Expert Understudy Data Protection and Security Addendum

Version 1.0, effective November 5, 2026. This Addendum forms part of the Expert Understudy Terms of Service. Capitalized terms not defined here have the meanings given in those Terms. The Wallace Understudy product for firms has its own addendum at wallaceunderstudy.io.

Purpose of This Document

The firm edition of this Addendum is built around client files staying on the user’s device. This edition is built differently. The Expert Understudy includes the Client data tab and Validation, so a client file is read in Customer’s browser and only its column names and the summary described in Section 2(a-2) are sent, as in the firm edition; but an expert also types and uploads directly into the Services, and what an expert types and uploads reaches Wallace.

So this Addendum does three things. It states plainly what Wallace holds and how it gets there. It applies service provider and processor protections to that information. And it gives experts in regulated fields the specific undertakings, and the specific limits, they need in order to reach their own conclusions.

The point, stated plainly.

Keep client details out of what you type and upload, read client files only on the Client data tab, and the Services are designed to hold what you know, not who your clients are. Wallace will never make client consent, a client-facing disclosure, or a third party’s approval a condition of service. Each expert must still reach their own conclusion under their own professional rules, and Wallace cannot waive a duty an expert owes to a client, a patient, an employer, or a regulator.

1. Definitions and Roles

(a) Customer Data. Interview Content, Map, Documents, Meeting Content (including the short quote kept with each statement drawn from a transcript), what Wallace keeps from client files under Section 2(a-3), answers to Checks, Playbook content, questions, chats, and Output associated with Customer’s account, together with Personal Information about the Expert and Team Members.

(b) Client Information. Has the meaning given in the Terms of Service. Customer must keep Client Information out of the Services, except that Customer may read a client file on the Client data tab, which sends only what Section 2(a-2) describes, and may supply meeting transcripts, which are handled as Section 2(a) describes. What Wallace keeps from a client file is Customer Data. Any other Client Information that reaches Wallace is handled as Customer Data.

(c) Personal Information. Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with an identified or identifiable natural person, as defined under applicable U.S. privacy law, including “personal information,” “personal data,” and “nonpublic personal information.”

(d) Security Incident. A confirmed unauthorized access to, acquisition of, use of, or disclosure of Customer Data in Wallace’s possession or control. Unsuccessful attempts, pings, scans, and routine failed log-ins are not Security Incidents and are not individually reportable.

(e) Roles. Where a business opens the account, Customer is the business, controller, and owner of Customer Data, and Wallace is a service provider and processor that acts only on Customer’s documented instructions. Where an Individual opens the account, Customer owns Customer Data and Wallace processes it to provide the Services to Customer. The service provider and processor terms of this Addendum apply for that Individual’s benefit to the extent applicable law recognizes them for a natural person, and Wallace is otherwise the business and controller as the Privacy Policy describes. In every case Wallace is an independent business and controller as to its own account registration, support, marketing, and Service Telemetry records, for the limited purposes stated in the Privacy Policy.

2. What Wallace Holds

(a) Meeting transcripts. The Services are designed so that a meeting or call transcript supplied by Customer is pseudonymized on Customer’s device, with known client names, contact details, and account numbers replaced before any transmission, and so that the transcript itself is not persisted by Wallace. Amounts, including round amounts and balances, and partial account numbers (for example, “card ending 4417”) may remain. Each statement drawn from a transcript keeps a short quote from it as its source, whether or not Customer later confirms the statement; the statements and their quotes are Customer Data, and rejecting a statement deletes it and its quote. A statement drawn from a transcript enters the Playbook only after Customer confirms it. Name detection is automated and can miss things. When Customer adds notes one at a time, Customer sees the result before it is sent; notes read in bulk from a connected folder are sent without that preview.

(a-1) Client files. On the Client data tab, a client file (for example, a spreadsheet exported from Customer’s own records) is opened and read in Customer’s browser. The file itself, whole rows, and the values of any column marked private never leave Customer’s device. When a file is read, its column names are sent to Wallace, where an AI step suggests which columns identify clients and what each column holds. This happens before the review card is shown, so column names should not contain client details; if they do, those details reach Wallace and its AI model subprocessor. The review card then shows the column names, which columns are marked private, each column’s type, and the category labels and staff codes proposed for release. Customer can mark columns private or shared, choose which labels to release, and answer questions about columns. The card does not show the counts, bands, and months that will be sent. A later file with the same columns as one already read is summarized with the earlier choices and stored without showing the card again. Client emails and planning PDFs added on the same tab are read in the browser, and only a writing-style tally from the emails and a count of the PDFs are sent.

(a-2) What a client file sends. When Customer reads a file, Wallace receives: for every column, its name, its type, and how many cells are filled, empty, or distinct, and a private column sends only this; for each shared column, dates as months or years (never a day), amounts and other numbers as bands with a median band (never an exact amount), category columns as the labels Customer releases (a label is proposed only if it has at most 40 characters and appears in at least 3 rows, and at most 25 are proposed per column), yes/no columns as counts and the spellings used, and ID columns as their shape and how many values repeat; counts across pairs of shared columns, with any group of one or two rows withheld; staff codes (Staff 1, Staff 2, and so on) in place of staff names, and when a column is detected as naming staff, its codes are sent without a separate release step; and the number of rows, the months the file covers, a fingerprint (a one-way hash) of the file, and Customer’s typed answers to the card’s questions (an answer holding a date, an amount, a known client name, or an account number is blocked in the browser). Detection of identifying columns and values is best effort. Customer decides what it marks shared and is responsible for it.

(a-3) What Wallace keeps from a client file, and Validation. Anthropic, Wallace’s AI model subprocessor, reads the summary and writes facts about how Customer works. Wallace keeps those facts; the column names and what each means; which columns were private (names only); the released labels and staff codes; and, for each file, its row count, the months it covers, and its fingerprint. Wallace does not keep the summary itself. Deleting a client file removes its facts from use, but they stay in the database until Customer’s understudy content is erased under Section 8(a) or deleted under Section 8(c). Validation compares the Playbook with the facts from client files. It asks whether a captured rule is still right: it measures the Playbook against activity, not a person against the Playbook, and it is not an employment, performance, or compliance metric. Every seat in the account can view it.

(a-4) What stays in the browser. To take client names out of meeting notes, Customer’s browser keeps, on that computer, a list of up to 5,000 client names seen in client files, and the key to the staff codes. Neither is sent to Wallace. Signing out does not clear them; clearing the browser’s data for the site does.

(b) Everything else reaches Wallace. Interview Content, questions in Ask, and answers to Checks reach Wallace’s servers and its AI subprocessors as Customer wrote them. Documents are uploaded; a scanned page is sent to an AI subprocessor to be read, and Wallace keeps a Document’s cleaned text, not the original file. Folder and file paths from a connected folder (a local folder, or Microsoft OneDrive or SharePoint) are sent to an AI subprocessor to sort them. Section 3 of the Terms of Service describes each path.

(c) Automated safeguards. Wallace applies automated safeguards: a question or a Document holding a Social Security number written with dashes, a valid payment card number, or a labeled account number is refused, as is a Document whose title is only a client’s name, and an automated privacy step removes client names, contact details, ID numbers, dates of birth, and exact amounts from Interview Content, questions in Ask, and Documents before they are stored. The privacy step does not remove health conditions, and nothing in the Services detects information about minors (see Rider E). Answers to Checks are stored as typed, with neither safeguard. The step is best effort. Text reaches the AI model subprocessor before the step runs, because that subprocessor runs it; a scanned page is read by it before the refusal check runs; and a Document waiting in the queue holds its raw text until the step runs. These safeguards reduce risk. They are not a warranty that Client Information will never be held.

(d) No re-identification. Wallace will not attempt to re-identify any individual from scrubbed text, will not permit any subprocessor to do so, and will contractually prohibit it.

(e) Notice of change. Wallace will not change the Services so that a meeting transcript leaves Customer’s device before it is pseudonymized without at least sixty (60) days’ prior written notice to Customer.

(f) Verification. On reasonable request, Wallace will provide a data-flow diagram of every path by which data leaves Customer’s device, an inventory of the network destinations the application sends data to, and its documented assessment of re-identification risk for the privacy step. Customer may verify that behavior in its own environment using standard network inspection tools, and the Terms of Service do not prohibit doing so.

(g) [Reserved.]

2.1 Customer’s Corresponding Obligation

These protections work only if Customer keeps Client Information out of what it types and uploads. Customer will not upload Client Information as a Document and will not enter client, patient, or customer names, account or record numbers, tax identification numbers, health information, or other direct identifiers into the interview, Ask, Checks, or any other field. On the Client data tab, Customer will read only files whose column names hold no client details, will mark private any column that holds health information or information about a child, and is responsible for each column it marks shared and each label it releases. Information Customer supplies in breach of this Section is handled under Sections 3 through 9 like any other Customer Data.

3. Processing of Customer Data

(a) Documented instructions. Wallace processes Customer Data only on Customer’s documented instructions, which consist of this Addendum, the Terms of Service, and Customer’s use of the Services’ configuration options. Wallace will notify Customer if it believes an instruction violates applicable law.

(b) Enumerated business purposes. The specific business purposes for which Customer discloses Customer Data to Wallace, and the only purposes for which Wallace may process it, are: (i) conducting the interview and building and version-controlling the Map; (ii) distilling Documents and Meeting Content into candidate items, reading the summaries of client files Customer reads on the Client data tab and writing and keeping facts from them, and compiling and updating the Playbook; (iii) operating Ask, grading Checks, operating the Knowledge map and Validation, and routing questions to the Expert; (iv) providing, authenticating, and administering seats; (v) providing technical support requested by Customer; (vi) detecting, preventing, investigating, and responding to security incidents, fraud, and abuse; (vii) maintaining audit and access logs; (viii) complying with legal obligations; and (ix) [Reserved.] No other purpose is authorized.

(c) Prohibited processing. Wallace will not: (i) sell or share Customer Data, as “sell” and “share” are defined in California Civil Code sections 1798.140(ad) and (ah); (ii) retain, use, or disclose Customer Data for any purpose other than the business purposes enumerated above, including any commercial purpose not specified; (iii) retain, use, or disclose Customer Data outside the direct business relationship between Wallace and Customer; (iv) combine Customer Data with personal information received from or on behalf of any other person, or collected from its own interactions with any consumer, except as expressly permitted by applicable law to detect security incidents or resist malicious action; or (v) use Customer Data to train, fine-tune, evaluate, benchmark, or improve any artificial intelligence or machine learning model, whether in identified, de-identified, or aggregated form.

(d) Cross-customer prohibition. Wallace will not use Customer Data to build or improve services provided to any other person, and will not create cross-customer comparisons, industry benchmarks, or peer cohorts from Customer Data. Where Wallace uses information to improve the Services, it will do so only from Service Telemetry as defined in Section 3(e).

(e) Service Telemetry. Wallace collects operational data about the software itself: feature usage counts, session and page metrics, error and exception rates, latency and performance measurements, and browser and device type, by account identifier. Wallace does not configure telemetry to capture the substance of Interview Content, Documents, Meeting Content, client files, Playbook claims, questions, or Output, and will not do so. Telemetry is not Customer Data for purposes of the use restrictions in Section 3(c)(v), and Wallace confirms telemetry does not and will not include tax return information, nonpublic personal information, or privileged material.

(f) Compliance and notice of inability. Wallace will comply with the obligations applicable to a service provider and processor under applicable U.S. privacy law, will provide the same level of privacy protection those laws require of Customer, and will notify Customer promptly if it determines it can no longer meet those obligations.

(g) Confidentiality of personnel. Wallace personnel with access to Customer Data are bound by written confidentiality obligations that survive termination of employment or engagement, are subject to background screening consistent with role sensitivity before production access is granted, and receive privacy and security training at onboarding.

4. Subprocessors

(a) Authorization. Customer authorizes the subprocessors listed in Exhibit B. Wallace will maintain a current list and will give at least thirty (30) days’ notice before engaging a new subprocessor that will process Customer Data.

(b) Objection. Customer may object to a new subprocessor within thirty (30) days on reasonable data protection grounds. The parties will work in good faith toward a resolution. If none is reached, Customer may close its account.

(c) Flow-down and liability. Wallace will impose on each subprocessor written obligations no less protective than this Addendum, including the prohibitions on sale, sharing, secondary use, model training, and re-identification. Wallace remains fully liable to Customer for each subprocessor’s performance.

(d) United States. Customer Data is stored and processed in the United States. A small number of named Wallace personnel, including engineering personnel located in India, may access it remotely to operate and support the Services, under written confidentiality obligations and with access limited to what their role requires. From September 2026 until November 2026 the database was hosted in Canada (Montreal); it is now hosted in the United States (Ohio).

(e) AI model subprocessors. Wallace uses Anthropic for nearly all model work, including the privacy step, reading scanned pages, document reading, client files’ column names and summaries, the interview, the Playbook, Ask, Checks, and sorting connected folders, and OpenAI only to build the search index (numerical embeddings) from passages of stored Document text, interview and meeting answers, facts (including facts drawn from client files), Playbook claims, and question topics. Model calls are made both from the web application hosted by Vercel and from the backend hosted by Amazon Web Services. Each is engaged under commercial terms that prohibit training on Customer Data.

5. Security Measures

Wallace will maintain the administrative, technical, physical, and organizational safeguards described in Exhibit A. Wallace may update Exhibit A but will not materially reduce the overall level of security during the beta.

6. Security Incidents

(a) Notification within 72 hours. Wallace will notify Customer of a Security Incident without undue delay and in any event no later than seventy-two (72) hours after Wallace confirms it.

(b) Contents. The notice will describe, to the extent then known and with updates as more is learned: the nature of the incident, the date or range of dates, the categories and approximate volume of information involved, the individuals or accounts affected, the likely consequences, the containment and remediation steps taken and planned, and a point of contact.

(c) Cooperation. Wallace will investigate, contain, and remediate at its own expense, preserve relevant evidence and logs, and provide the information and assistance Customer reasonably needs to meet its own obligations.

(d) Customer controls downstream notice. Wallace will not notify Customer’s clients, Customer’s regulators, or any media on Customer’s behalf, and will not identify Customer publicly in connection with an incident, without Customer’s prior written consent, unless Wallace is independently required by law to do so. Customer controls the content, timing, and method of any notice to its own clients and regulators.

(e) Root cause. Within thirty (30) days of closing an incident, Wallace will provide Customer a written root cause analysis and corrective action plan.

(f) No admission. Notification is not an acknowledgment of fault or liability.

7. Legal Process and Government Demands

If Wallace receives a subpoena, warrant, court order, civil investigative demand, regulatory request, or other legal process seeking Customer Data, Wallace will, unless legally prohibited: notify Customer promptly and before producing anything; provide Customer a copy of the demand; give Customer a reasonable opportunity to object, move to quash, or seek a protective order; assert applicable privileges and confidentiality protections on Customer’s behalf pending resolution; disclose only the minimum required; and reasonably cooperate with Customer’s efforts to limit disclosure, at Customer’s expense. Where notice is legally prohibited, Wallace will seek to lift the prohibition and will notify Customer as soon as permitted. Wallace will maintain a record of demands received and, to the extent lawful, will report the number received on request.

8. Retention, Deletion, and Assistance

(a) During the term. Customer may delete any stored Document or client file at any time, and may edit any statement in the Playbook. A statement can be retired only when a stale, drift, or conflict question offers it, and a retired statement is designed to stay retired when the Playbook is next compiled. Customer may reject a statement drawn from a meeting transcript before confirming it; rejecting deletes it without a record, so the same transcript can suggest it again. Erasing understudy content in Settings removes all of it: the Playbook and its versions, Documents, the facts and layouts kept from client files, statements drawn from meetings, the interview and the Map, Ask threads and gaps, saved chats, Checks, routed questions, source settings, and the folder tree, and the Expert starts again from the interview. Erasing does not delete the account, its members, its profile, any continuity test records, or usage counts. Saved chats are retained for thirty (30) days. Wallace otherwise retains Customer Data until the account closes unless Customer directs otherwise.

(b) Copies. On written request during the term and for thirty (30) days after access ends under Section 14(d) of the Terms of Service, Wallace will prepare by hand and give Customer its Map and Playbook in a common format and the stored (cleaned) text of its Documents, at no charge and without precondition. The Services have no self-serve export. Wallace does not keep the original files Customer uploads, so it cannot return them. Wallace claims no proprietary or derivative-works interest in that material.

(c) Deletion. Customer may close its account by writing to support@wallacefinance.io with the subject “Close My Account” (Settings shows the address), and Wallace completes the closure by hand within thirty (30) days of the request. Within thirty (30) days after an account closes or the period in Section 8(b) ends, Wallace will delete Customer Data from active systems, and from backups on a rolling cycle not exceeding thirty-five (35) days, and will confirm deletion in writing on request. Copies held by Sentry, PostHog, and Resend are kept under their own retention. Wallace may retain records it is independently required by law to keep, and Service Telemetry, in each case subject to continuing confidentiality obligations and the use restrictions in this Addendum.

(d) Legal hold. On written notice of a litigation hold, Wallace will, as a manual step, suspend deletion of the identified Customer Data until Customer releases the hold. The Services have no legal-hold setting.

(d-1) [Reserved.]

(f) Assistance with individual rights. Wallace will, at no additional charge, provide the tooling or assistance Customer reasonably needs to respond to a request from the Expert or a Team Member to access, correct, delete, or port personal information. If Wallace receives such a request directly, it will not respond substantively on Customer’s behalf but will promptly forward it to Customer.

(g) Assistance with assessments and notices. Wallace will provide, on reasonable request, information Customer needs for a privacy or data protection impact assessment, and the vendor name, product name, purpose, and data categories Customer needs to prepare a workforce notice about the use of artificial intelligence.

9. Audit and Diligence

(a) Standing package. On reasonable request Wallace will provide its current subprocessor list and a description of its security measures and data flows and, once obtained, its SOC 2 Type II report or equivalent third-party attestation.

(b) Verification. Customer may, no more than once in any twelve-month period and on thirty (30) days’ notice, take reasonable and appropriate steps to verify that Wallace is using Customer Data consistently with its obligations, through written questionnaire or documentary review.

(c) Remediation. If verification identifies unauthorized use of Customer Data, Wallace will, on notice, take reasonable and appropriate steps to stop and remediate it.

(d) Regulator access. Where Customer is subject to examination by a governmental or professional regulator with authority over Customer’s use of the Services, Wallace will provide the regulator with reasonable access to relevant records concerning the Services, subject to confidentiality protections.

10. Sector Riders

The following riders apply automatically to Customers in the identified categories. They add to, and do not limit, the rest of this Addendum. None of them permits Client Information in the Services beyond what Section 2 describes.

10.1 Rider A: Investment Advisers, Broker-Dealers, and Other Financial Institutions

This rider applies where Customer is registered with the Securities and Exchange Commission or a state securities authority as an investment adviser, is a broker-dealer, or is otherwise a “financial institution” under the Gramm-Leach-Bliley Act.

(a) Service provider status. To the extent Customer is subject to Regulation S-P, 17 C.F.R. Part 248, Wallace acknowledges it is a service provider to Customer and will take appropriate measures to protect against unauthorized access to or use of customer information.

(b) 72-hour notice. Wallace will notify Customer as soon as possible and no later than seventy-two (72) hours after becoming aware that a breach in security has occurred resulting in unauthorized access to a customer information system maintained by Wallace, as required by Regulation S-P.

(c) Nonpublic personal information. The Services are not designed to hold nonpublic personal information, and Customer will keep it out of what it types and uploads. A client file read on the Client data tab sends only what Section 2(a-2) describes, which is drawn from client records, and questions, answers to Checks, and Documents can reach Wallace before an automated safeguard acts, so this rider does not state that the volume held is nil; Wallace treats what it keeps from client files as customer information under this rider.

(d) No advisory activity by Wallace. Wallace confirms that the Services do not provide advice regarding securities on Wallace’s behalf and do not exercise discretion over or take custody of any client assets. Ask answers from Customer’s Playbook and has no built-in refusal to recommend the purchase, sale, or holding of a security or investment, so Customer is responsible for how it and its Team Members use Output. Wallace is Customer’s software vendor and not an adviser to Customer’s clients.

10.2 Rider B: Law Firms and In-House Legal Departments

This rider applies where Customer is a lawyer, a law firm, or a legal department.

(a) Purpose and agency. Customer engages Wallace to assist Customer’s lawyers in the organization and retrieval of Customer’s own practice methodology, in support of the rendition of legal services by those lawyers. Wallace acts as an agent of Customer’s lawyers for that purpose.

(b) Confidentiality co-extensive with Rule 1.6. Wallace will treat all Customer Data as confidential to the same extent Customer’s lawyers are obliged to protect information relating to the representation of a client, and acknowledges that such information may be subject to the attorney-client privilege and the work product doctrine.

(c) No training. Wallace does not use Customer Data to train or improve any model, does not permit any subprocessor to do so, and maintains per-tenant isolation with no cross-customer retrieval.

(d) Non-waiver. The parties do not intend any disclosure under this Agreement to waive any privilege or protection. Wallace will assert applicable privileges on Customer’s behalf pending resolution if served with legal process, and will give Customer notice before producing anything, as provided in Section 7.

(e) No proprietary claim. Wallace asserts no proprietary or derivative-works right in any information Customer submits or in the Playbook compiled from it, and will return or delete it as provided in Section 8.

(f) No legal services. Wallace does not practice law, does not provide legal advice, and does not exercise independent legal judgment. Ask is designed to answer from what the lawyer supplied and to respond that a topic is not covered rather than generate an unsupported answer.

10.3 Rider C: Accounting Firms and Tax Practices

This rider applies where Customer is a certified public accounting firm, an enrolled agent, or a tax return preparer.

No tax return information.

Customer must not upload or enter tax return information, including by reading a client file that holds it on the Client data tab, because what a client file sends under Section 2(a-2) is drawn from the file. This is a condition of use, not a recommendation, and it exists because Internal Revenue Code section 7216 makes an unauthorized disclosure or use of tax return information a criminal offense. Customer Data is stored and processed in the United States. From September 2026 until November 2026 the database was hosted in Canada (Montreal). A small number of named Wallace personnel, including engineering personnel located in India, may access Customer Data remotely to operate and support the Services, under written confidentiality obligations and with access limited to what their role requires.

(a) Confidentiality by contract. This Addendum is a contractual agreement with a third-party service provider to maintain the confidentiality of confidential client information, for purposes of AICPA Code of Professional Conduct interpretation 1.700.040.

(b) If tax return information reaches Wallace. To the extent any tax return information were nonetheless to reach Wallace, Wallace will not use or disclose it for any purpose other than providing the Services, specifically will not use it for model training, analytics, benchmarking, marketing, or product development, and will delete it on request.

(c) Independence. The Services are a tool Customer operates. Wallace does not perform management functions, does not design or implement systems of internal control for Customer, and does not make decisions on Customer’s behalf. Wallace will provide information Customer’s independence group requires to evaluate the engagement against nonattest services rules.

10.4 Rider D: Other Fields

This rider applies where Customer works in architecture, engineering, construction, land services, the trades, consulting, creative work, technology, or any other field without a sector privacy regulator.

(a) Trade secrets. Wallace acknowledges that Customer’s knowledge, bid and pricing histories, vendor relationships, and Playbook are or may be trade secrets; that this Addendum forms part of Customer’s reasonable measures to maintain their secrecy; and that Wallace will not use them for any purpose other than providing the Services to Customer. Wallace will not use Customer’s knowledge to develop, improve, or inform any product or service provided to any other person, including a competitor of Customer.

(b) No responsible charge. The Services do not perform engineering, architecture, surveying, or any other licensed professional service, produce no sealed or stamped work product, and do not relieve any licensed professional of responsible charge. Output is drawn from what Customer supplied.

(c) Title and settlement services. If Customer provides title, escrow, or settlement services, Customer is a financial institution under the Gramm-Leach-Bliley Act and Rider A applies in addition to this rider.

10.5 Rider E: Health Care

This rider applies where Customer is a clinician, a therapist, or anyone else who provides or supports health care.

(a) No protected health information. Customer will not enter protected health information or anything that identifies a patient. Nothing in the Services detects or removes health information: the privacy step does not remove health conditions, and the Client data tab is not designed to mark a diagnosis, condition, medication, or other health column private on its own. Customer will not upload a Document or a meeting transcript that holds health information, will mark private, on the review card, any column of a client file that holds it, and will not release a label that names a condition. Wallace is not a covered entity or a business associate, will not sign a business associate agreement, and has not designed the Services to meet the requirements of HIPAA.

(b) Not part of care. The Services do not diagnose, treat, or advise on any patient. Customer will not use Output to make a decision about an individual patient, and the Services are not for emergencies.

(c) Children. Nothing in the Services detects or removes information about minors. Customer will keep anything that identifies a child out of the Services, and will mark private, on the review card, any column of a client file that holds information about a child.

10.6 Rider F: Individuals

This rider applies where Customer is an Individual.

(a) Your content. Wallace processes Customer’s content to provide the Services to Customer and for no other purpose. Sections 3(c), 3(d), 6, and 8 apply for Customer’s benefit.

(b) Other people’s information. Customer is responsible for not supplying other people’s confidential information, including an employer’s trade secrets or a former client’s data, and for its own professional obligations where it uses the Services in a profession.

(c) Investing. Where Customer’s profession involves investing or securities, Customer acknowledges that Wallace does not review Customer’s process and is not Customer’s investment adviser, and that Section 5.2 of the Terms of Service applies.

(d) Your rights. Customer’s privacy rights are described in the Privacy Policy and apply to Customer directly.

Exhibit A: Security Measures

Wallace maintains a written information security program covering the following. Wallace may enhance these measures but will not materially reduce the overall level of protection during the beta.

Governance. Measures: Written information security program with a named owner, reviewed at least annually and after any material change. Documented incident response plan. Documented due diligence on each subprocessor before it is engaged, and re-review at least annually.

Access control. Measures: Least-privilege, role-based access. Multi-factor authentication is required on the provider dashboards Wallace uses to administer production (Supabase, Vercel, Amazon Web Services, and Stripe). The application’s own administrator console is limited to an allowlist of named Wallace administrators and does not yet require multi-factor authentication; among other things it can issue a single-use link that sets the password of a customer account, used for account support. Unique named accounts, no shared credentials. Production access limited to named personnel with a documented business need, reviewed at least annually, and revoked within twenty-four hours of role change or departure.

Tenant isolation. Measures: Every record carries the identifier of the account it belongs to. Row-level security is on for every table, and server code that bypasses it filters every query by that identifier. No cross-customer retrieval at the application or retrieval layer.

Encryption. Measures: TLS 1.2 or higher for all data in transit. AES-256 or equivalent for data at rest, including databases, object storage, and backups. Key management by the platform provider with access restricted to production roles.

Application security. Measures: Secure development lifecycle with peer code review. The web application’s build pipeline runs automated tests and a dependency audit; the backend’s runs automated tests only; deploys do not wait for these checks. Separation of development, staging, and production environments, with no production data in non-production environments. Wallace intends to commission a third-party penetration test and will provide the summary once it is available.

Logging and monitoring. Measures: Application and platform logs are retained by the hosting and database providers under their standard retention. Application logs record identifiers, codes, and counts, never content. The backend’s logs (Amazon Web Services CloudWatch) currently have no expiry. AI usage is recorded in Wallace’s own usage table and kept about thirteen months (396 days). There is no dedicated audit-log table: administrative actions taken in the product are not separately recorded, and no log is tamper-evident. Source changes record who made each one and when. Wallace is working toward centralized log aggregation with alerting on anomalous access, and will update this exhibit when it is in place.

Data handling. Measures: On-device pseudonymization of meeting transcripts as described in Section 2(a), with a preview for notes added one at a time and none for notes read in bulk from a connected folder. Client files read in the browser, with only the column names and the summary described in Section 2(a-2) sent. Automated refusal of Social Security, payment card, and labeled account numbers in questions and Documents. Automated privacy step on Interview Content, questions, and Documents, which does not remove health information. No production data on personal or unmanaged devices. Secure disposal of media and cryptographic erasure of storage on decommission.

Resilience. Measures: Automated encrypted backups by the database provider, kept on its rolling cycle. No stated recovery time or recovery point objectives. Infrastructure hosted with providers maintaining recognized third-party security certifications.

Personnel. Measures: Written confidentiality agreements surviving termination, for every person with access to Customer Data. Background screening consistent with role sensitivity before production access is granted. Security and privacy training at onboarding. Documented offboarding checklist including immediate credential revocation.

Endpoints. Measures: Full-disk encryption, screen lock, and automatic patching on all devices with access to production systems or Customer Data.

Certification. Measures: Wallace is pursuing SOC 2 Type II. Wallace will notify Customers when the report is available and will provide it under confidentiality on request. Wallace will not represent that it holds a certification it has not obtained.

Exhibit B: Subprocessors

Current as of November 5, 2026. Wallace will give at least thirty (30) days’ notice before adding a subprocessor that processes Customer Data.

Anthropic PBC. Function: AI model inference (nearly all model work, including the privacy step); Location: United States; Data processed: Interview Content; Document text, including the raw text the privacy step cleans and scanned pages to be read; Meeting Content; client files’ column names and summaries; Playbook claims; questions; answers to Checks; and connected-folder and file paths. Called from the backend and from the web application. Accessed under commercial terms prohibiting training on customer content.

OpenAI, L.L.C. Function: Search index (embeddings only); Location: United States; Data processed: Passages of stored Document text, interview and meeting answers, facts (including facts drawn from client files), Playbook claims, and question topics, as text to index for search. Accessed under API terms under which data sent through the API is not used to train or improve OpenAI models; abuse-monitoring logs retained for up to thirty (30) days, then deleted.

Amazon Web Services, Inc. Function: Backend hosting; Location: United States; Data processed: The backend service: it runs the interview and the privacy step, reads Documents and client-file summaries, and answers questions. Customer Data passes through it, and the backend’s logs are kept there.

Supabase. Function: Database and authentication; Location: United States; Data processed: Account data, Interview Content, Maps, the cleaned text of Documents, what Wallace keeps from client files, Playbooks, chats, settings, and usage counts. Row-level security scopes every record to one account. Passwords held only as salted hashes. Hosted in Ohio; from September 2026 until November 2026, in Canada (Montreal).

Vercel. Function: Application hosting and delivery; Location: United States; Data processed: Application traffic, request metadata, Service Telemetry. Also runs meeting extraction, Check grading, scanned-page reading, and folder sorting, which call Anthropic. Customer content passes through it and is not persisted there.

Resend. Function: Transactional email; Location: United States; Data processed: Recipient email address and message content for account, security, and service notices, invitation links, and routed-question notifications.

PostHog, Inc. Function: Product analytics; Location: United States; Data processed: Service Telemetry by account identifier. Text capture and session recording turned off. No content.

Functional Software, Inc. (Sentry). Function: Error monitoring; Location: United States (web application); Data processed: Error types and code locations, with identifiers and codes. Error messages and anything a person wrote are removed before sending.

Cloudflare, Inc. Function: Bot check; Location: Global (Cloudflare network); Data processed: A token and the user’s IP address at sign-up, when Turnstile’s keys are set.

Acceptance

This Addendum is effective on the date Customer accepts the Terms of Service. It may be accepted electronically; sign-up records the time Customer accepted, not which version. A copy for signature is available on request from support@wallacefinance.io.

Wallace Finance Co., based in Chicago, IL. Mailing address for legal notices (registered agent): 8 The Grn, Ste B, Dover, DE 19901. Security matters, privacy questions, and legal notices: support@wallacefinance.io.