Terms of Service

You must be at least 18 years old and legally capable of entering into a binding agreement to use the Services.

If you use Lucy on behalf of an organization, you represent that:

• You are authorized to act on behalf of that organization;
• The organization agrees to these Terms; and
• Your use of the Services complies with the organization's policies and applicable law.

The Services are intended for business, professional, institutional, and enterprise use, not for personal, family, or household purposes.

Certain Services require an account. You must provide accurate and current registration information and keep it up to date.

You are responsible for:

• Protecting your login credentials;
• Maintaining the confidentiality of your account;
• Ensuring that users you authorize comply with these Terms; and
• Promptly notifying Lucy if you suspect unauthorized access to or misuse of your account.

You may not share individual account credentials unless Lucy expressly permits credential sharing for a particular Service or account type.

Lucy may require multi-factor authentication or other security measures for certain accounts or features.

Customers may purchase Services under an order form or another written agreement with Lucy, such as a master services agreement, data license agreement, subscription agreement, Data Processing Addendum, security addendum, or statement of work. In these Terms, "Order Form" means any such agreement that sets out the Services purchased and their commercial terms.

If these Terms conflict with a separately executed agreement:

• The Order Form or master agreement controls with respect to commercial terms;
• A Data Processing Addendum controls with respect to processing of personal information covered by that addendum;
• A security addendum controls with respect to the security obligations it expressly addresses; and
• These Terms govern all other matters.

Lucy provides financial information, structured datasets, filing intelligence, search, retrieval, analytics, artificial intelligence, compliance-support, and related tools. The Services may include:

• Structured information derived from SEC filings and other public sources;
• Company intelligence;
• Fund and ETF intelligence;
• Filing search and retrieval;
• APIs and data feeds;
• Compliance-support tools;
• AI-generated analysis and responses;
• Document comparison and change detection;
• Monitoring and alerts; and
• Other products Lucy makes available from time to time.

Features, datasets, coverage, supported forms, update frequency, and availability vary by subscription plan.

Lucy may modify, improve, discontinue, or replace features of the Services. Lucy will not materially reduce the core functionality of a paid subscription during its current term, except as required by law or to address a security issue.

"Customer Content" means information submitted to Lucy by or on behalf of Customer through the Services, and the outputs Lucy generates for Customer from it, including:

• Uploaded documents and files;
• Prompts and queries;
• URLs submitted for analysis or monitoring;
• Marketing and compliance materials;
• Notes, comments, annotations, and reviewer decisions;
• Data submitted through an API;
• Customer-specific rules or instructions;
• Outputs generated for Customer; and
• Other non-public information Customer provides to Lucy.

Lucy Data (defined in Section 9) that appears in outputs remains Lucy Data and is subject to Section 10.

Ownership

As between Lucy and Customer, Customer retains all right, title, and interest in Customer Content.

Customer grants Lucy a limited, non-exclusive right to host, copy, process, transmit, display, and otherwise use Customer Content only as necessary to:

• Provide the Services;
• Perform requested analysis and generate outputs;
• Maintain and secure the Services;
• Provide support;
• Follow documented Customer instructions; and
• Comply with applicable law and contractual obligations.

This license ends when the relevant Customer Content is deleted, except to the extent retention is required by law, for backup processes described in Section 25, or for the resolution of a pending dispute.

Lucy uses artificial intelligence and machine-learning systems, including systems provided by third-party service providers, to provide the Services.

No model training. Lucy does not use Customer Content to train, fine-tune, or evaluate any AI model, whether shared, general-purpose, or customer-specific, unless Customer expressly agrees in writing or through an explicit opt-in.

Third-party AI providers. Lucy's agreements with third-party AI model providers prohibit them from using Customer Content to train their models.

Service improvement. Lucy may use de-identified information, aggregated usage information, operational telemetry, and performance metrics to operate, secure, analyze, and improve the Services. This does not include Customer Content, except for feedback on outputs as described in the Lucy Privacy Policy.

No cross-customer disclosure. Lucy will not disclose one Customer's Customer Content to another customer, except at the direction of the Customer, as expressly permitted by contract, or as required by law.

Lucy serves customers in regulated industries, including financial services.

Unless expressly authorized in an Order Form, Data Processing Addendum, or other written agreement, you must not submit:

• Social Security numbers;
• Government identification numbers;
• Payment-card numbers;
• Consumer bank-account credentials;
• Protected health information;
• Biometric identifiers;
• Nonpublic personal information about consumers subject to the Gramm-Leach-Bliley Act;
• Export-controlled technical data; or
• Other information subject to specialized legal restrictions that Lucy has not agreed in writing to process

(together, "Restricted Data"). Lucy has no obligation or liability with respect to Restricted Data submitted in violation of this Section.

Customers subject to the Gramm-Leach-Bliley Act, SEC Regulation S-P, state financial privacy laws, or other financial-services regulations are responsible for determining whether Customer Content may lawfully be provided to Lucy.

Where Lucy expressly agrees to process information subject to particular regulatory requirements, Lucy will process it in accordance with the applicable written agreement.

Nothing in these Terms represents that any configuration of the Services by itself satisfies the legal, regulatory, supervisory, recordkeeping, or security obligations that apply to Customer.

Customer is responsible for:

• Having all rights, permissions, notices, and legal bases necessary to provide Customer Content to Lucy;
• Determining whether use of the Services is appropriate for Customer's business;
• Configuring user access and permissions appropriately;
• Reviewing material outputs before relying on them;
• Maintaining independent records where required;
• Complying with the laws and regulations that apply to Customer; and
• Ensuring that Customer's use of the Services does not infringe third-party rights.

Customer may not direct Lucy to process information in a manner that violates applicable law.

"Lucy Data" means datasets, taxonomies, classifications, normalized fields, schemas, mappings, analytics, metadata, derived information, data structures, and other information made available by Lucy that is not Customer Content.

Lucy Data may include information derived from SEC filings, government records, regulatory disclosures, publicly available information, licensed third-party sources, and Lucy's proprietary processing, classification, normalization, and analytical systems.

Public facts and government records remain subject to applicable law and to any rights of their original sources. Lucy retains all rights in its proprietary selection and arrangement of data, schemas, taxonomies, data models, normalization methods, enrichment, classifications, software, APIs, metadata, derived datasets, and other intellectual property.

Subject to payment of applicable fees and compliance with these Terms, Lucy grants Customer a limited, non-exclusive, non-transferable, non-sublicensable license to access and use Lucy Data for Customer's internal business purposes during the applicable subscription term.

Unless an Order Form expressly permits it, Customer may not:

• Resell Lucy Data;
• Redistribute Lucy Data, in whole or in substantial part, including as a standalone product;
• Make Lucy Data available to third parties;
• Create a competing commercial data product substantially derived from Lucy Data;
• Systematically extract or scrape Lucy Data outside authorized APIs or export functions;
• Remove Lucy attribution, provenance, or proprietary notices;
• Use Lucy Data beyond applicable usage or volume limits; or
• Permit third parties to access Lucy Data using Customer's credentials.

Rights for redistribution, external publication, AI model training, data feeds, white-label use, benchmarking products, or incorporation into third-party commercial products require a separate written agreement.

If Customer receives access to a Lucy API, Customer must:

• Protect API credentials;
• Use the API within applicable rate and usage limits;
• Follow Lucy's API documentation;
• Implement reasonable safeguards against unauthorized access; and
• Notify Lucy promptly of compromised credentials.

Lucy may limit, suspend, or rotate API credentials when reasonably necessary to protect security, system integrity, or other customers.

API access does not grant rights to redistribute Lucy Data except where expressly permitted in an Order Form.

You may not use the Services to:

• Violate any applicable law or regulation;
• Infringe intellectual-property, privacy, confidentiality, or other rights;
• Gain unauthorized access to another account, system, or dataset;
• Circumvent authentication, entitlement, usage, or security controls;
• Probe, scan, or test the vulnerability of the Services without Lucy's written authorization;
• Interfere with the availability, integrity, or performance of the Services;
• Introduce malware, malicious code, or harmful content;
• Reverse engineer the Services, except to the extent this restriction is prohibited by law;
• Scrape or extract data from the Services by automated means, including AI agents, bots, or crawlers, except through authorized APIs or export functions;
• Use the Services, outputs, or Lucy Data to train, fine-tune, or benchmark any AI model without Lucy's written permission;
• Use the Services, outputs, or Lucy Data as a factor in determining any individual's eligibility for credit, insurance, employment, housing, or any other purpose governed by the Fair Credit Reporting Act or similar laws;
• Impersonate another person or organization;
• Generate fraudulent, deceptive, or unlawful content;
• Build a product or service that competes with Lucy using the Services or Lucy Data; or
• Use the Services in a way reasonably likely to create material security, legal, or operational risk for Lucy or other customers.

Lucy may investigate suspected violations and may suspend access in accordance with Section 24.

Lucy is a technology and financial-data provider. Unless expressly stated in a separate written agreement, Lucy is not acting as a broker-dealer, investment adviser, fiduciary, law firm, legal counsel, accounting firm, auditor, tax adviser, or compliance officer.

The Services do not constitute investment, legal, accounting, tax, regulatory, compliance, or other professional advice. Information and outputs are intended to support human research and decision-making, not to replace professional judgment.

Compliance-related features may identify potential inconsistencies, risks, missing information, or matters requiring review. They do not guarantee that any document, communication, filing, investment product, or business practice complies with SEC, FINRA, CFTC, state, federal, or other requirements.

Customer remains responsible for all final business, investment, legal, accounting, filing, compliance, and publication decisions.

Certain Services generate text, classifications, summaries, recommendations, extracted information, comparisons, or other outputs using artificial intelligence. AI-generated outputs may:

• Contain errors;
• Be incomplete;
• Misinterpret source information;
• Produce false positives or false negatives;
• Differ across model versions or repeated requests; or
• Require professional review.

Customer is responsible for evaluating outputs before using or relying on them.

Outputs are not necessarily unique. Other users may receive similar outputs, and Customer's ownership of its outputs does not extend to similar outputs generated for others.

Where available, Lucy provides source citations or provenance to support verification. Customer should review the underlying source material for matters of material importance.

Lucy processes large volumes of regulatory filings and other source material. Although Lucy works to provide accurate, timely, and source-linked information:

• Source filings may contain errors;
• Regulators or issuers may later amend information;
• Data processing may be delayed;
• Information may be incomplete;
• Entity, series, class, ticker, or filing relationships may require interpretation; and
• Third-party or public systems may become unavailable.

Lucy does not warrant that the Services contain every filing, event, amendment, or data point, or that information will be available immediately after publication. Where accuracy is material, Customer should confirm information against the applicable primary source.

If you provide suggestions, recommendations, ideas, enhancement requests, or other feedback about the Services ("Feedback"), you grant Lucy a worldwide, perpetual, irrevocable, royalty-free right to use that Feedback to develop and improve Lucy's products and services.

This does not permit Lucy to disclose Customer Confidential Information or Customer Content merely because it appears alongside Feedback.

Each party may receive non-public information from the other that is identified as confidential or that a reasonable person would understand to be confidential ("Confidential Information").

Customer Content is Customer's Confidential Information ("Customer Confidential Information"). Lucy's Confidential Information includes non-public information about Lucy's technology, product roadmap, security, pricing, algorithms, systems, and business operations.

The receiving party will:

• Use Confidential Information only for purposes related to the business relationship;
• Protect it using at least reasonable care;
• Disclose it only to personnel, affiliates, contractors, or service providers who need access and are bound by confidentiality obligations at least as protective as these; and
• Not disclose it to any other third party except with the disclosing party's permission or as required by law.

Confidential Information does not include information that the receiving party can demonstrate:

• Is or becomes public through no breach of these Terms;
• Was lawfully known to it without confidentiality restrictions;
• Was independently developed without use of the Confidential Information; or
• Was lawfully received from another source without confidentiality restrictions.

If disclosure is legally required, the receiving party may disclose Confidential Information to the extent required and, where legally permitted, will give the disclosing party reasonable advance notice.

Lucy maintains administrative, technical, and organizational safeguards designed to protect Customer Content and the Services from unauthorized access, disclosure, alteration, or destruction. These safeguards include:

• Encryption in transit and at rest;
• Authentication and access controls, including role-based access;
• Logging and monitoring;
• Secure development practices;
• Vulnerability management;
• Incident-response procedures; and
• Backup and recovery measures.

No system is completely secure.

If Lucy confirms a security incident involving Customer Content, Lucy will notify affected Customers without undue delay and as required by applicable law and any applicable security or data-processing agreement.

Additional security commitments may be set out in a security addendum, Data Processing Addendum, or Order Form.

Lucy's collection and use of personal information is described in the Lucy Privacy Policy at lucydata.ai/privacy-policy.

Where Lucy processes personal information on Customer's behalf, Lucy acts as Customer's service provider or processor, and the parties will enter into a Data Processing Addendum where legally required or upon Customer's request.

Lucy will process personal information in accordance with applicable U.S. privacy laws and the parties' written agreements.

Lucy uses third-party providers to deliver the Services, including providers of cloud infrastructure, hosting, storage, artificial intelligence, authentication, monitoring, security, analytics, email and communications, and customer support.

Lucy remains responsible for its subprocessors' performance of Lucy's obligations under these Terms. A list of Lucy's material subprocessors is available on request at privacy@lucydata.ai, and enterprise customers may have additional subprocessor rights under their agreements.

The Services may contain integrations with, links to, or functionality provided by third parties. Lucy is not responsible for third-party products or services that Customer chooses to use, which may be subject to separate terms and privacy policies. Lucy does not control the availability, security, or operation of third-party services.

Paid subscriptions are subject to the fees, billing terms, usage limits, subscription period, and payment terms specified at purchase or in the applicable Order Form. Unless otherwise stated:

• Fees are quoted and payable in U.S. dollars;
• Invoiced fees are due within 30 days of the invoice date;
• Fees are exclusive of taxes, and Customer is responsible for applicable sales, use, withholding, and similar taxes, other than taxes based on Lucy's net income;
• Subscription fees are non-refundable except as expressly stated in an applicable agreement;
• Late payments accrue interest at 1.5% per month or the maximum rate permitted by law, whichever is lower; and
• Customer must notify Lucy of any disputed charge within 30 days of the invoice or charge date, or the charge will be deemed accepted.

Lucy may suspend access for non-payment of undisputed amounts in accordance with Section 24.

The term of a paid subscription is specified in the applicable Order Form or purchasing interface.

Self-serve subscriptions purchased online renew automatically for successive periods equal to the initial term unless cancelled before the end of the current term. You can cancel at any time by contacting help@lucydata.ai or, where available, through your account settings. Cancellation takes effect at the end of the current term.

Order Form subscriptions renew only as stated in the applicable Order Form.

Lucy will give at least 30 days' notice of any price increase before it applies at renewal.

Lucy may suspend access to some or all of the Services where reasonably necessary because of:

• A material breach of these Terms;
• Non-payment of undisputed amounts;
• A security threat;
• Suspected fraud or unlawful activity;
• Use that materially threatens the Services or other customers;
• A legal or regulatory requirement; or
• Usage materially exceeding agreed limits.

Where practicable, Lucy will give notice and a reasonable opportunity to cure before suspension, except where immediate action is reasonably necessary. Lucy will restore access promptly once the cause of the suspension is resolved.

Either party may terminate Services as permitted under the applicable Order Form or subscription terms.

Either party may terminate these Terms for the other party's material breach that is not cured within 30 days after written notice. Lucy may terminate immediately where required by law or reasonably necessary to prevent material harm.

Upon termination:

• Customer's right to use the terminated Services and Lucy Data ends;
• Outstanding payment obligations remain due;
• Customer may export its Customer Content for 30 days after termination. Lucy will delete it within 30 days after that export period ends, except where retention is required by law. Copies in encrypted backups are overwritten within 35 days after deletion; and
• Sections 5 (Ownership), 6, 9, 10 (the restrictions on use of Lucy Data), 12, 13 through 17, 22 (amounts owed), 25, and 27 through 38 survive, along with any other provisions that by their nature should survive.

Enterprise customers may have additional export or transition rights under their agreements.

Lucy may make beta, pilot, preview, experimental, or early-access features available. These features may change without notice, contain more errors, be discontinued, have limited support, or be subject to separate usage restrictions.

Unless otherwise agreed in writing, beta and preview features are provided "AS IS," without any warranty, service-level commitment, or indemnity, and Lucy's total liability for them will not exceed US$100. They should not be used as the sole basis for material legal, compliance, accounting, financial, or investment decisions.

Except for Customer Content and third-party materials, Lucy and its licensors retain all right, title, and interest in the Services, software, interfaces, designs, documentation, APIs, data models, schemas, taxonomies, workflows, algorithms, data transformations, Lucy Data, and related intellectual property.

No rights are granted except those expressly provided in these Terms or another written agreement.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE SERVICES AND LUCY DATA ARE PROVIDED "AS IS" AND "AS AVAILABLE."

EXCEPT AS EXPRESSLY PROVIDED IN A WRITTEN AGREEMENT, LUCY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, AND ACCURACY OR COMPLETENESS.

LUCY DOES NOT WARRANT THAT:

• THE SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE;
• EVERY FILING OR DATA POINT WILL BE AVAILABLE;
• EVERY ERROR OR COMPLIANCE ISSUE WILL BE DETECTED;
• OUTPUTS WILL BE COMPLETE OR CORRECT;
• THE SERVICES WILL SATISFY CUSTOMER'S REGULATORY REQUIREMENTS; OR
• THE SERVICES WILL PRODUCE ANY PARTICULAR INVESTMENT, BUSINESS, LEGAL, OR COMPLIANCE RESULT.

Nothing in this Section limits an express warranty in an applicable enterprise agreement.

Exclusion of damages. TO THE MAXIMUM EXTENT PERMITTED BY LAW, EXCEPT FOR EXCLUDED CLAIMS, NEITHER PARTY WILL BE LIABLE TO THE OTHER FOR INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR FOR LOSS OF PROFITS, REVENUE, GOODWILL, OR BUSINESS OPPORTUNITY, ARISING OUT OF OR RELATING TO THE SERVICES OR THESE TERMS, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Liability cap. TO THE MAXIMUM EXTENT PERMITTED BY LAW, EXCEPT FOR EXCLUDED CLAIMS, EACH PARTY'S AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THE SERVICES OR THESE TERMS WILL NOT EXCEED THE AMOUNTS PAID OR PAYABLE BY CUSTOMER TO LUCY FOR THE AFFECTED SERVICES DURING THE 12 MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM. FOR USERS OF FREE SERVICES, LUCY'S AGGREGATE LIABILITY WILL NOT EXCEED US$100.

Excluded claims. "Excluded Claims" means:

• Customer's breach of Section 10 (License to Lucy Data) or Section 12 (Acceptable Use);
• A party's breach of Section 17 (Confidentiality), other than a breach relating to Customer Content, which remains subject to the cap;
• Customer's obligations under Section 30 (Customer Indemnification);
• Customer's obligation to pay fees; and
• A party's gross negligence, fraud, or willful misconduct.

A separately signed enterprise agreement may provide different limitations or exclusions.

To the extent permitted by law, Customer will defend and indemnify Lucy and its affiliates, officers, directors, employees, and agents against third-party claims, and resulting losses, damages, and reasonable attorneys' fees, arising from:

• Customer Content that infringes or violates third-party rights;
• Restricted Data submitted in violation of Section 7;
• Customer's unlawful use of the Services;
• Customer's material breach of these Terms; or
• Customer's use or redistribution of Lucy Data outside the rights granted by Lucy.

This obligation does not apply to the extent a claim results from Lucy's own breach of these Terms or applicable law.

Enterprise customers may have different indemnification provisions under their agreements.

You may not use, export, re-export, transfer, or provide access to the Services in violation of applicable U.S. export-control, trade-control, or economic-sanctions laws. You represent that you are not prohibited from receiving the Services under those laws.

Lucy may update these Terms from time to time and will update the "Last updated" date when it does.

For material changes, Lucy will notify account administrators by email or through the Services at least 30 days before the changes take effect, unless the change is required by law or necessary to address a security issue.

For paid subscriptions, a material change that reduces Customer's contractual rights will take effect at the start of the next renewal term, unless the change is required by law, necessary to address a security issue, agreed to by Customer, or the applicable Order Form provides otherwise.

Continued use of the Services after updated Terms take effect constitutes acceptance.

These Terms are governed by the laws of the State of Delaware, without regard to its conflict-of-laws principles, unless an applicable Order Form specifies otherwise.

Any dispute arising out of or relating to these Terms or the Services will be brought exclusively in the state or federal courts located in the State of Delaware, and each party consents to personal jurisdiction and venue in those courts. Either party may seek injunctive relief in any court of competent jurisdiction to protect its intellectual property or Confidential Information.

EACH PARTY WAIVES ITS RIGHT TO A JURY TRIAL IN ANY DISPUTE ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICES. Claims may be brought only on an individual basis, and not as a plaintiff or class member in any purported class, collective, or representative proceeding.

Neither party is responsible for delay or failure to perform caused by events beyond its reasonable control, including natural disasters, internet or telecommunications failures, governmental actions, labor disputes, civil unrest, acts of war or terrorism, widespread cloud-provider outages, or similar events. This Section does not excuse payment obligations.

Neither party may assign these Terms without the other party's prior written consent, except that either party may assign these Terms without consent to an affiliate or in connection with a merger, acquisition, corporate reorganization, or sale of substantially all of its relevant assets. However, Customer may not assign these Terms to a competitor of Lucy without Lucy's consent. Any attempted assignment in violation of this Section is void.

Lucy may identify Customer as a customer, including by using Customer's name and logo on its website and in marketing materials, in accordance with any trademark guidelines Customer provides. Customer may opt out at any time by emailing help@lucydata.ai.

Notices to Lucy. Legal notices to Lucy must be sent by email to help@lucydata.ai, with a copy by mail or courier to:

Notices to Customer. Lucy will send notices to the email address associated with Customer's account administrator, or through the Services.

Effectiveness. Email notices are effective when sent, unless the sender receives a delivery failure notification. Notices by mail or courier are effective upon delivery.

You consent to receive communications from Lucy electronically, and you agree that electronic communications satisfy any legal requirement that communications be in writing.

If any provision of these Terms is found unenforceable, it will be enforced to the maximum extent permissible and the remaining provisions will remain in effect.

Failure to enforce a provision is not a waiver of that provision.

Headings are for convenience only. The word "including" means "including without limitation."

The parties are independent contractors. These Terms do not create a partnership, joint venture, or agency relationship.

These Terms, together with any applicable Order Forms and other incorporated agreements, are the entire agreement concerning the Services covered by them and supersede all prior or contemporaneous understandings regarding those Services.

No third party is a beneficiary of these Terms unless expressly stated.

General and support: help@lucydata.ai

Legal notices: help@lucydata.ai (see Section 37)

Privacy: privacy@lucydata.ai

You can also reach us through the Contact Us page on lucydata.ai. Enterprise customers may also contact their designated Lucy account representative.