AND EVEN IF A REMEDY FAILS OF ITS ESSENTIAL PURPOSE.

11(b) Liability Cap. TO THE FULLEST EXTENT PERMITTED BY LAW, EXCEPT FOR: (A) A PARTY’S GROSS NEGLIGENCE OR WILLFUL MISCONDUCT; (B) A PARTY’S INDEMNIFICATION OBLIGATIONS UNDER SECTION 10; (C) CUSTOMER’S PAYMENT OBLIGATIONS; OR (D) A PARTY’S BREACH OF SECTION 8 (CONFIDENTIALITY); OR (E) CUSTOMER’S BREACH OF SECTION 4(c) (RESTRICTIONS); EACH PARTY’S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THESE TERMS WILL NOT EXCEED TOTAL FEES PAID OR PAYABLE BY CUSTOMER DURING THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO LIABILITY.

11(c) Basis of the Bargain. The Parties agree that they have entered into these Terms in reliance on the limitations and exclusions of liability set forth in this Section 11, and that these provisions form an essential basis of the bargain between the Parties. The limitations of liability in this Section 11 apply: (i) to the maximum extent permitted by applicable law; (ii) to liability in tort (including negligence), contract, strict product liability, or otherwise; (iii) regardless of the form of action; and (iv) even if the breaching Party is advised in advance of the possibility of the damages in question and even if such damages were foreseeable.

12. Term, Suspension, and Termination

12(a) Term. These Terms commence on the Effective Date and continue until terminated in accordance with this Section 12 (the “Term”).

12(b) Termination for Cause. Either Party may terminate these Terms upon written notice if the other Party: (i) materially breaches these Terms and fails to cure such breach within thirty (30) days after receipt of written notice specifying the breach in reasonable detail; or (ii) ceases its business operations, becomes subject to insolvency proceedings, makes an assignment for the benefit of creditors, or is otherwise unable to meet its obligations as they become due.

12(c) Immediate Termination. Company may terminate these Terms immediately upon written notice if: (i) Company reasonably determines that provision of the Services to Customer is prohibited by applicable law; or (ii) Customer commits a material breach of Section 4(c) (Restrictions), Section 8 (Confidentiality), or the Usage Policy that is incapable of cure.

12(d) Suspension. Company may limit or suspend Customer’s access to all or any portion of the Services, without liability, if: (i) Company reasonably believes there is a security risk or threat to the integrity of the Services; (ii) Customer or any User is in material violation of these Terms, the Usage Policy, or applicable law; (iii) a Third-Party Provider suspends or terminates Company’s access to a service required to provide the Services; or (iv) suspension is required by applicable law or by order of a governmental authority.

12(e) Effect of Termination. Upon termination or expiration of these Terms:

1. all rights and licenses granted to Customer under these Terms will immediately cease;
2. Customer will immediately cease all use of the Services and, if applicable, delete or remove any Company Confidential Information in its possession;
3. Company will delete all Customer Content from its systems within thirty (30) days of the effective date of termination, consistent with the data retention commitment in Section 5(c), unless: (A) Company is required by applicable law to retain such content; or (B) Customer Content is subject to the limited retention exception at the time of termination, in which case such content will be deleted in accordance with the timelines specified therein;
4. any accrued payment obligations and any rights or obligations that by their nature should survive termination will survive; and
5. except for a termination by Customer for cause, any unpaid Fees for the remainder of the then-current Term (if applicable under an Order Form with a minimum commitment) will become immediately due and payable.

12(f) Survival. The following Sections will survive termination or expiration of these Terms: Section 1 (Definitions), Section 5(a) (Ownership of Customer Content), Section 5(c) (Data Use and Retention), Section 6 (Fees, to the extent of accrued obligations), Section 7 (Intellectual Property), Section 8 (Confidentiality), Section 9 (Warranties and Disclaimers), Section 10 (Indemnification), Section 11 (Limitation of Liability), Section 12(e) (Effect of Termination), Section 12(f) (Survival), Section 13 (Dispute Resolution), and Section 14 (General).

13. Dispute Resolution

13(a) Informal Resolution. In the event of any dispute, claim, or controversy arising out of or relating to these Terms (a “Dispute”), the Parties will first attempt in good faith to resolve the Dispute informally. The Party raising the Dispute will provide written notice to the other Party describing the nature of the Dispute and the relief sought (a “Dispute Notice”). The Parties will negotiate in good faith for a period of forty-five (45) days following delivery of the Dispute Notice. If the Parties are unable to resolve the Dispute within such period, either Party may proceed to litigation as set forth in Section 13(b).

13(b) Exclusive Jurisdiction. Subject to Section 13(a), any Dispute that cannot be resolved informally will be resolved exclusively in the federal or state courts located in Delaware. Each Party irrevocably submits to the exclusive jurisdiction of such courts, waives any objection to venue in such courts, and waives any claim that such courts are an inconvenient forum.

14. General Provisions

14(a) Governing Law. These Terms will be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict-of-laws principles.

14(b) Notices. All notices, demands, waivers, and other communications under these Terms (each, a “Notice”) must be in writing. Except for notices related to legal proceedings or equitable relief, Notices may be delivered: (i) by email to the address associated with Customer’s Account (for notices to Customer) or to the address specified below (for notices to Company); (ii) by nationally recognized overnight courier; or (iii) by first class, registered, or certified mail, postage prepaid. Notice is effective upon receipt by the receiving party, provided that the sending party has complied with the requirements of this Section.

Notices to Company:

Circuit & Chisel, Inc.

Address: 268 Post Road STE 200 PMB 586312, Fairfield, CT 06824

Email: legal@circuitandchisel.com

14(c) Entire Agreement. These Terms, together with any Order Forms, the Usage Policy, the DPA, and any other documents expressly incorporated by reference, constitute the entire agreement between the Parties with respect to the subject matter hereof and supersede all prior or contemporaneous agreements, understandings, negotiations, and communications, whether written or oral. Any terms or conditions contained in any purchase order, confirmation, or similar document issued by Customer are null and void and will have no effect.

14(d) Amendments and Updates. Company may update these Terms by posting the updated Terms on its website. If Company determines that an update materially affects Customer’s rights, Company will provide at least thirty (30) days’ prior notice. Updates will not apply retroactively. Customer’s continued use of the Services after the effective date of an update constitutes acceptance. No other amendment will be effective unless in writing and signed by both Parties.

14(e) Assignment. Neither Party may assign these Terms without the other Party’s prior written consent, except that either Party may assign to an Affiliate or to a successor in connection with a merger, acquisition, or sale of substantially all of its assets, upon thirty (30) days’ prior written notice. These Terms will bind and inure to the benefit of the Parties and their permitted successors and assigns.

14(f) Severability; Waiver; Construction. If any provision of these Terms is found unenforceable, it will be modified to the minimum extent necessary to make it enforceable, and the remaining provisions will remain in full force. A waiver of any default is not a waiver of any subsequent default. The failure to enforce any provision will not constitute a waiver. These Terms will be interpreted fairly without strict construction in favor of or against either Party. Section headings are for reference only.

14(g) Independent Contractors; No Third-Party Beneficiaries. The Parties are independent contractors and nothing in these Terms creates any agency, partnership, or employment relationship. Neither Party has the authority to bind the other. These Terms are for the sole benefit of the Parties and their permitted successors and assigns; nothing herein confers any right upon any third party.

14(h) Force Majeure. Except for payment obligations, neither Party will be liable for failures or delays resulting from events beyond its reasonable control, including acts of God, pandemics, war, government actions, or telecommunications failures (“Force Majeure Event”). If a Force Majeure Event continues for more than sixty (60) days, either Party may terminate upon written notice.

14(i) Export Controls and Sanctions. Customer is solely responsible for ensuring that its use of the Services complies with all applicable export control laws and trade sanctions. Customer represents that it is not located in any U.S.-sanctioned country, is not on any Restricted Party List, and will not use the Services in violation of export control laws.

14(j) Electronic Communications. Customer agrees that these Terms may be accepted electronically and that such acceptance constitutes Customer’s legally binding signature. Customer agrees to receive all communications related to these Terms electronically.

Privacy Policy

Circuit & Chisel, Inc.

Privacy Policy

Effective as of: June 17, 2026

This Privacy Policy describes how Circuit & Chisel, Inc. ("Circuit & Chisel, Inc.", "we", "us" or "our") processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the "Service"). Circuit & Chisel, Inc. may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

For clarity, this Privacy Policy does not apply to any decentralized aspect of the blockchain that we do not control due to the decentralized nature of such services.

European Users: Please see the Notice to European Users section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as "Europe", and "European" should be understood accordingly).

Personal information we collect

Information you provide to us or that we may generate about you. Personal information you may provide to us through the Service or otherwise or that we may generate about you includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.

• Demographic data, such as your city, state, country of residence, postal code, and age.

• Profile data, such as the username and password that you may set to establish an account on the Service, date of birth, redemption code, biographical details, photograph or picture, links to your profiles on social networks, interests, preferences, information about your participation in the Service, communicate with us via the app's chat features, social media, or otherwise.

• Transactional data, such as information relating to or needed to complete your orders on or through the Service.

• Blockchain activity data, such as information relating to or needed to complete your cryptocurrency transactions on or through the Service (including wallet address, transaction number, transaction sender and recipient, transaction amount), as well as information relating to other on-chain activity associated with your account or wallet, such as applications or smart contracts you have interacted with on the blockchain.

• Financial data, such as your digital currency or wallet account balance and other associated information.

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• Derived data, such as information derived from your use of the Services. For example, we may infer your geolocation, income, or the type of linked third party service.

• User-generated content data, such as inputs, outputs, photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.

• Data providers, such as information services and data licensors.

• Partners, such marketing partners and event co-sponsors.

• Service providers that provide services on our behalf or help us operate the Service or our business.

• Third-party services, such as linked wallets that you use to log into or otherwise link to your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) - we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

Tracking and other technologies

Cookies and similar technologies. Some of the automatic collection described above is facilitated by cookies and other similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide the Service and operate our business;
• enable security features of the Service;
• establish and maintain your user profile on the Service;
• facilitate your invitations to friends who you want to invite to join the Service;
• facilitate social features of the Service, such as providing chat or messaging functionality;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or contests in which you participate; and
• provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

• understand your needs and interests;
• personalize your experience with the Service and our Service-related communications; and
• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.

• Interest-based advertising. We and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the Tracking technologies section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

Events, promotions and contests. We may use your personal information to:

• administer promotions and contests
• communicate with you about promotions or contests in which you participate
• contact or market to you after collecting your personal information at an event

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events - for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and similar technologies. In addition to the other uses included in this section, we may use Cookies and similar technologies - for more information, see our Cookie Policy.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, chat functionality providers, email delivery, marketing, consumer research and website analytics).

Payment processors. Any payment information you use to make a purchase on the Service is collected and processed directly by our payment processors, including MoonPay. You can view MoonPay's privacy policy here: https://www.moonpay.com/legal/privacy_policy.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so, such as third parties who you direct the Service to pay or with whom to otherwise engage in a transaction.

Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a wallet provider or other third-party service, we may share your personal information with that third-party service. The third party's use of the shared information will be governed by its privacy practices and the settings associated with your account with the third-party service. When you provide login data or other information needed to connect your accounts, you give Circuit & Chisel, Inc. permission and authority to act on your behalf to access and transmit data (including personal information) to and from the linked third-party services.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of Circuit & Chisel, Inc., public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Circuit & Chisel, Inc. as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Due to the nature of blockchain technologies, any data posted to or otherwise interacting with public blockchains will be visible to other users of the Service and the public. Information about your interactions and/or transactions will be provided to the applicable blockchain network and may be accessible to third parties due to the blockchain protocol's nature. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. It may be possible for someone to identify you through your pseudonymous, public wallet address using external information sources, and any transaction you enter or otherwise interact with the blockchain could possibly be used to identify you or information about you.

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and other technologies. For more information about cookies and similar technologies employed by the Service and how to manage your preferences, see our Cookie Policy.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit https://www.allaboutdnt.com.

Linked third-party services. If you choose to connect to the Service through your wallet or other third-party service, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should also read the information provided about transfers of personal information to recipients outside Europe contained in the Notice to European Users section below.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you depending upon applicable law, please contact us.

Email: legal@circuitandchisel.com

Notice to European users

Where this Notice to European users applies. The information provided in this 'Notice to European users' section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., "Europe" as defined at the top of this Privacy Policy).

Personal information. References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" as defined in the "GDPR" (i.e., the General Data Protection Regulation 2016/679 ("EU GDPR")) and the EU GDPR as it forms part of the laws of the United Kingdom ("UK GDPR") Under the GDPR, "personal data" means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section Personal Information we collect that is set out above.

Controller. Circuit & Chisel, Inc. is the "controller" in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the How to contact us section above for our contact details.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR - you can contact them directly:

Our Representative in the EU

Our EU representative appointed under the EU GDPR is European Data Protection Office (EDPO). You can contact them:

• By using EDPO's online request form: https://edpo.com/gdpr-data-request/
• By postal mail to: Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Our Representative in the UK

Our UK representative appointed under the UK GDPR is EDPO UK Ltd. You may contact EDPO UK regarding matters relating to the UK GDPR and/or complaints under section 164A of the Data Protection Act 2018 ("DPA 2018") as amended by the Data (Use and Access) Act 2025 ("DUAA"). You can contact them:

• By using EDPO's online request and complaint form: https://edpo.com/uk-gdpr-data-request/.
• By postal mail to: Unit 33, Waterside, Schooner Court, 44-48 Wharf Road, London, N1 7UX, United Kingdom

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a "legal basis" for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

• Where we need to process your personal information in order to deliver the Service to you, or where you have asked us to take specific action which requires us to process your personal information ("Contractual Necessity").

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests"). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.

• Where we need to comply with a legal or regulatory obligation ("Compliance with Law").

• Where we have your specific consent to carry out the processing for the Purpose in question ("Consent").

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see the How we use your personal information section above and the description of associated data sharing relevant to such purposes set out in the How we share your personal information section also above.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or otherwise for the ‘Compliance and protection’ purposes outlined above.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information that we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.

No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any such sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your additional rights

General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.

• Correct. Update or correct inaccuracies in your personal information.

• Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.

• Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.

• Object. Object to our processing of your personal information where we are relying on Legitimate Interests - you also have the right to object where we are processing your personal information for direct marketing purposes.

• Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area

The contact information for the data protection regulator in your place of residence can be found here: https://www.edpb.europa.eu/about-edpb/our-members_en

For users in the UK

The contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

Data processing outside of Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

• Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.

• Transfers to territories without an adequacy decision.

  • We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S.).

  • However, in these cases:

    • we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe - for example, standard-form contracts approved by relevant authorities for this purpose; or

    • in limited circumstances, we may rely on an exception, or 'derogation', which permits us to transfer your personal information to such country despite the absence of an 'adequacy decision' or 'appropriate safeguards' - for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

Unbiased Data Policy

This page explains the Pareto-specific practices that sit alongside the Circuit & Chisel, Inc. Privacy Policy and Terms.

What the service processes

• API credentials. Today's public checkout does not require a third-party provider key. If a separate comparison evaluation does, the key-handling terms and controls will be disclosed before it is provided.
• API call content. Prompts and Pareto responses pass through Circuit & Chisel infrastructure to operate the guided evaluation.
• Comparison workflows. If separately agreed during onboarding, prompts and responses may be evaluated against another model under disclosed handling terms.
• Comparison data. Quality scores, workload classifications, model identifiers, cost metadata, and other derived evaluation data may be retained to produce an agreed evaluation report and improve the service.
• Usage metadata. Timestamps, model identifiers, token counts, latency, workload class, and cost may be collected for service operation, billing, and reporting.
• Account and payment information. Circuit & Chisel uses account information to provision access. Stripe processes payment information; Circuit & Chisel does not store raw card data.

How data is used

• Operate Pareto access, agreed evaluation workflows, reporting, billing, and account provisioning.
• Use derived quality and workload data to improve comparisons and the service.
• Comply with applicable law and valid legal process.

What we do not do

• We do not sell member data.
• We do not use member call content for advertising.
• We do not train Pareto on raw member prompts or responses without explicit member consent.
• We do not share member data except with service providers needed to operate the service or as required by law.

Access and security

Do not send provider credentials through the public contact form. Before any evaluation requires a customer API credential, the applicable storage, access, logging, deletion, and support-access controls will be disclosed in writing. Site and API traffic is protected in transit using TLS.

Retention

API credentials are retained while needed to provide the service and are scheduled for deletion after access ends. Usage, billing, and derived comparison records may be retained for reporting, legal, accounting, and service-improvement purposes.

The retention window for raw prompts and responses is not yet published because the technical architecture and customer agreement are still being finalized. A member-specific retention commitment will be disclosed before applicable onboarding.

Member choices

Members may request access to account and usage data, request deletion of eligible personal data, withdraw a prior training opt-in prospectively, or request a machine-readable export of available usage and reporting data.

Questions

Send data questions or requests to info@unbiased.ai.

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