Legal & Governance.

1. Regulatory Status and Publisher's Exclusion

1.1 Not a Registered Investment Adviser

HoundCreek Research LLC ("HoundCreek Research," "the Company") is not registered as an investment adviser with the U.S. Securities and Exchange Commission ("SEC") or with any state securities regulatory authority. The Company does not believe registration is required because it operates under the publisher's exclusion set forth in Section 202(a)(11)(D) of the Investment Advisers Act of 1940 (15 U.S.C. 80b-2(a)(11)(D)).

1.2 Legal Basis

The publisher's exclusion, as interpreted by the Supreme Court of the United States in Lowe v. SEC, 472 U.S. 181 (1985), and by the SEC in Release IA-1092 (October 8, 1987), excludes from the statutory definition of "investment adviser" the publisher of any bona fide newspaper, news magazine, or business or financial publication of general and regular circulation that provides only impersonal investment advice.

1.3 Three Requirements

HoundCreek Research believes it satisfies, and structures the Service to satisfy, the three requirements recognized in Lowe:

• Bona fide publication — Each research memo is a genuine analytical product generated by the Company's structured research pipeline. Memos are not pretexts for personalized consulting, shams designed to circumvent registration, or solicitations for individual advisory relationships.
• General and regular circulation — The Service is available to the general public. Any person of legal age may create an account, purchase credits or a subscription, and request a research memo on any supported ticker. Every memo is produced by the same standardized methodology, offered to all users on identical terms; the Company publishes research on a continuous basis as users request coverage, does not issue episodic trade alerts, and does not time its publications to specific market events. Access is not restricted to a select group of clients in a manner that would characterize the Service as a private advisory relationship.
• Impersonal advice — All research output is generated by a standardized analytical pipeline applying fixed methodological assumptions. No memo is, or can be, tailored to any individual user's personal financial circumstances.

1.4 Other Registrations

HoundCreek Research is not registered as, and does not act as, any of the following:

• Broker-dealer under the Securities Exchange Act of 1934
• Transfer agent
• Futures commission merchant
• Commodity trading adviser
• Commodity pool operator
• Municipal adviser
• Any other category of regulated financial services firm

The Company does not effect, facilitate, route, or recommend securities transactions. The Company does not custody funds or securities on behalf of any user.

2. Research Boundary

2.1 Informational and Educational Purpose

HoundCreek Research memos are published for informational and educational purposes only. They are intended to supplement, not replace, the user's own independent research, analysis, and judgment.

2.2 Impersonal Nature

Every research memo reflects a standardized pipeline and a fixed set of analytical assumptions. No memo is tailored to any individual user's:

• Investment portfolio or holdings
• Risk tolerance or risk capacity
• Financial situation, net worth, or income
• Tax circumstances or tax obligations
• Investment objectives, goals, or time horizon
• Liquidity needs or cash requirements
• Age, employment status, or personal demographics

2.3 No Suitability Analysis

The Company does not evaluate whether any security, investment strategy, or research output is suitable, appropriate, or advisable for any individual user. The Company does not request, collect, or consider any information that would enable such an evaluation.

2.4 No Recommendation to Trade

Nothing published by HoundCreek Research — including ratings, fair value estimates, scenario ranges, probability distributions, investment theses, risk assessments, or any other content — constitutes a recommendation, solicitation, or offer to buy, sell, or hold any security. This includes any verdict label or watch designation displayed with a memo (for example, "Fully Valued," "Value Watch," or "Not Rated") and any composite score: these are outputs of the standardized model, not recommendations to buy, sell, hold, or monitor any security. A research output is an analytical product reflecting a model and a set of assumptions. It is not a directive, suggestion, or instruction to take any investment action.

2.5 Prohibited Content

HoundCreek Research memos do not contain, and the Company's editorial standards prohibit:

• Personalized portfolio allocation or position-sizing recommendations
• Tranche plans, scaling schedules, or dollar-cost-averaging instructions
• Stop-loss levels, take-profit targets, or entry/exit price points intended as individual trade parameters
• De-risk schedules or portfolio rebalancing instructions
• Instructions to place orders with any broker or trading venue
• Portfolio construction advice of any kind

2.6 No Fiduciary Duty; Risk of Loss

HoundCreek Research owes no fiduciary, advisory, or similar duty to any user. No advisory, agency, or client relationship is created by your use of the Service. All investments in securities involve risk, including the possible loss of the entire principal invested. Securities discussed in any memo may not be suitable for any particular investor.

3. Valuation, Scenario Analysis, and Analytical Limitations

3.1 Nature of Valuation Estimates

Fair value estimates, blended fair values, and valuation ranges presented in research memos are the output of quantitative models applied to publicly available financial data and a set of stated analytical assumptions. They represent the Company's modeled assessment as of the date of generation. They are not:

• Guarantees or predictions of future security prices
• Price targets the market will reach
• Promises of investment returns or financial performance
• Offers to buy or sell securities at the stated values

3.2 Monte Carlo Simulation

Research memos may include probability distributions generated by Monte Carlo simulation. These distributions are intended to frame the range and dispersion of plausible outcomes under the model's assumptions. They do not:

• Represent the actual probability of future events
• Constitute statistical certainty about any outcome
• Account for all possible future states of the world
• Guarantee that actual outcomes will fall within the modeled range

3.3 Forward-Looking Statements

Research memos may contain forward-looking statements, projections, forecasts, and interpretive analysis. All forward-looking content is inherently uncertain and subject to material error. Actual results may differ materially from projected results for reasons including:

• Changes in macroeconomic conditions
• Competitive developments
• Regulatory changes
• Geopolitical events
• Company-specific events
• Errors in source data
• Limitations of the analytical model

3.4 No Guarantee of Accuracy

The Company does not warrant the accuracy, completeness, reliability, timeliness, or currentness of any data, analysis, valuation, rating, or other content in any research memo. Research outputs may contain errors, omissions, or outdated information.

3.5 Past Performance

Past performance of any security, analytical model, index, or research output does not guarantee future results. Historical data and backtested results are not indicative of future performance.

4. Data Sources and Limitations

HoundCreek Research relies on publicly available financial data, including company filings with the SEC (via EDGAR), market price data from public providers, and macroeconomic data from government sources (e.g., FRED). Source data coverage, timeliness, granularity, and completeness may vary by ticker and by reporting period. The Company does not independently verify the accuracy of third-party data sources. The quality gate may block memos with insufficient data, restoring the consumed credit.

5. Conflicts of Interest and Trading Policy

5.1 No Net Short Exposure

No founder, member, employee, or contractor of HoundCreek Research may maintain net short economic exposure to any security that is or has been the subject of a published HoundCreek memo — that is, no position or combination of positions whose overall value increases when the covered security's price falls. This prohibition covers outright short sales and any option, derivative, or synthetic structure that produces net negative exposure to a covered issuer.

Income- and hedging-oriented option writing that maintains net long or neutral exposure is permitted — for example, covered calls written against shares held, or cash-secured puts (which commit the writer to buying the security). Such positions retain or add long exposure to the covered security; they are not bets against it.

This prohibition is enforced as an internal policy and is intended to eliminate the most acute motive-conflict pattern affecting independent research publishers: publishing research on a company the publisher stands to profit against.

5.2 Long Positions and Pipeline Isolation

Founders, members, employees, and contractors may hold long positions in securities that are or have been the subject of published memos. HoundCreek's research pipeline is architecturally isolated from personal-position data:

• The pipeline does not collect, ingest, or process information about the personal holdings of any founder, member, employee, contractor, or user.
• Memo content for a given ticker is determined entirely by impersonal pipeline inputs — public filings, market data, fixed methodological assumptions, and the valuation components and deterministic checking layers described in Section 6.
• No human editorial review occurs between memo generation and delivery to the user's terminal. The pipeline produces the memo; the pipeline delivers the memo.
• The same ticker requested at the same time is analyzed from identical inputs under identical methodology for every user, regardless of any positions held by HoundCreek personnel or the requesting user.

The architectural impersonality that supports HoundCreek's publisher-exclusion posture under Section 1 also operates to ensure that personal long positions cannot influence the analytical content of any memo.

HoundCreek Research or its personnel may hold long positions (or the permitted option positions described in Section 5.1) in securities that are the subject of published memos, and every memo carries a standing disclosure to this effect. Personal holdings have no effect or bearing on any memo's analysis: the research pipeline and personal accounts are completely independent, as described above.

5.3 No Issuer Compensation

HoundCreek does not accept compensation, equity, advisory fees, or any other consideration from issuers covered in memos. No paid coverage. No coverage-for-payment relationships. No revenue-sharing arrangements with brokers or trading platforms. No advertising relationships with covered issuers.

5.4 Disclosure of Material Conflicts Beyond This Policy

If HoundCreek enters into any arrangement that creates a material conflict not addressed by the architectural and prohibitive measures above, that conflict will be disclosed on this page before publication of any affected memo.

6. Artificial Intelligence and Machine-Generated Content

HoundCreek Research memos are produced by an analytical pipeline that incorporates large language model (LLM) processing alongside deterministic financial-modeling components. The Company uses third-party LLM infrastructure. The specific provider's identity is available on written request to legal@houndcreekresearch.com (see also the subprocessor disclosures in the Privacy Policy). The Monte Carlo simulation and fair-value valuation are deterministic and independent of LLM output; the fact-binding and quality-gate layers apply deterministic rules to check LLM-generated content against source data.

All LLM components operate under standardized prompts, model selections, and parameters that are identical for every user. The pipeline does not customize prompts based on any individual user's characteristics: the same ticker submitted at the same time is processed from identical inputs under identical instructions for every user. The analytical conclusions are determined by the deterministic components; LLM-generated prose may vary from run to run without altering those conclusions. This impersonality is architecturally enforced.

LLM-assisted content may:

• Contain hallucination — statements not fully supported by source data
• Reflect a training-data cutoff — the pipeline injects current filing data to mitigate this, but residual gaps may persist
• Exhibit run-to-run prose variation
• Misinterpret tone or context in source filings

The Company's fact-binding and quality-gate layers are designed to catch unsupported numeric claims before delivery, but no automated check is exhaustive. The limitations in Sections 3 and 4 above apply with full force to LLM-assisted content.

LLM-generated prose is editorial — it expresses the analytical pipeline's deterministic outputs in readable form. The LLM does not generate personalized investment recommendations, position-sizing advice, or trading instructions, and is constrained by the prohibitions in Section 2.5.

The Company may change LLM providers, model versions, prompt templates, or pipeline components from time to time without prior notice.

7. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, HOUNDCREEK RESEARCH AND ITS FOUNDERS, MEMBERS, MANAGERS, OFFICERS, EMPLOYEES, AGENTS, CONTRACTORS, LICENSORS, AND SERVICE PROVIDERS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES.

DAMAGES SUBJECT TO THIS LIMITATION INCLUDE, WITHOUT LIMITATION, INVESTMENT LOSSES, TRADING LOSSES, LOSS OF PROFITS, LOSS OF REVENUE, LOSS OF DATA, AND LOSS OF GOODWILL — ARISING FROM OR RELATED TO YOUR USE OF OR RELIANCE ON ANY RESEARCH OUTPUT, ANY INVESTMENT DECISION MADE IN CONNECTION WITH THE SERVICE, ANY INACCURACY OR ERROR IN ANY RESEARCH OUTPUT, ANY INTERRUPTION OR DISCONTINUATION OF THE SERVICE, OR ANY UNAUTHORIZED ACCESS TO YOUR DATA OR ACCOUNT.

THIS LIMITATION APPLIES REGARDLESS OF THE LEGAL THEORY (CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE) AND WHETHER OR NOT THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. ANY LIABILITY NOT EXCLUDED BY THIS SECTION IS SUBJECT TO THE AGGREGATE LIABILITY CAP SET FORTH IN SECTION 10.2 OF THE TERMS OF SERVICE.

8. Consult a Professional

If you require investment advice tailored to your individual financial situation, risk tolerance, tax circumstances, investment objectives, or any other personal factor, you should consult a qualified, registered investment adviser, financial planner, tax professional, or attorney. HoundCreek Research is not a substitute for individualized professional financial advice.

9. Contact

Questions about these disclosures should be directed to HoundCreek Research LLC at legal@houndcreekresearch.com, or by mail to HoundCreek Research LLC, PMB 224, 11811 Shaker Blvd, Suite 204, Cleveland, OH 44120, United States.

1. Agreement to Terms

1.1 Binding Agreement

These Terms of Service ("Terms") constitute a legally binding agreement between you ("User," "you," or "your") and HoundCreek Research LLC ("HoundCreek Research," "the Company," "we," "us," or "our"). By creating an account, accepting these Terms through the registration acceptance flow, purchasing credits, subscribing to a plan, submitting a ticker for research, or otherwise accessing or using the HoundCreek Research website, terminal, or any associated services (collectively, the "Service"), you agree to be bound by these Terms in their entirety.

1.2 Capacity

By using the Service, you represent and warrant that you are at least eighteen (18) years of age, that you have the legal capacity to enter into a binding agreement, and that your use of the Service complies with all applicable laws and regulations in your jurisdiction.

1.3 Refusal

If you do not agree to these Terms, you must not create an account, purchase credits, or use any part of the Service. Your sole remedy for disagreement with these Terms is to discontinue use of the Service.

1.4 Additional Policies

These Terms incorporate by reference the following additional policies, each of which forms part of this agreement:

• Privacy Policy — governs collection, use, sharing, and retention of personal data
• Disclosures and Disclaimers — defines the research boundary and regulatory posture
• Acceptable Use Policy — defines prohibited conduct and enforcement
• Refund and Credit Policy — governs credit restoration and refund eligibility

In the event of a conflict between these Terms and any supplemental policy, these Terms shall control unless the supplemental policy expressly states otherwise.

2. Nature of the Service

2.1 Service Description

HoundCreek Research provides access to an on-demand equity research workflow through which registered users may purchase memo credits, submit supported U.S.-listed ticker symbols, and receive institutional-style research memos delivered to a private terminal workspace and archive.

2.2 Publisher of Impersonal Research

HoundCreek Research is a publisher of impersonal equity research for informational and educational purposes. The Company operates under the publisher's exclusion set forth in Section 202(a)(11)(D) of the Investment Advisers Act of 1940 (15 U.S.C. 80b-2(a)(11)(D)), as interpreted by the Supreme Court in Lowe v. SEC, 472 U.S. 181 (1985), and SEC Release IA-1092 (October 8, 1987).

2.3 What the Service Is Not

The Service is not, and shall not be construed as:

• Personalized investment advice or financial planning
• A recommendation, solicitation, or offer to buy, sell, or hold any security
• Portfolio management, asset allocation, or suitability analysis
• A broker-dealer interface, trading venue, or order-routing system
• A substitute for independent financial, legal, or tax advice from a qualified professional

2.4 Impersonal Nature of Research

All research memos are generated by a standardized analytical pipeline applying fixed methodological assumptions. No memo is, or can be, tailored to any individual user's portfolio, risk tolerance, financial situation, tax circumstances, investment objectives, liquidity needs, or any other personal characteristic. Every user who requests a memo for the same ticker at the same point in time receives materially identical research output.

2.5 No Suitability Determination

The Company does not evaluate, and the Service does not consider, whether any security or research output is suitable, appropriate, or advisable for any individual user. The Company does not request, collect, or use information about your investment holdings, net worth, income, risk tolerance, investment objectives, or time horizon.

3. Accounts

3.1 Registration

Access to the memo workflow requires a registered account authenticated via magic link email verification. By registering, you agree to provide a valid email address and to maintain access to that email address for the duration of your account.

3.2 Account Security

You are solely responsible for maintaining the security of the email account associated with your HoundCreek Research account. You are responsible for all activity that occurs under your account, whether or not authorized by you. You must notify the Company promptly at support@houndcreekresearch.com if you become aware of any unauthorized use of your account.

3.3 One Account Per Person

Each natural person may maintain one (1) HoundCreek Research account. You may not create multiple accounts, share account credentials, transfer your account to another person, or allow any other person to access the Service through your account, without the Company's prior written consent.

3.4 Account Suspension and Termination

The Company reserves the right to suspend or terminate your account, with or without notice, if:

• You violate these Terms or any supplemental policy
• The Company reasonably believes your account is being used for fraudulent, abusive, or unlawful activity
• You fail to pay amounts owed
• Continued provision of the Service to you would expose the Company to legal liability
• The Company discontinues the Service entirely

Upon termination, your right to access the Service ceases immediately. Sections 2, 5, 7, 8, 9, 10, 11, 12, 13, and 14 survive termination.

3.5 Individual Use; Institutional and Enterprise Arrangements

Accounts, and the license granted under these Terms, are for use by one natural person. These Terms do not grant any organization the right to provision access for its employees or members, to pool or systematically share memo content within an organization, or to integrate research output into an organization's own products, services, or workflows. Institutional, corporate, multi-seat, or other organizational use of the Service requires a separate written agreement with the Company; prospective institutional users should contact sales@houndcreekresearch.com. Where the Company and an organization have executed such an agreement, that agreement governs the organization's use of the Service and supersedes these Terms to the extent of any conflict. Absent such an agreement, organizational use is not authorized.

4. Credits, Pricing, and Payments

4.1 Credit Purchases

The Service uses a credit-based system. Credits are sold as one-time purchases in the quantities and at the prices displayed at the time of checkout. Each credit entitles you to submit one (1) supported ticker symbol for research memo generation.

4.2 Credit Consumption

One (1) credit is consumed upon submission of a ticker for a memo run. Credits are non-transferable between accounts.

4.3 Pricing Changes

The Company may change credit pricing, pack sizes, and promotional offers at any time at its sole discretion. Price changes apply to future purchases only and do not retroactively affect credits already purchased and held in your account.

4.4 Payment Processing

All payments are processed by Stripe, Inc. ("Stripe"). The Company does not collect, store, process, transmit, or have access to your full credit card number, expiration date, or CVC. Your payment is subject to Stripe's terms of service and privacy policy in addition to these Terms. By making a purchase, you authorize Stripe to charge your payment method for the amount displayed at checkout.

4.5 Currency

All prices are denominated and charged in United States Dollars (USD) unless otherwise stated.

4.6 Taxes

You are responsible for any applicable sales tax, use tax, value-added tax, or other tax imposed on your purchase, except for taxes on the Company's net income. The Company will collect and remit taxes where required by law.

4.7 Credit Expiration

Purchased one-time credits do not expire while your account remains active and in good standing. If the Service is permanently discontinued, unused purchased credits will be refunded as provided in Section 13.3 and the Refund and Credit Policy. Subscription credits are governed by Section 4.8 and expire at the end of each billing period.

4.8 Monthly Subscription Plans

4.8.1 The Plans. In addition to one-time credit packs, the Company offers one or more optional monthly subscription plans. Each plan grants a fixed number of research credits each billing period at a recurring monthly price (for example, the standard plan currently grants ten (10) credits per month for $49.00 per month). Current plan details and pricing are displayed at the point of subscription. Where more than one plan is offered, you may switch plans through the billing portal; unless stated otherwise at the point of change, a plan change takes effect at the start of your next billing period. The provisions of this Section 4.8 apply to every subscription plan.

4.8.2 Automatic Renewal. THE SUBSCRIPTION AUTOMATICALLY RENEWS EACH MONTH UNTIL YOU CANCEL. By subscribing, you authorize the Company and Stripe to charge your payment method the then-current monthly fee on a recurring basis at the start of each billing period until you cancel. The Company does not send a separate reminder before each renewal.

4.8.3 Subscription Credits. At the start of each billing period, your subscription credit balance is set to the plan amount. Subscription credits do not roll over: any unused subscription credits expire at the end of the billing period in which they were granted (use-it-or-lose-it). When you submit a memo run, subscription credits are consumed before any separately purchased one-time credits. Purchased one-time credits are separate, are not affected by your subscription, and do not expire while your account is active (Section 4.7).

4.8.4 Cancellation. You may cancel your subscription at any time through the billing portal accessible from your account. Cancellation takes effect at the end of the current paid billing period: your subscription remains active and your current-period subscription credits remain usable through that date, after which the subscription ends and any remaining subscription credits expire. Cancellation stops all future charges but does not entitle you to a refund of the current or any prior billing period.

4.8.5 Price Changes. The Company may change the subscription price or plan terms. Any change to your recurring price will apply only to billing periods beginning at least thirty (30) days after the Company provides notice to you (by email or through the Service). If you do not agree to a price change, you may cancel before it takes effect; continuing the subscription after the effective date constitutes acceptance of the new price.

4.8.6 Failed Payments. If a renewal payment fails, the Company (through Stripe) will attempt to charge your payment method again periodically for a limited retry period of up to thirty (30) days. Your subscription remains active during this retry period, but subscription credits for the new period are issued only once a payment succeeds. If payment has not succeeded by the end of the retry period, the Company may cancel your subscription, after which subscription credits expire. You remain responsible for keeping a valid payment method on file.

4.8.7 Refunds. Subscription fees are non-refundable except as expressly provided in the Refund and Credit Policy (for example, verified billing errors, duplicate charges, or permanent discontinuation of the Service). Cancellation stops future billing but does not refund amounts already charged.

5. Delivery, Quality Gates, and Refunds

5.1 Delivery Window

The Service aims to deliver completed research memos within the stated operating window (typically ten to fifteen minutes from submission). Delivery times are estimates and are not guaranteed. Factors including system load, data availability, and quality gate processing may affect delivery time.

5.2 Quality Gate

The Company maintains an automated quality gate that evaluates research output before delivery. If a memo does not meet the Company's internal quality standards, it will be blocked and will not be delivered. The quality gate exists to protect the integrity and reliability of delivered research. The Company does not deliver degraded or partial research.

A delivered memo whose conclusion is "Not Rated" or otherwise non-directional is not a blocked or failed run. It is a complete research artifact produced by the standardized pipeline — the analysis was performed and the pipeline determined that a directional rating was not warranted. Such a memo constitutes a fulfilled order under Section 5.3 and the Refund and Credit Policy.

5.3 Automatic Credit Restoration

If a memo run fails due to infrastructure error, engine failure, unsupported ticker, or quality gate block, the consumed credit is automatically restored to your account balance. No memo is delivered for blocked or failed runs. Automatic credit restoration is not a refund — the credit returns to your balance for future use. A delivered memo — including one whose conclusion is "Not Rated" or otherwise non-directional — constitutes a fulfilled order; its credit is consumed and is not restored.

5.4 No Monetary Refunds

All purchases are final. The Company does not offer monetary refunds of credit purchases or subscription fees. Automatic credit restoration under Section 5.3 is the sole and exclusive remedy for failed or blocked memo runs. Money is returned to your payment method in only two circumstances:

• Correction of verified billing errors, duplicate charges, or unauthorized charges — done as a matter of course, not as a discretionary refund, upon report to customer support through the procedure in Section 5.6 so the Company can investigate and remedy the issue in a timely manner
• Permanent discontinuation of the Service (for unused one-time credits only), governed by Section 13.3 and the Refund and Credit Policy and not discretionary

Nothing in this Section limits any non-waivable right you may have under applicable consumer protection law.

5.5 Non-Refundable Circumstances

The following do not constitute grounds for a refund — in every case, the only remedy for a failed or blocked run is automatic credit restoration under Section 5.3:

• Disagreement with a memo's conclusions, valuation, rating, or analytical methodology
• Dissatisfaction with the format, length, depth, or presentation of a delivered memo
• A security's market price moving in a direction inconsistent with a memo's analysis
• The user's failure to read or understand the Terms, Disclosures, or research boundary before purchasing
• The user deciding not to use remaining credits

The product is the research process and delivered output, not an investment outcome. A delivered memo constitutes a fulfilled order.

5.6 Billing-Correction Procedure

Billing-correction requests must be submitted in writing to support@houndcreekresearch.com within thirty (30) days of the transaction in question (or, for billing errors discovered after the fact, within thirty (30) days of becoming aware of the issue). The Company will respond within ten (10) business days. The Company's determination is final, except as required by applicable consumer protection law.

5.7 Archive Retention

Delivered memos remain available in your terminal archive while your account is active and in good standing. The Company may retain memo artifacts after account closure for backup and legal-compliance purposes, consistent with the retention schedule in the Privacy Policy.

6. Acceptable Use

6.1 Permitted Use

You may use the Service to:

• Create and maintain your authenticated account
• Purchase memo credits or subscribe to a monthly plan
• Submit supported U.S.-listed ticker symbols for research
• Review, read, and revisit completed memos in your terminal archive
• Access the Company's public methodology, disclosure, and legal pages

6.2 Prohibited Conduct

You agree not to, and you agree not to assist, encourage, or enable any third party to:

• Use automated tools, bots, scripts, crawlers, or any non-human means to access, scrape, extract, copy, or monitor any content from the Service without the Company's prior written consent
• Attempt to bypass, circumvent, disable, or interfere with any authentication, authorization, credit, rate-limiting, quality gate, or other security or access control mechanism
• Interfere with, disrupt, or impose an unreasonable burden on the Service's infrastructure, servers, networks, or other users' access
• Reproduce, redistribute, resell, sublicense, syndicate, or white-label memo content at scale or for commercial purposes without the Company's prior written authorization
• Use the Service for any purpose that violates applicable local, state, national, or international law or regulation
• Misrepresent HoundCreek Research outputs as personalized investment advice, individual recommendations, guaranteed predictions, or as your own original research in a commercial publication
• Share, transfer, sell, or otherwise provide access to your account credentials or authenticated session to any other person
• Submit requests designed to test, probe, reverse-engineer, or exploit the research pipeline, infrastructure, or methodology for any purpose other than legitimate personal research consumption
• Use the Service to generate research for the purpose of market manipulation, insider trading, front-running, or any other unlawful trading activity
• Upload, transmit, or introduce any virus, malware, trojan, worm, or other harmful code through the Service
• Impersonate any person or entity, or falsely represent your affiliation with any person or entity
• Use the Service in any manner that could damage, disable, overburden, or impair the Service or interfere with any other party's use of the Service

6.3 Enforcement

The Company reserves the right to investigate suspected violations of this Section and to take any action it deems appropriate, including but not limited to:

• Issuing a warning
• Temporarily or permanently suspending your account
• Permanently terminating your account without refund of unused credits
• Reporting suspected illegal activity to appropriate law enforcement authorities
• Pursuing civil remedies, including injunctive relief and damages

7. Intellectual Property

7.1 Company Ownership

The Service, including but not limited to the website, terminal interface, research methodology, analytical pipeline, workflow design, software code, visual design, branding, trade names, logos, and memo presentation format, is owned by HoundCreek Research or its licensors and is protected by United States and international copyright, trademark, trade secret, and other intellectual property laws.

7.2 Limited License to Memo Content

Subject to your compliance with these Terms, the Company grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use delivered memo content for your personal, non-commercial research and reference purposes. You may cite, quote, and share excerpts of memo content — including text excerpts, screenshots, and headline metrics such as fair value estimates, scenario ranges, ratings, and scores — with proper attribution to HoundCreek Research, including in commentary or other publications, whether or not commercial, provided such use is not at a scale or in a manner that substitutes for the Service. This includes sharing excerpts and screenshots publicly (for example, on social media), provided the shared content (a) is not the complete memo or substantially all of one, (b) identifies HoundCreek Research as the source, and (c) includes a link to houndcreekresearch.com where the medium permits. Complete memos may not be shared or republished publicly. The Company may narrow the scope of this sharing permission prospectively in accordance with Section 15; sharing that occurred while permitted under the then-current Terms is not retroactively a violation.

7.3 Restrictions

You may not:

• Reproduce, distribute, publicly display, or publicly perform any memo content in its entirety without the Company's prior written consent
• Create derivative works based on memo content for commercial distribution
• Remove, alter, or obscure any copyright notice, attribution, or proprietary marking from memo content
• Use memo content to train, fine-tune, or develop any machine learning model, artificial intelligence system, or automated research tool without the Company's prior written consent
• Sell, license, syndicate, or commercially redistribute memo content in any form

7.4 Feedback

If you provide the Company with feedback, suggestions, bug reports, feature requests, or other input regarding the Service ("Feedback"), you grant the Company a perpetual, irrevocable, worldwide, royalty-free, fully paid-up, non-exclusive license to use, reproduce, modify, distribute, and otherwise exploit such Feedback for any purpose, without attribution, compensation, or further obligation to you.

7.5 Trademarks

"HoundCreek Research," the HoundCreek logo, and related marks are trademarks or service marks of the Company. You may not use the Company's trademarks without prior written consent, except as expressly permitted in Section 7.2.

8. Reliance on Content and Assumption of Risk

8.1 Independent Judgment

Research outputs published through the Service are intended to inform and supplement your own independent analysis. They are not a substitute for your own judgment, due diligence, or the advice of a qualified financial adviser, tax professional, or attorney.

8.2 No Recommendation

The existence of a rating, fair value estimate, probability distribution, scenario range, or any other analytical output in a memo does not constitute a recommendation tailored to your individual circumstances. No content published by the Company constitutes a recommendation, solicitation, or offer to buy, sell, or hold any security.

8.3 Investment Risk

You acknowledge and agree that:

• All investments involve risk, including the potential loss of principal
• Past performance of securities, analytical models, or research outputs does not guarantee future results
• Market prices can move materially and quickly for reasons not captured by any model or analysis
• No analytical methodology, including Monte Carlo simulation, can predict future market prices with certainty
• You are solely responsible for your own investment decisions and any financial consequences thereof

8.4 Assumption of Risk

YOU EXPRESSLY ACKNOWLEDGE AND AGREE THAT YOUR USE OF THE SERVICE AND ANY RELIANCE ON RESEARCH OUTPUTS IS AT YOUR SOLE RISK. YOU ASSUME FULL RESPONSIBILITY FOR ALL INVESTMENT DECISIONS YOU MAKE AND ALL FINANCIAL CONSEQUENCES THEREOF, REGARDLESS OF WHETHER SUCH DECISIONS WERE INFORMED BY CONTENT FROM THE SERVICE.

9. Disclaimer of Warranties

THE SERVICE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT WARRANTY OF ANY KIND. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, HOUNDCREEK RESEARCH EXPRESSLY DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING BUT NOT LIMITED TO:

• IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT
• WARRANTIES THAT THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE, ERROR-FREE, OR FREE OF VIRUSES, MALWARE, OR OTHER HARMFUL COMPONENTS
• WARRANTIES REGARDING THE ACCURACY, RELIABILITY, COMPLETENESS, CURRENTNESS, OR QUALITY OF ANY RESEARCH OUTPUT, DATA, ANALYSIS, VALUATION, RATING, OR OTHER CONTENT
• WARRANTIES THAT ANY RESEARCH OUTPUT WILL RESULT IN ANY PARTICULAR INVESTMENT OUTCOME, RETURN, OR PROFIT
• WARRANTIES THAT ERRORS IN THE SERVICE OR ANY RESEARCH OUTPUT WILL BE CORRECTED
• WARRANTIES ARISING FROM COURSE OF DEALING, COURSE OF PERFORMANCE, OR USAGE OF TRADE

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES. IN SUCH JURISDICTIONS, THE ABOVE EXCLUSIONS APPLY TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.

10. Limitation of Liability

10.1 Exclusion of Damages

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL HOUNDCREEK RESEARCH, ITS FOUNDERS, MEMBERS, MANAGERS, OFFICERS, EMPLOYEES, AGENTS, CONTRACTORS, LICENSORS, OR SERVICE PROVIDERS (COLLECTIVELY, THE "COMPANY PARTIES") BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY:

• INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES
• LOSS OF PROFITS, REVENUE, BUSINESS, SAVINGS, GOODWILL, OR ANTICIPATED BENEFITS
• LOSS OF DATA OR DATA BREACH
• INVESTMENT LOSSES, TRADING LOSSES, OR LOSSES ARISING FROM INVESTMENT DECISIONS
• COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES
• ANY DAMAGES ARISING FROM OR RELATED TO YOUR USE OF OR INABILITY TO USE THE SERVICE, YOUR RELIANCE ON ANY RESEARCH OUTPUT, OR ANY INVESTMENT DECISION MADE IN CONNECTION WITH OR INFORMED BY THE SERVICE

WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT THE COMPANY PARTIES HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

10.2 Aggregate Liability Cap

IN NO EVENT SHALL THE COMPANY PARTIES' TOTAL AGGREGATE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATED TO THESE TERMS OR THE SERVICE EXCEED THE LESSER OF: (a) THE TOTAL AMOUNT YOU HAVE ACTUALLY PAID TO THE COMPANY IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM; OR (b) ONE HUNDRED UNITED STATES DOLLARS ($100.00).

10.3 Essential Basis of the Bargain

YOU ACKNOWLEDGE AND AGREE THAT THE COMPANY HAS OFFERED THE SERVICE, SET ITS PRICES, AND ENTERED INTO THESE TERMS IN RELIANCE UPON THE DISCLAIMERS OF WARRANTY AND LIMITATIONS OF LIABILITY SET FORTH HEREIN, THAT THE SAME REFLECT A REASONABLE AND FAIR ALLOCATION OF RISK BETWEEN YOU AND THE COMPANY, AND THAT THE SAME FORM AN ESSENTIAL BASIS OF THE BARGAIN BETWEEN YOU AND THE COMPANY. THE COMPANY WOULD NOT BE ABLE TO PROVIDE THE SERVICE TO YOU ON AN ECONOMICALLY REASONABLE BASIS WITHOUT THESE LIMITATIONS.

10.4 Jurisdictional Limitations

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES. IN SUCH JURISDICTIONS, THE LIABILITY OF THE COMPANY PARTIES SHALL BE LIMITED TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.

11. Indemnification

11.1 Your Indemnification Obligations

You agree to indemnify, defend, and hold harmless the Company Parties from and against any and all claims, demands, actions, suits, proceedings, losses, damages, liabilities, judgments, settlements, costs, and expenses (including reasonable attorneys' fees and court costs) arising out of or related to:

• Your use of or access to the Service
• Your violation of these Terms or any supplemental policy
• Your violation of any applicable law, regulation, or third-party right
• Any investment decision you make based on or informed by research outputs from the Service
• Any content you submit, post, or transmit through the Service
• Any claim by a third party that your use of the Service caused them damage

11.2 Company's Right to Control Defense

The Company reserves the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify the Company, and you agree to cooperate with the Company's defense of such claim. You agree not to settle any such claim without the Company's prior written consent.

12. Dispute Resolution

12.1 Governing Law

These Terms and any dispute arising out of or related to these Terms or the Service shall be governed by and construed in accordance with the laws of the State of Ohio, the state in which HoundCreek Research LLC is organized, without giving effect to any choice-of-law or conflict-of-law provision or rule.

12.2 Exclusive Jurisdiction

Subject to Section 12.3, any legal action or proceeding arising out of or related to these Terms or the Service shall be brought exclusively in the state or federal courts located in the State of Ohio, and you irrevocably consent to the personal jurisdiction and venue of such courts.

12.3 Informal Resolution

Before filing any legal action, you agree to attempt to resolve the dispute informally by sending written notice to legal@houndcreekresearch.com (or by mail to the address in Section 16) describing the nature and basis of the claim. The Company will attempt to resolve the dispute within thirty (30) days. If the dispute is not resolved within that period, either party may proceed with formal legal action.

12.4 Waiver of Class Action

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, YOU AGREE THAT ANY DISPUTE RESOLUTION PROCEEDINGS WILL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION, AND YOU WAIVE YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION LAWSUIT AGAINST THE COMPANY.

12.5 Limitation Period

Any claim arising out of or related to these Terms or the Service must be filed within one (1) year after the date the cause of action accrues, or such claim is permanently barred.

13. Service Changes and Termination

13.1 Modifications to Service

The Company may modify, update, suspend, or discontinue any aspect of the Service at any time, with or without notice. The Company is not liable to you or any third party for any modification, suspension, or discontinuation of the Service.

13.2 Beta and Evolution

The Service may be in beta or early-access status. Features, supported tickers, delivery behavior, and interface design may change as the product and infrastructure evolve. You acknowledge that the Service is under active development and accept the inherent variability of a developing product.

13.3 Credit Survival

Purchased one-time credits held in your account remain valid and redeemable regardless of feature changes. If the Company permanently discontinues the Service entirely, unused one-time credits are refundable to the original payment method on request submitted within sixty (60) days of the discontinuation notice, as provided in the Refund and Credit Policy; subscription credits are governed by Section 4.8 and the Refund and Credit Policy.

13.4 Your Right to Terminate

You may terminate your account at any time by contacting support@houndcreekresearch.com. Upon termination at your request, the Company will make reasonable efforts to provide access to your memo archive for thirty (30) days following the termination request.

14. General Provisions

14.1 Entire Agreement

These Terms, together with the Privacy Policy, Disclosures and Disclaimers, Acceptable Use Policy, and Refund and Credit Policy, constitute the entire agreement between you and the Company regarding the Service and supersede all prior or contemporaneous agreements, understandings, representations, and warranties, whether written or oral, regarding the Service.

14.2 Severability

If any provision of these Terms is found by a court of competent jurisdiction to be invalid, illegal, or unenforceable, that provision shall be modified to the minimum extent necessary to make it valid, legal, and enforceable, or if modification is not possible, shall be severed from these Terms. The invalidity, illegality, or unenforceability of any provision shall not affect the validity, legality, or enforceability of any remaining provision.

14.3 Waiver

The Company's failure to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision. Any waiver of any provision of these Terms shall be effective only if in writing and signed by the Company.

14.4 Assignment

You may not assign, transfer, or delegate your rights or obligations under these Terms without the Company's prior written consent. The Company may assign its rights and obligations under these Terms without restriction. These Terms are binding upon and inure to the benefit of the parties and their respective successors and permitted assigns.

14.5 Force Majeure

The Company shall not be liable for any delay or failure in performance resulting from causes beyond its reasonable control, including but not limited to acts of God, natural disasters, epidemics, war, terrorism, riots, government actions, power failures, internet or telecommunications failures, or third-party service provider outages.

14.6 No Third-Party Beneficiaries

These Terms do not create any third-party beneficiary rights in any individual or entity that is not a party to these Terms.

14.7 Notices

The Company may provide notices to you via email to the address associated with your account, via posting on the Service, or via any other method the Company deems reasonably likely to reach you. You are responsible for maintaining a current, valid email address in your account.

14.8 Headings

Section headings are for convenience of reference only and shall not affect the interpretation of these Terms.

14.9 Electronic Agreement

You agree that these Terms and all related documents may be executed electronically, and that your electronic acceptance has the same legal force and effect as a handwritten signature.

15. Changes to These Terms

15.1 Right to Modify

The Company reserves the right to modify these Terms at any time. Material modifications will be communicated through one or more of the following: email notification to the address associated with your account, prominent notice on the Service, or requirement to re-accept the updated Terms before continued use.

15.2 Re-Acceptance

When the Company determines that a modification is material, you will be required to affirmatively re-accept the updated Terms through the Service's acceptance flow before continued access to the terminal workspace. Your acceptance of the updated Terms constitutes agreement to all modifications.

15.3 Disagreement

If you do not agree with modified Terms, your sole remedy is to discontinue use of the Service and contact support@houndcreekresearch.com regarding any remaining credit balance.

16. Contact

Questions, concerns, or notices regarding these Terms should be directed to HoundCreek Research LLC at legal@houndcreekresearch.com, or by mail to:

HoundCreek Research LLC
PMB 224
11811 Shaker Blvd, Suite 204
Cleveland, OH 44120
United States

Institutional and enterprise inquiries should be directed to sales@houndcreekresearch.com.

1. Introduction

1.1 Commitment

HoundCreek Research LLC ("HoundCreek Research," "the Company," "we," "us," or "our") is committed to protecting the privacy of individuals who visit our website, create accounts, and use our services. This Privacy Policy ("Policy") describes what personal information we collect, how we use it, with whom we share it, how long we retain it, and what rights you have regarding your personal information.

1.2 Scope

This Policy applies to all personal information collected through the HoundCreek Research website, terminal workspace, and associated services (collectively, the "Service"). It does not apply to third-party websites, services, or applications that may be linked from or integrated with the Service, even if accessed through our platform. We encourage you to review the privacy policies of any third party before providing them with personal information.

1.3 Acceptance

By creating an account, accepting the Terms of Service, or otherwise using the Service, you acknowledge that you have read and understood this Policy and consent to the collection, use, and sharing of your personal information as described herein.

2. Information We Collect

2.1 Information You Provide Directly

• Account information — When you create an account, we collect your email address. Your email serves as your primary account identifier and is used for authentication via magic link and for transactional communications.
• Payment information — When you purchase memo credits, your payment is processed directly by Stripe, Inc. ("Stripe"). Stripe collects your credit card number, expiration date, CVC, and billing address directly from your browser. HoundCreek Research receives from Stripe only: a transaction identifier, the last four digits of your card number, the card brand (e.g., Visa, Mastercard), and your billing country. We never see, receive, store, process, or transmit your full credit card number, expiration date, or CVC. If you subscribe to a recurring plan, Stripe additionally maintains a customer record to process renewals, and the Company stores a Stripe customer identifier and your subscription status (plan, renewal date, and active or cancelled state) to manage your plan.
• Research requests — When you submit a ticker symbol for a memo run, we record the ticker symbol, the date and time of submission, and the resulting job status (queued, running, succeeded, failed, or blocked).
• Support communications — If you contact us for support, we collect the content of your communication, including any personal information you choose to include.

2.2 Information Collected Automatically

• Usage data — We automatically collect information about your interactions with the Service, including pages visited, features used, actions taken within the terminal workspace, and the date and time of your visits. Where our privacy-focused, cookieless analytics are enabled, this usage data is measured in aggregate through the analytics provider described in Section 4.2, and its collection honors the opt-out signals described in Section 8.5.
• Device and connection information — Your IP address, browser type and version, operating system, device type, referring URL, and language preference are collected by our hosting infrastructure in the normal course of serving web requests. Screen and viewport size are collected client-side only when our cookieless analytics script is enabled (Section 4.2).
• Cookies and local storage — We use essential cookies and browser local storage required for authentication, session management, and terms-of-service acceptance tracking. We do not use third-party advertising cookies, cross-site tracking cookies, or analytics cookies that identify individual users. See Section 8 for details.

2.3 Information We Do Not Collect

We do not collect, and the Service does not request:

• Investment portfolio holdings or brokerage account information
• Net worth, income, or salary information
• Tax returns or tax identification numbers
• Risk tolerance questionnaire responses
• Investment objectives, time horizons, or financial goals
• Social Security numbers or government-issued identification numbers
• Biometric data (fingerprints, facial recognition, retinal scans)
• Precise geolocation data (GPS coordinates)
• Health, genetic, or medical information

3. How We Use Your Information

3.1 Primary Purposes

We use your personal information for the following purposes:

• Account management — Authenticating your identity via magic link, maintaining your authenticated session, and managing your terminal workspace access.
• Payment processing — Facilitating credit purchases through Stripe, maintaining order records, and reconciling transactions.
• Service delivery — Queuing, processing, and delivering research memos to your terminal archive; tracking job status; restoring credits for failed or blocked runs.
• Transactional communications — Sending order confirmations, credit purchase receipts, memo-ready notifications, account security alerts, and other notices directly related to your use of the Service. These communications are a necessary part of the Service and are not marketing.
• Security and abuse prevention — Detecting, investigating, and preventing unauthorized access, fraud, abuse, and violations of our Terms of Service.
• Legal compliance — Complying with applicable laws, regulations, legal processes, and enforceable governmental requests; enforcing our Terms of Service; protecting the rights, property, or safety of the Company, our users, or the public.

3.2 Secondary Purposes

• Service improvement — Analyzing usage patterns in aggregate (not individually) to improve reliability, performance, and the user experience. We do not build individual behavioral profiles for advertising or sell insights derived from your usage.
• Customer support — Responding to your inquiries, troubleshooting issues, and resolving disputes.

3.3 Purposes for Which We Do Not Use Your Information

We do not use your personal information for:

• Advertising, ad targeting, or behavioral profiling
• Sale to data brokers, advertising networks, or any third party
• Building individual investor profiles for resale or licensing
• Providing information about individual user investment behavior to issuers, broker-dealers, or any other party
• Any purpose not disclosed in this Policy without your prior consent

4. Information Sharing and Disclosure

4.1 We Do Not Sell Your Data

HoundCreek Research does not sell, rent, lease, or trade your personal information to any third party for monetary or other valuable consideration. We do not share your personal information with data brokers, advertising networks, or any third party for their own independent marketing purposes.

4.2 Service Providers (Subprocessors)

We share personal information with the following categories of service providers (subprocessors), each of which processes data on our behalf and subject to contractual obligations to protect your information:

The specific identity of each subprocessor is available on written request to legal@houndcreekresearch.com (and to business customers as part of a Data Processing Agreement, where applicable).

4.3 Legal Requirements

We may disclose your personal information if we believe in good faith that disclosure is necessary to:

• Comply with applicable law, regulation, legal process, or enforceable governmental request
• Enforce our Terms of Service, including investigation of potential violations
• Detect, prevent, or address fraud, security, or technical issues
• Protect against harm to the rights, property, or safety of the Company, our users, or the public, as required or permitted by law

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of the Company's assets, your personal information may be transferred to the acquiring entity. We will provide notice before your personal information becomes subject to a different privacy policy.

4.5 Aggregated and De-identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you, for research, analytics, or business purposes.

5. Data Retention

5.1 Retention Periods

5.2 Retention Rationale

Retention periods are based on:

• The period necessary to fulfill the purpose for which the information was collected
• Applicable legal, tax, and accounting obligations (including IRS record-keeping requirements for transaction records)
• The need to resolve disputes and enforce agreements
• Legitimate business interests in maintaining service continuity and fraud prevention

5.3 Deletion After Retention

When the applicable retention period expires, we will delete or de-identify your personal information, except where continued retention is required by law.

6. Your Rights

6.1 Rights Available to All Users

Regardless of your location, you may exercise the following rights by contacting us at support@houndcreekresearch.com:

• Access — Request a summary of the personal information we hold about you, including the categories of information collected, the purposes for which it is used, and the categories of third parties with whom it is shared.
• Correction — Request correction of inaccurate or incomplete personal information.
• Deletion — Request deletion of your account and associated personal information. We will complete deletion within thirty (30) days of verifying your identity and request, except for information we are legally required to retain (such as transaction records for tax compliance and terms acceptance records). A verified deletion request overrides the standard post-closure retention periods in Section 5.1: account and job records are deleted or de-identified within the same thirty (30) days rather than retained for the standard period.
• Data export — Request a copy of your personal information and memo archive in a standard, machine-readable format (JSON or CSV).
• Objection — Object to the processing of your personal information for purposes not directly related to the Service.

6.2 California Residents — CCPA/CPRA Rights

If you are a California resident and the Company meets the applicability thresholds of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (Cal. Civ. Code 1798.100 et seq.), you have the following additional rights:

• Right to Know — the specific pieces of personal information collected, the categories of sources, the business purpose for collection, and the categories of third parties with whom information is shared.
• Right to Delete — request deletion of personal information collected from you, subject to specified exceptions.
• Right to Opt Out of Sale/Sharing — opt out of the sale or sharing of personal information for cross-context behavioral advertising. Note: HoundCreek Research does not sell or share personal information as defined by the CCPA/CPRA.
• Right to Non-Discrimination — the Company will not discriminate against you for exercising any CCPA/CPRA right.
• Right to Limit Use of Sensitive Personal Information — the Company does not collect sensitive personal information as defined by the CCPA/CPRA.

As of the effective date of this Policy, the Company is below CCPA/CPRA applicability thresholds but maintains practices consistent with these rights.

6.3 European and International Users

If you access the Service from the European Economic Area, United Kingdom, Switzerland, or another jurisdiction with comprehensive data protection laws, you may have additional rights under applicable law, including rights related to lawful basis for processing, data portability, and lodging complaints with supervisory authorities. The primary lawful basis for our processing of your personal information is the performance of our contract with you (the Terms of Service) and our legitimate business interests.

6.4 Exercising Your Rights

To exercise any right described in this Section, contact us at support@houndcreekresearch.com with a description of your request. We will verify your identity before processing any request. We will respond within thirty (30) days, or within the time period required by applicable law.

6.5 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require the agent to provide proof of authorization and may verify your identity directly.

7. Security

7.1 Safeguards

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction, including:

• Encryption of all data in transit via Transport Layer Security (TLS/HTTPS) enforced across all pages
• Encryption of data at rest through our database provider
• Per-user data isolation — each user's terminal archive, job records, and account data are accessible only through authenticated requests validated against the user's identity
• API keys, database credentials, and service secrets stored as environment variables, never committed to source code
• PCI DSS SAQ A compliance through full outsourcing of payment card handling to Stripe
• Access to production infrastructure limited to authorized personnel
• Regular review of third-party service provider security practices

7.2 No Absolute Security

No method of electronic transmission or storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. You acknowledge that you provide personal information at your own risk.

7.3 Breach Notification

If we become aware of a security breach that affects your personal information, we will notify you in accordance with applicable law. Notification may be provided via email to the address associated with your account, via prominent notice on the Service, or via other means as required by law.

8. Cookies and Local Storage

8.1 Essential Cookies

We use essential cookies required for the Service to function. These cookies are strictly necessary for authentication, session management, and security. They cannot be disabled without breaking core Service functionality.

8.2 Local Storage

We record your Terms of Service acceptance (version, timestamp, and user identifier) in our backend systems — this is the authoritative record referenced in Section 5.1 — and cache a copy in browser local storage so you are not re-prompted unnecessarily. The cached copy is used to determine whether you need to re-accept updated terms.

8.3 What We Do Not Use

We do not use:

• Third-party advertising or remarketing cookies
• Cross-site tracking cookies or pixels
• Analytics cookies that identify individual users
• Social media tracking cookies
• Any cookie or tracking technology for behavioral profiling or targeted advertising

8.4 Browser Controls

You can control cookies through your browser settings. Blocking essential cookies may prevent you from using the Service.

8.5 Do Not Track and Opt-Out Preference Signals

Our Service honors browser Do Not Track (DNT) signals: when DNT is enabled in your browser, our analytics do not run and no analytics events are sent. Because we do not sell or share personal information and do not engage in cross-context behavioral advertising, there is no sale or sharing to opt out of via the Global Privacy Control (GPC) or similar opt-out preference signals; essential authentication and session functions operate regardless of such signals, as permitted by law.

9. Children's Privacy

The Service is not intended for, directed to, or designed to attract individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe a child under 18 has provided us with personal information, please contact us immediately at support@houndcreekresearch.com.

10. International Data Transfers

10.1 United States Processing

HoundCreek Research is operated from the United States. If you access the Service from outside the United States, your personal information will be transferred to, stored in, and processed in the United States, which may have data protection laws that differ from those in your jurisdiction.

10.2 Consent to Transfer

By using the Service, you consent to the transfer of your personal information to the United States and the processing of your personal information in the United States in accordance with this Policy.

10.3 Safeguards

Where we transfer personal information across borders, we implement appropriate safeguards, including the security measures described in Section 7 and contractual obligations with our service providers.

11. Third-Party Links and Services

The Service may contain links to third-party websites or services, including but not limited to Stripe for payment processing. We are not responsible for the privacy practices, content, or security of any third-party website or service. We encourage you to review the privacy policy of any third party before providing personal information.

12. Changes to This Policy

12.1 Right to Update

We may update this Policy from time to time to reflect changes in our practices, applicable law, or the Service. The "Updated" date shown at the top of this Policy reflects the most recent revision.

12.2 Notification of Material Changes

Material changes will be communicated through one or more of the following: email notification to the address associated with your account, prominent notice on the Service, or requirement to re-accept updated terms.

12.3 Continued Use

Your continued use of the Service after the posting of changes constitutes acceptance of the revised Policy. If you do not agree with the revised Policy, you must discontinue use of the Service.

13. Contact

Questions, concerns, or requests regarding this Privacy Policy or your personal information should be directed to HoundCreek Research LLC at support@houndcreekresearch.com, or by mail to HoundCreek Research LLC, PMB 224, 11811 Shaker Blvd, Suite 204, Cleveland, OH 44120, United States.

1. Overview

This Refund and Credit Policy ("Policy") governs the restoration of memo credits and the limited circumstances in which money is returned for purchases made through the HoundCreek Research Service. This Policy supplements the Terms of Service. Capitalized terms not defined here have the meanings given in the Terms of Service.

2. Credit Restoration (Automatic)

2.1 When Credits Are Automatically Restored

The Company automatically restores the consumed credit to your account balance when a memo run results in any of the following outcomes:

A delivered memo whose conclusion is "Not Rated" or otherwise non-directional is not a blocked or failed run. It is a complete research artifact and a fulfilled order: the analysis was performed and the standardized pipeline determined that a directional rating was not warranted. The credit is consumed and is not restored. Disagreement with a memo's conclusion — including a Not-Rated outcome — is addressed in Section 4.1.

2.2 Timing

Automatic credit restoration occurs when the failed or blocked run is finalized, typically within minutes of the failure. The restored credit is reflected in your wallet balance immediately or upon your next page load.

2.3 Not a Refund

Automatic credit restoration is not a monetary refund. The credit returns to your account balance for future use. No money is returned to your payment method.

3. Refunds, Billing Corrections, and Cancellation

3.1 No Monetary Refunds

All purchases are final. The Company does not offer monetary refunds (return of funds to your payment method) of credit-pack purchases or subscription fees. Automatic credit restoration under Section 2 is the sole and exclusive remedy for failed or blocked memo runs. Money is returned to your payment method in only two circumstances:

• Billing corrections — You were charged an incorrect amount, charged more than once for the same purchase, or a technical error resulted in an unauthorized charge. Correcting a verified erroneous charge is not a discretionary refund; it is done as a matter of course. To obtain a correction, you must report the charge to customer support through the procedure in Section 3.2 so the Company can investigate and remedy the issue in a timely manner. Please contact us before initiating a payment dispute with your bank or card issuer (Section 5.1).
• Permanent service discontinuation — Governed by Section 6 and not discretionary.

If a service failure prevents you from using credits, the remedy is restoration of the affected credits (Section 2). If the Company can no longer restore your ability to use them because the Service has been permanently discontinued, Section 6 applies.

3.2 Billing-Correction Procedure

• Submit a billing-correction request in writing to support@houndcreekresearch.com.
• Include your account email address, the date and amount of the transaction, and a description of the reason for the request.
• Requests must be submitted within thirty (30) days of the transaction date (or within thirty (30) days of becoming aware of the issue, for billing errors discovered after the fact).
• The Company will acknowledge receipt within five (5) business days, investigate the reported charge, and respond with a determination within ten (10) business days.
• Verified billing errors are remedied promptly: the correction is processed to the original payment method via Stripe. Processing time depends on your bank or card issuer and is typically five to ten (5–10) business days.

3.3 Subscription Cancellation

You may cancel your subscription at any time through the billing portal in your account. Cancellation is forward-looking only: it stops all future charges, and no further renewal will be billed. Your subscription — including your current-period subscription credits — remains fully usable through the end of the billing period you have already paid for, after which the subscription ends and any unused subscription credits expire.

3.4 Subscription Fees

Monthly subscription fees are non-refundable. The Company does not prorate or refund the current or any prior billing period; your remedy is cancellation under Section 3.3, which stops future charges while preserving your paid-for access. Billing corrections under Section 3.1 apply equally to subscription charges, as does permanent service discontinuation under Section 6. Subscription credits are granted each billing period and expire at its end (use-it-or-lose-it); they are not separately refundable.

3.5 Statutory Rights

Nothing in this Policy limits any non-waivable right you may have under the consumer protection laws of your jurisdiction, including any statutory right of withdrawal, cancellation, or refund. If you are a consumer in a jurisdiction that provides a statutory withdrawal period for digital content or services (for example, the European Union or the United Kingdom), you acknowledge that delivery of research content begins when you submit a memo run and that, where permitted by law and subject to your express consent at the time of purchase, any statutory withdrawal right lapses once performance has begun.

4. Non-Refundable Circumstances

The following circumstances do not constitute grounds for a monetary refund. In every case, the only remedy for a failed or blocked memo run is automatic credit restoration under Section 2 — not a return of funds.

4.1 Disagreement with Research Content

Disagreement with a delivered memo's conclusions, valuation estimate, fair value, rating, analytical methodology, data sources, scenario analysis, or any other substantive aspect of the research. The product is the research process and delivered output, not an investment outcome or a guarantee that the user will agree with the analysis.

4.2 Investment Losses

A security's market price moving in any direction — including a direction inconsistent with a memo's analysis, valuation, or rating. HoundCreek Research does not guarantee investment results and is not liable for investment losses.

4.3 Dissatisfaction with Format or Presentation

Dissatisfaction with the length, depth, format, visual presentation, or structure of a delivered memo, provided the memo was delivered as a complete research artifact.

4.4 Failure to Read Terms

The user's failure to read, understand, or appreciate the Terms of Service, Disclosures, Privacy Policy, or research boundary before purchasing credits. All governance documents are available on the website; the Terms of Service, which incorporate this Policy and the other governance documents by reference, must be accepted before using the memo workflow.

4.5 Decision Not to Use Credits

The user deciding not to use remaining credits, absent permanent service discontinuation. Purchased one-time credits do not expire while the account is active. Subscription credits, by contrast, reset each billing period and expire at its end (use-it-or-lose-it); unused subscription credits are not refundable.

4.6 Change of Mind

A change of mind about the purchase after credits have been delivered to the account, absent any billing error or service failure.

4.7 Third-Party Actions

Actions by third parties, including but not limited to changes in market conditions, broker actions, regulatory changes, or acts of God, that affect the user's perception of the value of a delivered memo.

4.8 Credits Forfeited for Policy Violations

Credits forfeited pursuant to the enforcement provisions of the Terms of Service or the Acceptable Use Policy — including account termination for violations and fraudulent chargebacks (Section 5.2) — are not refundable.

5. Chargebacks

5.1 Request Before Disputing

If you believe a charge is incorrect, we strongly encourage you to contact us at support@houndcreekresearch.com before initiating a chargeback or payment dispute with your bank or card issuer. We are committed to resolving legitimate billing issues promptly.

5.2 Fraudulent Chargebacks

If a user initiates a chargeback that the Company determines to be fraudulent or without legitimate basis — for example, a chargeback filed after receiving and using a delivered memo — the Company reserves the right to:

• Suspend or terminate the user's account
• Forfeit any unused credits
• Pursue recovery of the disputed amount plus any fees imposed on the Company by the payment processor
• Report the activity to appropriate fraud-prevention services

6. Service Discontinuation

6.1 Permanent Discontinuation

If the Company permanently discontinues the Service entirely:

• The Company will announce the discontinuation by email to the address associated with your account and by prominent notice on the Service.
• Users with unused purchased one-time credits are entitled to a monetary refund for those credits at the per-credit price originally paid, on request submitted to support@houndcreekresearch.com within sixty (60) days of the discontinuation notice. Verified requests are processed to the original payment method within sixty (60) days of receipt.
• Subscription credits are not separately refundable (Section 3.4); however, if the Service is permanently discontinued during a paid subscription billing period, the pro-rated portion of that period's subscription fee for the unused remainder of the period is refundable on request in the same manner.
• Requests received after the sixty (60)-day claim window are handled as required by applicable law, including any unclaimed-property obligations.
• The Company will make reasonable efforts to provide users with access to their memo archives for at least thirty (30) days following the discontinuation announcement.

6.2 Feature Changes

Modifications, improvements, or changes to specific features of the Service — including supported tickers, delivery times, interface design, or methodology — do not constitute service discontinuation and do not trigger refund obligations, provided the core service (credit purchase and memo delivery) remains available.

7. Company Discretion

The Company does not make discretionary or goodwill monetary refunds. Except for permanent service discontinuation (Section 6) and any non-waivable statutory rights (Section 3.5), the Company's determination on any billing-correction request is final, except as required by applicable consumer protection law.

8. Contact

Billing-correction requests and billing questions should be directed to HoundCreek Research LLC at support@houndcreekresearch.com, or by mail to HoundCreek Research LLC, PMB 224, 11811 Shaker Blvd, Suite 204, Cleveland, OH 44120, United States.

1. Purpose

This Acceptable Use Policy ("AUP") defines the rules governing how you may and may not use the HoundCreek Research website, terminal workspace, and associated services (collectively, the "Service"). This AUP supplements the Terms of Service. Capitalized terms not defined here have the meanings given in the Terms of Service.

2. Permitted Use

You may use the Service to:

• Create, access, and maintain your authenticated account
• Purchase memo credits or subscribe to a monthly plan through the authorized checkout process
• Submit supported U.S.-listed ticker symbols for research memo generation
• Read, review, and revisit delivered research memos in your private terminal archive
• Cite, quote, and share excerpts and screenshots from delivered memos with proper attribution to HoundCreek Research — including publicly on social media, with a link to houndcreekresearch.com where the medium permits — in accordance with the intellectual property provisions of the Terms of Service
• Access the Company's public methodology, disclosure, legal, and informational pages

3. Prohibited Conduct

3.1 Automated Access and Scraping

You may not use automated tools, bots, scripts, crawlers, spiders, data miners, or any non-human means to access, scrape, extract, copy, download, monitor, index, or collect any content, data, or information from the Service without the Company's prior written consent. This prohibition includes, without limitation:

• Systematically downloading or caching memo content
• Scraping research outputs, pricing information, or website content
• Using headless browsers or automated testing frameworks to interact with the Service for data-extraction purposes
• Accessing any Service endpoint or interface, documented or undocumented, by any means other than the web application's intended user interface, for bulk or automated access

3.2 Security and Access Controls

You may not:

• Attempt to bypass, circumvent, disable, reverse-engineer, or interfere with any authentication, authorization, credit-balance, rate-limiting, quality gate, encryption, or other security or access-control mechanism of the Service
• Attempt to gain unauthorized access to any part of the Service, other users' accounts, or any system or network connected to the Service
• Probe, scan, or test the vulnerability of the Service or any connected system or network
• Use any device, software, or routine to interfere with the proper functioning of the Service
• Attempt to decompile, disassemble, or reverse-engineer any software component of the Service

3.3 Infrastructure and Performance

You may not:

• Impose an unreasonable or disproportionately large load on the Service's infrastructure
• Send or facilitate the sending of unsolicited or unauthorized communications through the Service
• Upload, transmit, or introduce any virus, trojan, worm, logic bomb, ransomware, spyware, adware, or other malicious code
• Interfere with or disrupt the Service, servers, networks, or other users' access
• Use the Service in any manner that could damage, disable, overburden, or impair the Service

3.4 Content Redistribution

You may not:

• Reproduce, copy, distribute, publish, display, or transmit any complete memo (or substantially all of one) without the Company's prior written authorization (sharing excerpts and screenshots with attribution and a source link, as permitted by Section 7.2 of the Terms of Service, is not a violation of this bullet)
• Resell, sublicense, syndicate, or white-label memo content for commercial purposes
• Create derivative works from memo content for commercial distribution
• Use memo content to train, fine-tune, develop, or improve any machine learning model, artificial intelligence system, large language model, or automated research tool without the Company's prior written consent
• Aggregate memo content with other content to create a competing research product or service
• Remove, alter, or obscure any copyright notice, attribution, or proprietary marking

3.5 Misrepresentation

You may not:

• Misrepresent HoundCreek Research outputs as personalized investment advice, individual recommendations, or guaranteed predictions
• Present memo content as your own original research in any commercial publication, newsletter, blog, social media account, or other media without attribution
• Impersonate any person or entity, or falsely state or misrepresent your affiliation with any person or entity
• Represent or imply an endorsement, sponsorship, or affiliation with HoundCreek Research that does not exist
• Use HoundCreek Research's name, logo, or trademarks in any manner that suggests endorsement of your investment activities, products, or services

3.6 Account Integrity

You may not:

• Create multiple accounts for the purpose of circumventing credit limits, access restrictions, or enforcement actions
• Share, sell, transfer, or otherwise provide access to your account credentials or authenticated session to any other person
• Use another person's account without their express authorization and the Company's written consent
• Provide false or misleading information during account registration

3.7 Unlawful Use

You may not:

• Use the Service for any purpose that violates applicable local, state, national, or international law or regulation
• Use the Service to facilitate or promote market manipulation, insider trading, front-running, spoofing, layering, wash trading, or any other unlawful trading activity
• Use the Service to launder money or facilitate the financing of terrorism
• Use the Service to violate any sanctions or export control regulations
• Use the Service in connection with any fraudulent scheme or deceptive practice

3.8 Exploitation of Research Pipeline

You may not:

• Submit requests designed to probe, test, or reverse-engineer the Company's research methodology, analytical pipeline, valuation models, or quality gate for any purpose other than legitimate personal research consumption
• Submit requests in patterns designed to reconstruct proprietary model parameters, training data, or algorithmic processes
• Systematically submit requests across tickers for the purpose of building a competing research product or database

4. Enforcement

4.1 Investigation

The Company reserves the right to investigate any suspected violation of this AUP. During an investigation, the Company may suspend your access to the Service.

4.2 Enforcement Actions

If the Company determines that you have violated this AUP, the Company may take one or more of the following actions at its sole discretion:

• Issue a written warning
• Temporarily suspend your account for a specified period
• Permanently terminate your account
• Cancel any active subscription, effective immediately or at the end of the current billing period, without refund of amounts already charged (see the Refund and Credit Policy)
• Forfeit unused credits in your account without refund
• Remove or disable access to any content that violates this AUP
• Report suspected illegal activity to appropriate law enforcement or regulatory authorities
• Pursue civil legal remedies, including injunctive relief and monetary damages
• Cooperate with law enforcement investigations and legal proceedings

4.3 No Obligation to Monitor

The Company is not obligated to monitor all use of the Service for compliance with this AUP. The absence of enforcement in any particular instance does not constitute a waiver of the Company's right to enforce this AUP in the future.

5. Reporting Violations

If you become aware of any violation of this AUP, please report it to legal@houndcreekresearch.com. Reports may be made anonymously.

6. Changes

The Company reserves the right to modify this AUP at any time. Material changes will be communicated in accordance with the Terms of Service.

7. Contact

Questions about this Acceptable Use Policy should be directed to HoundCreek Research LLC at legal@houndcreekresearch.com, or by mail to HoundCreek Research LLC, PMB 224, 11811 Shaker Blvd, Suite 204, Cleveland, OH 44120, United States.