GENERAL AI DISCLAIMER

DwellFi, Inc. (collectively, “DwellFi”, “we”, “us” or “our”) employs specialized, permissioned Artificial Intelligence (”AI”) Agents by leveraging advanced language and automated workflows that autonomously execute fund-related tasks by processing structured and unstructured data. While AI enhances efficiency and accuracy, it is important to understand the scope, limitations, and responsibilities associated with AI-driven processes.

1. DATA AND USE LIMITATIONS

Data Processing

AI agents process various types of data, including personal, financial, and transactional information, strictly for purposes related to fund administration and investor relations. Data processed by AI agents is transformed from unstructured formats into structured AI-ready data to enable efficient automation and real-time insights.

Purpose Limitation & Use

The AI agents operate solely to streamline internal fund administration workflows, enhance investor communication by providing real-time fund insights, and facilitate seamless fund administrator transitions. Data processed is not used beyond these defined purposes without explicit consent or contractual agreement.

2. LIMITATION OF OUR PLATFORM

AI-generated outputs

Our platform’s AI models automate tasks and generate the outputs, recommendations, and insights based on data inputs, algorithms, and statistical probabilities. While we strive to ensure high accuracy, AI-driven results should not be considered perfect, complete, unbiased, or fully reliable. AI models may have limitations due to biases in the underlying data, modeling techniques, and changes in market conditions. Further, these models may be trained on imbalanced or inadequate data which may generate a myopic output. All AI outputs should be interpreted as advisory rather than definitive.

No guarantee of accuracy or completeness

The information and insights provided through our Platform and AI tools are intended for informational purposes only and to augment human decision-making but do not constitute investment, financial, legal, professional or any other sort of advice. Users should perform their own analysis or consult with a qualified professional before making decisions based on the data provided by the platform. DwellFi will not be liable for the decisions you make through using our platform or our AI agents.

Human oversight

DwellFi encourages human oversight in reviewing AI-generated insights. Our Platform allows for human-in-the-loop processes to ensure that AI outputs can be corrected or adjusted by the users as necessary. All outputs should always be reviewed and validated by qualified professionals before taking final actions based on such information

3. AI-GENERATED CONTENT AND COPYRIGHT

Copyright protection over Platform generated content

Content generated by DwellFi’s using our platform or by our AI Agents, including but not limited to financial insights, data analysis, and reports, may involve the use of AI and machine learning models. To the extent that content is generated solely by AI systems without human authorship, such content may not be protected by international or US copyright law.

Despite this, the use of all AI-generated content is subject to DwellFi’s Terms of Service, and users are granted a non-exclusive, worldwide, royalty-free license to use, reproduce, and distribute the generated content, provided that they do not claim authorship or ownership of the AI-generated material.

When using or publishing content generated through our platform, we encourage all users to disclose that the information was produced using AI. This disclosure should include appropriate clarifications about the extent to which human oversight or editorial changes have been exercised. We recommend including disclaimers similar to or more comprehensive than those found in this DwellFi General AI Disclaimer, emphasizing the limitations of the data and the user’s responsibility when relying on it.

Our intellectual property rights over the Platform

All materials, content, and tools provided on our platform, including the software, AI agents (off-the-shelf or customized), algorithms, designs, logos, and other proprietary information, are the intellectual property of DwellFi and are protected under applicable laws including copyright, patent, trademark and trade secret.

Unauthorized reproduction, distribution, or modification of any materials from our Platform without our prior written consent is strictly prohibited. Any rights not expressly granted herein are reserved by DwellFi.

4. SECURITY PROTECTION AND COMPLIANCE

Security and Access Control

DwellFi ensures that AI agents operate within a highly secure environment, protected by enterprise-grade controls such as encryption, multi-factor authentication, role-based access, and tenant-specific encryption keys. AI agents have permissioned access limited to the minimum data necessary to perform their tasks.

SOC 2 Type 2 certification

DwellFi is SOC 2 Type 2 certified, reflecting our commitment to implementing strict data security, privacy, and operational controls. We continuously monitor our platform to ensure the integrity, confidentiality, and availability of data processed by our AI systems. This certification demonstrates that we adhere to best practices in safeguarding sensitive financial data and meeting the rigorous standards expected in fund operations.

5. Third-Party Integrations

Where AI agents incorporate third-party AI services, large language models, or data sources, DwellFi ensures these providers comply with equivalent privacy and security standards. Data sharing with third parties is governed by strict contractual safeguards. We require our AI service providers to use your information only for the purpose of providing the requested output and we do not allow those providers to train their AI models using your data. The input data is deleted once a response is generated and sent back to our platform.

6. NO REPRESENTATION OR WARRANTY

While we make every effort to ensure the functionality and reliability of our AI agents, DwellFi disclaims all warranties, whether express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, or non-infringement. We do not warrant the accuracy, reliability, or functionality of the suggested AI agents or resources and do not warrant that the suggested AI agents or resources will meet users’ requirements, be error-free, or operate without interruption.

All users assume full responsibility for the use of information and tools provided by the DwellFi Platform. Any performance, functionality, accuracy, or impact of these tools on the user’s business or operations is the sole responsibility of the user.

We reiterate that all users are advised to consult with professionals and exercise their own judgment when using AI agents and interpreting AI-generated outputs.

7. LIMITATION OF LIABILITY

In no event shall DwellFi be liable to the users or any third party for any direct, indirect, incidental, consequential, special, or exemplary issues, damages and losses or negative consequences including but not limited to damages for loss of profits, data, or business interruption, arising out of or in connection with the use or performance of the suggested AI tools or resources.

8. CHANGES TO THE DISCLAIMER

We reserve the right to modify this disclaimer at any time. Any changes will be effective immediately upon posting the revised disclaimer. Continued use of AI Platform constitutes acceptance of the updated terms.

9. EU AI ACT COMPLIANCE DISCLAIMER

Limited-risk AI system

As per the directive of the European Union Artificial Intelligence Act (Regulation 2024/1689 of the European Parliament and the Council of the European Union) (“AI ACT”), DwellFi’s AI Platform is categorized as a limited-risk system, as it is used for administrative and operational functions rather than high-risk activities, such as credit scoring or investment decisions. Although our AI tools automate aspects of fund operations, human intervention and oversight are integral to the DwellFi Platform's design, ensuring that human operators can intervene, review, and modify AI outputs as needed.

Transparency and user awareness

We ensure that users of our platform are informed when AI-driven processes are used in administrative and fund operations functions. The role of AI in these processes is fully transparent, and users can request human oversight or review at any stage. AI is used solely to enhance operational efficiency, not to replace human judgment.

Data management and privacy

DwellFi is committed to data protection. All personal data processed by our AI Platform complies with the General Data Protection Regulation (”GDPR”) and the California Consumer Privacy Act (”CCPA”). Data used for training and operation is handled with care, ensuring user privacy and security. Please refer to our Privacy Policy and the “Security Protection and Compliance” section above to learn more about how we ensure user privacy and security through the careful handling of data in a fair and transparent manner.

User education

To ensure effective use of our platform, Users are encouraged to:

• familiarize themselves with the system's features; and
• understand the context and limitations of the AI’s outputs (as detailed in “Limitations of Our Platform” above).

For any queries related to the functioning and operation of our AI-powered platform, please reach out to support@dwell.fi.

Monitoring and improvement

DwellFi continuously monitors its AI models for performance, fairness, and accuracy, and to ensure they operate as intended. We are committed to improving our systems in accordance with evolving regulations and ethical standards.

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Last updated on: June 27, 2025