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

Early Access Terms

GARUNA GROUP — Enhanced Due Diligence ("EDD")

Controlling document for the Early Access period. These Early Access Terms govern the Client's use of the Service during Early Access. They supplement the Terms of Service / Master Services Agreement (the "Terms") and the Acceptable Use Policy, Privacy Policy, Data Processing Addendum ("DPA"), Disclaimers & Legal Notices, and Sub-processor List, each of which continues to apply in full. For the duration of the Early Access Period, and only as to the specific commercial matters expressly addressed below (fees, term, and the liability cap), these Early Access Terms prevail over any inconsistent provision of the Terms. On all other matters the Terms (and, on personal-data processing, the DPA) govern. Capitalised terms not defined here have the meanings given in the Terms. Every account — whether opened through the self-serve membership door, through an operator invitation, or as part of a One Horizon client membership — is governed by these Early Access Terms, and every membership covers individual, entity and cryptocurrency searches alike.

1. Early Access

1.1 Early-access service. The Service is offered to the Client during Early Access on a paid membership basis while it is under active development and is not a finished product. Features, sources, and coverage may change between releases.

1.2 Personal to the Client. Access is by membership and is personal to the Client. The licence granted under clause 3.2 of the Terms is limited to use by the Authorised Users the Client designates. The Client must not resell, sublicense, or otherwise extend access to any other person or organisation, and must not share account credentials or sign-in links.

1.3 Revocable. Garuna may grant, limit, suspend, or revoke a Client's or any Authorised User's access to the Service at any time, with or without cause, and (where practicable) with notice, including to manage capacity, protect the Service or third parties, or respond to a breach of these Early Access Terms, the Terms, or the Acceptable Use Policy.

2. Early Access Period, changes, and termination

2.1 Early Access Period. The "Early Access Period" begins when the Client (through an Authorised User) is first granted access to the Service and accepts these terms, and continues until the earliest of: (a) Garuna ending Early Access or the Client's participation in it; (b) the Client ceasing to participate; or (c) the Service becoming generally available and the parties entering into commercial terms for continued use.

2.2 No commitment to release. Garuna makes no commitment that the Service, any feature, or Early Access will be continued, completed, supported, or made generally available, or that any data, configuration, or result generated during Early Access will be preserved or carried over to any future version.

2.3 Changes to the Service. Garuna may add, modify, suspend, or discontinue any feature or the whole of the Service at any time during Early Access, without liability. Early-access features may be changed or withdrawn without notice.

2.4 Termination. Either party may terminate the Client's use of the Service at any time, for any reason, on written notice (which may be given by email or in-product). Termination of Early Access does not affect accrued rights, and clauses 4–9 and 11–12 of these Early Access Terms, together with the surviving provisions of the Terms (Terms clause 15.5), survive termination or expiry. On termination the Client's access ends and the Client must stop using the Service; any Report the Client has exported remains under the Client's control and responsibility (Terms clause 15.4).

3. Fees during Early Access

3.1 Membership-based access; one search is one search. Use of the Service is sold as a monthly membership with a monthly search allowance (Essential, Professional and Practice plans), with optional top-up searches, a one-time rush-priority fee, an optional continued-monitoring add-on, and optional paid record checks, all as set out in clause 10 of the Terms and at the prices displayed in the Service at the time of purchase (renewal, cancellation, allowance-reset, and refund terms per clause 10.1 of the Terms). Every search of any subject type — individual, entity or cryptocurrency — uses one search from the monthly allowance; a search run with deep verification uses two; a self-search uses two. Garuna may, at its discretion, grant complimentary searches to particular accounts; complimentary searches have no cash value. Other than the membership and purchases the Client chooses to make, no fee is payable for Early Access, and the giving of feedback is free of charge.

3.2 Future paid terms. Any continued or paid use of the Service after the Early Access Period will be governed by separate commercial terms (for example, an order form) agreed in writing by the parties. Garuna may introduce fees for general availability and is under no obligation to offer the Client any particular pricing.

4. Pre-release — provided "as is"; verify before relying

4.1 As is / as available. The Service and all Output are provided "as is" and "as available", without warranty of any kind, to the fullest extent permitted by law. The "as is" disclaimer in clause 12 of the Terms and the Disclaimers & Legal Notices apply with full force to the Service, and the Client acknowledges that a pre-release product is more likely than a finished one to contain bugs, errors, interruptions, incomplete features, and inaccuracies, and that source coverage and accuracy may be lower or change without notice.

4.2 Human verification is mandatory. The Output is intelligence to inform human judgement, not a finding of fact. Consistent with clauses 7.4 and 12 of the Terms and the Disclaimers, the Client and its Authorised Users must independently verify every material finding against its cited primary sources before relying on it, must review the in-product identity-resolution, accuracy, and sanctions disclosures, and must not make any decision producing legal or similarly significant effects about any Subject on the basis of the Output without meaningful human review. The same-name / identity-resolution risk, the AI-synthesis risk, the breach-presence and account-existence "VERIFY" signals, and the indicative-only nature of sanctions screening, each as described in the Disclaimers, apply during Early Access.

4.3 No reliance for regulated decisions. The Service must not be used as, or as a factor in, a "consumer report" or any FCRA-regulated or Canadian provincial consumer-reporting eligibility decision, or for any of the prohibited uses in the Acceptable Use Policy. The cautions in the Disclaimers (not a consumer report; not legal, compliance, financial, or professional advice) apply in full.

5. Feedback

5.1 Feedback expected. A purpose of Early Access is to obtain the Client's evaluation. The Client and its Authorised Users are encouraged to provide feedback — comments, suggestions, bug reports, evaluations, and ideas — about the Service, and Garuna may contact the Client's Authorised Users to request it.

5.2 Licence to use feedback. The Client grants Garuna a perpetual, irrevocable, worldwide, royalty-free, fully paid-up, transferable, and sublicensable licence to use, reproduce, modify, and otherwise exploit all such feedback for any purpose, including to develop, improve, and commercialise the Service, without obligation, compensation, or attribution, provided that Garuna will not publicly identify the Client as the source without the Client's consent (clause 7) and will not disclose the Client's Confidential Information except as permitted by clause 6. Feedback is provided voluntarily and the Client is not obliged to provide any.

6. Confidentiality (mutual)

6.1 Confidential Information. Clause 11 of the Terms (Confidentiality) applies during Early Access and is supplemented by this clause 6. The Client acknowledges and agrees that, in addition to anything that is Confidential Information under the Terms, the following are Garuna's Confidential Information: the Service and its non-public, pre-release, or unreleased features, interfaces, screens, models, methods, and documentation; the Service's performance, behaviour, accuracy, and any evaluation, benchmark, or test results; any pre-release pricing or roadmap; and any non-public information the Client learns about the Service through Early Access.

6.2 Obligations. Each party will protect the other's Confidential Information with at least reasonable care, will use it only to exercise its rights and perform its obligations under these Early Access Terms and the Terms, and will not disclose it except to personnel, advisers, and contractors who need to know it and are bound by confidentiality obligations no less protective than these.

6.3 No publication of evaluations. The Client will not publish, post, present, or otherwise disclose to any third party any description, screenshot, recording, evaluation, benchmark, or performance result of the Service without Garuna's prior written consent. This does not restrict the Client's internal evaluation and reporting, or any disclosure of the Client's own due-diligence Output to the extent the Client is permitted to use that Output under the Terms.

6.4 Exceptions and compelled disclosure. The exclusions and the compelled-disclosure provision in clause 11 of the Terms (information that is or becomes public other than through breach, was lawfully known without obligation, is independently developed, or is lawfully received without restriction; and disclosure required by law or legal process with notice where lawful) apply to this clause 6.

6.5 Survival. This clause 6 survives termination or expiry of the Early Access Period and continues for so long as the relevant information remains confidential.

7. Publicity

7.1 Neither party will use the other party's name, logo, or trade marks, or refer to the other party or to the Client's use of the Service, in any public statement, marketing, customer list, or press communication, without the other party's prior written consent. Garuna will not publicly identify the Client as a Client without consent, and the Client will not publicly identify itself as a user of, or comment publicly on, the Service without consent.

8. Data protection during Early Access

8.1 Privacy and DPA apply. The Privacy Policy and the DPA apply during Early Access without change. As under the Terms, the Client is the Controller of Subject Personal Data and Garuna is the Processor, and the Client remains responsible for holding a lawful basis and authority for each Subject and each Sweep and for the lawful use of the Output.

8.2 Conservative defaults. During Early Access, and consistent with the DPA: Deep Mode is off by default (its optional cloud-LLM transfer to a cloud AI synthesis & verification provider via a consumer-grade endpoint is disclosed in DPA §11.5 and is not enabled for a Client's regulated processing); the authenticated account lookup against a major email/account provider ships disabled; and processing of Personal Data of Subjects located in the EEA or United Kingdom is disabled by default and is enabled for a Client only after the SCC / UK IDTA schedules are completed and executed (DPA §11.2). Completed Reports are retained for a limited period (currently thirty days) so the Client can retrieve them and are then deleted automatically; the retention of Subject data is described in the Privacy Policy and DPA Annex 2.

8.3 Acceptance evidence. Garuna records an Authorised User's acceptance of the in-product legal gate (which references these Early Access Terms, the Terms, the Acceptable Use Policy, the Privacy Policy, and the Disclaimers) as evidence of acceptance, as described in the Privacy Policy.

9. Limitation of liability for Early Access

9.1 Exclusion of indirect damages. The exclusion of indirect, incidental, special, consequential, and similar damages in clause 13.1 of the Terms applies during Early Access.

9.2 Early Access liability cap. Because the Service is provided at early-access pricing during Early Access, the parties agree that, notwithstanding clause 13.2 of the Terms, Garuna's total aggregate liability arising out of or related to the Service, these Early Access Terms, the Terms, and the Service during and in respect of the Early Access Period will not exceed CAD $5,000. This is a single aggregate cap and is not multiplied by the number of claims, Sweeps, Subjects, or Authorised Users.

9.3 Carve-outs and Client obligations preserved. The carve-outs in clause 13.4 of the Terms (and the consumer-law savings in clause 13.6) continue to apply, so this cap does not limit liability that cannot be limited under applicable law. The cap in this clause 9 limits Garuna's liability only; it does not limit the Client's payment obligations or the Client's indemnification obligations under clause 14 of the Terms, which continue to apply during Early Access in full (including in respect of unlawful or unauthorised use, breach of the Acceptable Use Policy, absence of a lawful basis, third-party-platform and Subject claims, and consumer-report misuse).

9.4 Allocation of risk. The Client acknowledges that the Output is intelligence to inform human judgement, that the Client is responsible for verifying it and for any decision it makes, and that — given the Service is provided at early-access pricing — the limitations in this clause 9 are a reasonable allocation of risk and an essential basis on which Garuna offers Early Access.

10. Subjects are not parties

10.1 As under clause 10 of the Disclaimers, a Subject is a third party who is not a party to these Early Access Terms or the Terms and is generally unaware of a Sweep. Nothing in these Early Access Terms, and no disclaimer, exclusion, or cap of liability in it or in the Terms, limits or affects any direct statutory or common-law claim a Subject or other third party may have against Garuna or the Client (including in defamation, in tort, for breach of privacy, or under PIPEDA, Quebec Law 25, or the GDPR / UK GDPR). As between Garuna and the Client, the Client's selection of Subjects, its Subject Inputs, and its use of the Output remain the Client's responsibility, and the Client's indemnity in clause 14 of the Terms applies.

11. Relationship to the Terms; order of precedence

11.1 These Early Access Terms is part of the Terms and is incorporated into them. The Terms, the Acceptable Use Policy, the Privacy Policy, the DPA, the Disclaimers & Legal Notices, and the Sub-processor List continue to apply in full to the Client's use of the Service during Early Access.

11.2 Order of precedence. For the Early Access Period, and solely as to the specific matters of fees (clause 3), term and termination (clause 2), and the liability cap (clause 9), these Early Access Terms prevails over any inconsistent provision of the Terms. On all other matters, the order of precedence in clause 24.1 of the Terms applies (the DPA prevailing on personal-data processing).

12. Governing law and venue

12.1 These Early Access Terms is governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein, and the governing-law, venue, notices, and general provisions of the Terms (clauses 19–24) apply to it.

Garuna Group — Enhanced Due Diligence (EDD). Early Access Terms, Version 1.2, effective 2026-09-02 — Garuna Inc. (operating as "Garuna Group"), 10 Thornmount Drive, Toronto, Ontario M1B 3J4, Canada — [email protected]. These Early Access Terms is incorporated into and forms part of the Terms of Service / Master Services Agreement; the Acceptable Use Policy, Privacy Policy, DPA, Disclaimers & Legal Notices, and Sub-processor List continue to apply.