Effective 2 September 2026 · Version 1.1 · Print / Save PDF

Legal Disclaimers & Important Notices

GARUNA GROUP — Enhanced Due Diligence ("EDD") — Early Access (invite-only pilot)

These Disclaimers & Important Notices form part of, and are incorporated by reference into, the Terms of Service / Master Services Agreement ("Terms") that governs your use of the Service. Capitalised terms not defined here have the meanings given in the Terms. This document is also surfaced in-product. In the event of conflict, the Terms (and, on matters of personal-data processing, the DPA) govern.

1. No Warranty — "As Is"

The Service and all Output are provided "as is" and "as available", without warranty of any kind, whether express, implied, statutory, or otherwise. To the fullest extent permitted by law, Garuna disclaims all warranties and conditions, including any implied warranties or conditions of accuracy, completeness, currency, reliability, merchantability, fitness for a particular purpose, title, and non-infringement, and any warranty arising from course of dealing or usage of trade.

Garuna does not warrant that the Service will be uninterrupted, error-free, or secure, that any particular source will be available or reachable, or that any Output will be sufficient for the Client's purposes. The Output is intelligence to inform human judgement — not a finding of fact, a verdict, or a recommendation. Any reliance on the Service or the Output is at the Client's and Authorised User's own risk.

2. Accuracy & Identity Resolution

Output is compiled from open-source and public-record material and may be incomplete, outdated, inaccurate, or mis-attributed. Sources may be wrong, stale, or absent; a Subject's footprint may be partial or deliberately obscured; and an absence of findings is not evidence of absence.

Same-name and identity-resolution risk is inherent. Many distinct people and entities share names and identifiers. The Service grades and clusters findings to the identity selected by the Authorised User and excludes same-name strangers, and each Report discloses an identity-confidence percentage and the rival identities it excluded — but this process is probabilistic and can err in either direction (mis-attribution or wrongful exclusion). You must review the identity-resolution disclosure and confirm the Subject's identity before relying on any finding. Do not attribute a finding to a person or entity on name alone.

Identifier-collision risk in breach-presence and account-existence findings. Findings that a given email address, phone number, username, or domain appears in a known data breach or leak source, or that an account exists on a particular website or platform, are indicative signals tied to that identifier — not to a confirmed individual. An identifier may be held, re-used, recycled, shared, or spoofed by a person other than the Subject, so such a signal may reflect a different holder of that identifier, a coincidental match, or a stale registration. These findings are surfaced in-product with a "VERIFY" indication and must be verified before any reliance. Do not treat the presence (or absence) of an identifier in a breach source or on a platform as confirmation about the Subject.

3. AI-Generated Content

The executive summary, verdicts, and synthesis in a Report are generated by artificial-intelligence models (a cloud Tier-1 model in Deep Mode; an on-device model otherwise). The synthesis operates under a citation gate that drops any sentence not supported by a cited, numbered source (a zero-fabrication design), and Deep Mode additionally runs independent claim verification (CONFIRMED / PARTIAL / UNVERIFIED / CONTRADICTED).

Notwithstanding these controls, AI-generated Output may still contain errors, omissions, mis-readings, or misinterpretations, including where a cited source is itself mistaken or is summarised incorrectly. Treat the synthesis as a research aid only and verify every material statement against the cited primary sources before acting on it. A citation confirms a source was relied on; it does not confirm the source is true or correctly interpreted.

4. Not a Consumer Report

Garuna is not a consumer reporting agency, and the Service is not a "consumer report."

The Service is not designed, authorised, or permitted to be used, in whole or in part, as a factor in establishing any individual's eligibility for credit, employment, insurance, housing or tenancy, or any other purpose regulated by the U.S. Fair Credit Reporting Act (FCRA) or by any Canadian provincial consumer-reporting or credit-reporting legislation (including the Ontario Consumer Reporting Act). The Service is likewise not a "consumer report" under such Canadian legislation.

Pre-employment screening is permitted only where it is independently lawful and is not conducted using this tool as a consumer report. No solely-automated decision producing legal or similarly significant effects on a Subject may be made on the Output without meaningful human review and independent verification.

5. Not Legal, Compliance, Financial, or Professional Advice

The Service and the Output are provided for informational and investigative purposes only and do not constitute legal, compliance, regulatory, financial, accounting, investment, tax, or other professional advice. Nothing in a Report should be construed as a legal conclusion, a regulatory determination, or a recommendation to take or refrain from any action. You are responsible for obtaining your own professional advice and for any decision you make.

6. Sanctions & Watchlist Screening

Sanctions and watchlist screening in the Service (performed against consolidated government sanctions and watchlist sources and any other configured source) is name-based and indicative only. It is intended to surface potential matches for human review and is subject to both false positives and false negatives — a match may be a different person of the same name, and a true match may be missed where a list, spelling, alias, or transliteration differs.

A flag is not a determination that a Subject is sanctioned or listed, and the absence of a flag is not confirmation that a Subject is clear. This screening is not a substitute for a regulated sanctions, AML, or KYC compliance programme, for official list verification at source, or for professional compliance advice. Any sanctions-related decision must be independently verified against the authoritative list and your own compliance controls.

7. Third-Party Sources, Public Records & Independent Platforms

Output is derived from third-party sources that Garuna does not own or control, including open web sources, public registries, court and corporate records, news and adverse-media indexes, breach/leak presence sources, account-discovery results, and domain/trademark records. Garuna does not endorse, verify, or warrant the accuracy, completeness, legality, or availability of any such source, and is not responsible for third-party content. Community, forum, and social-engagement signals are unverified and may be opinion, rumour, error, or impersonation; treat them with particular caution.

Certain public-record and reference sources are queried directly with Subject identifiers and act as independent controllers of their own data; they are not operated by Garuna, and the categories of sources, the data sent to each, and the cross-border transfers involved are set out in the Privacy Policy, the DPA, and the Sub-processor & Third-Party Data Source List. These categories include, among others, Canadian and U.S. court, tribunal, and case-law repositories; government securities and corporate-registry filings; patent and trademark registries; sanctions and watchlist sources; news and adverse-media archives; and breach/leak-presence and account-existence sources. Where a source's terms of use require attribution, the Service attributes the relevant finding to its originating repository in the Report. Use of such sources is subject to their respective terms of use, and the Client and Authorised User remain responsible for lawful use of any data so obtained.

8. Authenticated Investigation Sessions & Platform Terms

An Investigation Session is an authenticated browser session that an Authorised User establishes by signing in themselves to their own or a duly authorised investigation ("burner") account, which the Service then reuses to read certain public information about a Subject. The supported platforms are X, Instagram, Reddit, LinkedIn, and Facebook. A connected session may be reused both to read a Subject's public engagement graph (for X and Instagram) and to retrieve a Subject's publicly displayed profile photo through an authenticated page fetch on any connected platform (including LinkedIn). The Service may also perform an authenticated lookup of a Subject's email address against a major email/account provider where the Authorised User has separately established a session with that provider for that purpose.

The Service never cracks, guesses, or bypasses authentication; it reuses only a session the Authorised User established themselves. The Authorised User is solely responsible for each Investigation Session, including for ensuring that any account used is their own or duly authorised, and for compliance with the relevant platform's Terms of Service and applicable law.

Warning — platform restrictions. Several supported platforms restrict or prohibit automated access, data collection, or the use of investigation/"burner" accounts. LinkedIn and the Meta properties (Facebook and Instagram), in particular, expressly prohibit automated collection and the use of non-genuine accounts; a major email/account provider's terms likewise govern access to its account services. Using such a platform through an Investigation Session — or using an account that is not your own or not duly authorised — may breach that platform's terms and is your responsibility and not Garuna's. The in-product gate requires acknowledgement of this responsibility for the specific platform you connect.

9. Authorised & Lawful Use Only

The Service may be used only for lawful, authorised due-diligence purposes and only in accordance with the Terms and the Acceptable Use Policy (AUP), which are incorporated by reference. Permitted and prohibited uses — including the prohibition on stalking, harassment, doxxing, intimidation, unlawful surveillance, and any human-rights-violating, discriminatory, or otherwise unlawful purpose — are set out in the AUP. The Client and each Authorised User are responsible for holding a lawful basis or authority to process each Subject's information and for using the Output lawfully. Refer to the Terms and AUP for the full and governing terms of use. Suspected misuse of the Service may be reported to [email protected].

10. Subjects Are Not Parties — No Limitation of Third-Party Claims

A Subject is a third party who is not a party to the Terms and who is generally unaware of a Sweep. These Disclaimers, the Terms, and any warranty disclaimer, exclusion, or limitation or cap on liability set out in them bind only the Client and its Authorised Users. Nothing in these Disclaimers or the Terms operates to limit, exclude, cap, or otherwise affect any direct statutory or common-law claim a Subject or any other third party may have against Garuna or the Client — including any claim in defamation, in tort, for breach of privacy, under PIPEDA, under Quebec Law 25, or under the GDPR / UK GDPR (including Article 82) — and no such claim is waived or released by these Disclaimers or the Terms.

As between Garuna and the Client, the Client's selection of Subjects, its Subject Inputs, and its use of the Output are the Client's responsibility, and the Client's indemnity obligations (including in respect of claims by Subjects arising from those matters, such as defamation, privacy, PIPEDA, Law 25, and GDPR Article 82 claims) are set out in the Terms.

11. No Attorney–Client or Professional Relationship

Access to or use of the Service does not create any attorney–client, fiduciary, advisory, or other professional relationship between you (or any Subject) and Garuna or any of its personnel. Garuna does not act as your lawyer, compliance officer, investigator-of-record, or professional adviser. Communications through or about the Service are not privileged or confidential legal communications.

These Disclaimers are subject to and limited by the warranty, liability, and indemnity provisions of the Terms, save that nothing in these Disclaimers or the Terms limits a Subject's or other third party's direct statutory or tort claims (see §10). For the limitation of liability and the allocation of risk between the Client and Garuna, see the Terms of Service / Master Services Agreement.

Version 1.0 — Effective 2026-06-27 — Garuna Inc. (operating as "Garuna Group"), 10 Thornmount Drive, Toronto, Ontario M1B 3J4, Canada — [email protected]