Terms of Service

By accessing or using CAIRL ("the Service"), operated by reAPPlicate Incorporated, a Florida corporation, you agree to be bound by these Terms of Service ("Terms"). If you do not agree to these Terms, you may not use the Service.

To use CAIRL, you must meet one of the following eligibility requirements:

• Be at least 18 years of age and have the legal capacity to enter into a binding agreement, or
• Participate through a circle managed by a parent, legal guardian, or authorized adult on an eligible Identity Plan (see Section 6: Circle and Family Terms)

All users must provide accurate and complete information when creating an account and must not be prohibited from using the Service under applicable law.

CAIRL is a privacy-first identity verification platform. The Service includes the following capabilities at launch:

• Identity verification (CAIRL:verify) — Verify your identity using government-issued documents, biometric matching, and liveness detection
• Document storage (CAIRL/vault) — Securely store and manage your identity documents and verification records
• Verification sharing (CAIRL:connect) — Share verified claims with connected services you authorize via OAuth
• Proxy email (CAIRL/mail) — Generate proxy email addresses that protect your inbox when connecting to third-party services
• Authenticator and MFA (CAIRL/keys) — Manage multi-factor authentication credentials

Additional capabilities may be introduced over time. The specific features and resource limits available to you depend on your Identity Plan or Infrastructure Agreement (see Section 8: Billing and Payment Terms).

Platform functionality is identical across plans. Plans control scale, resource allocation, and governance scope — not feature availability.

When you create an account, you agree to:

• Provide accurate information — Your name, email, and other account details must be truthful
• Maintain one account — Each individual may only have one CAIRL account. We enforce this through biometric uniqueness checks during identity verification, as described in our Privacy Policy
• Keep your account secure — You are responsible for maintaining the confidentiality of your password and account credentials
• Notify us of unauthorized access — Contact us immediately at security@cairl.app if you suspect unauthorized use of your account

You are responsible for all activities that occur under your account. Uniqueness enforcement is designed to reduce duplicate accounts but is not guaranteed to detect all cases. We may provide remediation pathways in cases of verification errors or false biometric matches. If you believe you have been incorrectly flagged by our uniqueness enforcement, contact support@cairl.app.

4.1 Your Obligations

When using our identity verification services, you agree that:

• You will only submit real, valid, government-issued identity documents that belong to you
• All information you provide during verification must be truthful
• You will provide biometric consent through our verification interface before any biometric data is collected, as described in our Privacy Policy

4.2 Our Rights

We reserve the right to:

• Reject verification attempts that appear fraudulent or suspicious
• Revoke verified status if we discover fraud or misrepresentation
• Retain a biometric reference (facial embedding) for uniqueness enforcement and fraud prevention, as described in our Privacy Policy
• Report suspected fraud or identity theft to appropriate authorities, consistent with the Disclosure of Information section of our Privacy Policy

4.3 Verification Results

Your verification status may be shared with connected services only when you explicitly authorize such sharing. Connected services receive verification results (claims such as "age verified" or "identity verified") — they do not receive your identity documents, biometric data, or raw personal information.

CAIRL provides verification signals and claims based on submitted information. CAIRL provides verification infrastructure, not legal identity certification. CAIRL is not a government authority, certification body, or regulated KYC provider unless explicitly stated in a separate written agreement. CAIRL does not act as a financial intermediary, payment processor, or custodian of funds.

Connected services are solely responsible for determining whether CAIRL verification results meet their legal and regulatory requirements. CAIRL does not assume responsibility for compliance decisions made by connected services based on our verification results.

CAIRL does not use biometric or verification data to track users across unrelated services or for advertising, profiling, or behavioral monitoring.

5.1 Prohibited Conduct (All Users)

You agree not to:

• Submit fraudulent, forged, altered, or stolen identity documents
• Impersonate another individual or attempt to verify as someone other than yourself
• Create multiple accounts or circumvent biometric uniqueness enforcement
• Attempt to bypass, disable, or interfere with security features, including bot protection and liveness detection
• Use automated tools, bots, or scripts to access the Service without our written consent
• Use the Service for any unlawful purpose
• Take actions that could damage, disable, or impair the Service
• Attempt to decompile, disassemble, reverse engineer, or derive the source code of the Service

5.2 Additional Obligations for Business Users

If you operate a business context on CAIRL, you additionally agree to:

• Use verification results (claims) only for the purposes authorized by the verifying user
• Honor user consent revocations promptly — when a user revokes consent, you must cease using their claims
• Not re-sell, sublicense, or redistribute verification results or claims to any third party
• Not use claims to build profiles, dossiers, or behavioral tracking systems about users
• Not use verification results or claims to train machine learning models or AI systems without explicit written consent from CAIRL
• Not use CAIRL solely as a free authentication service — OAuth production calls must include at least one CAIRL verification claim
• Comply with all applicable laws regarding the use of identity verification data

5.3 Additional Obligations for Developers

If you access the Service via API, you additionally agree to:

• Respect rate limits and usage quotas as documented in our API documentation
• Keep API keys confidential and not share them publicly
• Use sandbox environments for testing and development — not production keys
• Comply with our API documentation and integration guidelines

We reserve the right to revoke API keys, suspend accounts, or terminate access for violation of these terms.

6.1 Circle Creation and Management

Users on eligible Identity Plans (Identity Plus and Identity Prime) may create circles — shared identity governance contexts for families, teams, clubs, and other groups. Circle administrators are responsible for managing circle membership, verification, and privacy settings.

6.2 Minor Participation

Minors (anyone under 18) may participate in CAIRL only through a circle managed by their parent, legal guardian, or an authorized adult.

If you manage a circle that includes minors, you represent and warrant that:

• You are the minor's parent, legal guardian, or authorized custodian
• You provide verifiable parental consent for the collection and processing of the minor's identity information, as required by the Children's Online Privacy Protection Act (COPPA) and applicable state laws
• You accept responsibility for governing the minor's identity data, privacy settings, and sharing permissions within the circle
• You understand that you may delete the minor's data at any time through circle management controls

6.3 Circle Administrator Liability

CAIRL relies on the circle administrator's representation of guardianship or custodial authority. If we become aware that a minor's data is being managed by someone without proper authority, we will suspend access and notify the appropriate parties.

Circle administrators are responsible for all activity within their circles, including the actions of circle members.

6.4 Circle Structural Constraints

Circles are flat governance contexts. Circles cannot contain other circles. Nested circles, circle hierarchies, circle-to-circle delegation, and circle inheritance are not supported. Organizations requiring hierarchical identity structures should use Infrastructure Agreements.

Your privacy is important to us. Our collection, use, and protection of your personal information — including biometric data — is governed by our Privacy Policy, which is incorporated into these Terms by reference.

By using the Service, you consent to the collection and processing of your information as described in our Privacy Policy. Biometric consent is obtained separately through an explicit consent prompt in the verification interface before any biometric data is collected. This biometric consent is separate from your acceptance of these Terms.

You may withdraw biometric consent at any time by contacting privacy@cairl.app or by deleting your account, as described in our Privacy Policy.

CAIRL does not sell, lease, or otherwise monetize biometric data. Biometric data is used solely for identity verification, fraud prevention, and uniqueness enforcement as described in our Privacy Policy.

CAIRL operates two separate pricing domains. Your billing terms depend on which domain applies to your usage.

8.1 Identity Plans (Individuals, Families, Communities)

Identity Plans govern personal identity ownership and coordination.

Identity Plan subscriptions auto-renew at the end of each billing period. You may cancel at any time; cancellation takes effect at the end of the current billing period. No partial refunds are issued for the remaining period.

Identity Plan governance limits (such as total circle member counts) require a plan upgrade and cannot be expanded through additional payment.

8.2 Infrastructure Agreements (Platforms, Businesses, Government)

Infrastructure Agreements govern commercial use of CAIRL's identity verification infrastructure.

Metered (usage-based):

Metered usage requires a prepaid wallet with a minimum load of $50.00. Usage is deducted from the prepaid balance. Wallet reload increments are: $50 / $100 / $250 / $500 / $1,000. Stripe processing fees are included in the wallet load amount (grossed up to the Business User, not absorbed by CAIRL).

Contract (committed usage):

Contract agreements require a minimum committed spend of $500/month ($6,000/year). Committed spend is a locked monthly amount, paid regardless of usage. Discounts: 10% for monthly billing, 20% for annual prepaid.

Enterprise (negotiated):

Enterprise agreements provide custom pricing, SLA guarantees, and dedicated support under separate written agreement.

8.3 Wallet Terms

Prepaid wallet balances are subject to our Refund Policy. Upon account termination, any remaining wallet balance is forfeited unless termination is initiated by CAIRL without cause, in which case the remaining balance will be refunded.

Wallet balances do not earn interest and are not held in escrow. CAIRL may apply wallet funds to outstanding usage charges. The CAIRL wallet is a prepaid service balance for platform usage and does not represent a deposit account, stored value instrument, or financial product. Wallet balances are solely for prepayment of CAIRL services and cannot be transferred, redeemed for cash, or used outside the Service. Wallet balances represent prepaid access to CAIRL services only and do not represent funds held on behalf of the user.

8.4 Price Changes

We may change our prices with at least 30 days' notice. Price changes for existing subscriptions take effect at the next renewal date. Price changes for metered usage take effect 30 days after notice. Committed contract rates are locked for the contract term.

8.5 Refunds

Completed identity verifications and enrollments are non-refundable. Subscription cancellations take effect at the end of the current billing period with no partial refund. We may offer refunds at our discretion for exceptional circumstances.

8.6 Compliance Gating

Access to certain features and environments may be gated by compliance requirements. Business Users progress through compliance stages (exploration, integration, activation) as documented in our developer documentation. Full production access requires completion of applicable compliance requirements, including minimum wallet funding.

9.1 Our Property

reAPPlicate Incorporated and its licensors own all rights, title, and interest in the Service, including the CAIRL name, logo, branding, and all associated trademarks; the platform software, technology, and infrastructure; and all content we create, including documentation and website content. You may not use our trademarks, logos, or branding without our prior written consent.

9.2 Your Property

You retain ownership of your identity documents, your personal information, and any content you submit to the Service. By using the Service, you grant us a limited, non-exclusive license to process your documents and information solely to provide the Service to you, enforce these Terms, and comply with applicable law.

The Service integrates with third-party service providers as described in our Privacy Policy, including AWS (infrastructure and identity verification processing), Stripe (payments and billing), Plaid (bank account verification), Mailgun (email delivery and proxy relay), Cloudflare (bot protection), Vercel (hosting), and Upstash (caching). These integrations are subject to the respective provider's terms of service.

You may also connect your CAIRL account to third-party connected services through our OAuth integration. When you do so:

• You control what verification claims are shared with each connected service
• Connected services receive verification results (claims), not your raw identity documents or biometric data
• The connected service's terms and privacy policy govern their use of your verification results
• You can revoke access at any time from your CAIRL account settings

We strive to maintain high availability but do not guarantee 100% uptime. The Service may be unavailable due to scheduled maintenance (we will provide advance notice when possible), unplanned outages or technical difficulties, or factors outside our control, including network issues, natural disasters, acts of government, pandemics, cyberattacks, or failures of third-party infrastructure providers.

We are not liable for any loss or damage resulting from Service unavailability, except as otherwise provided in a separate Enterprise agreement with SLA guarantees.

You have the right to export your data in a portable format, as described in our Privacy Policy. We will provide data export functionality through your account settings or upon request to privacy@cairl.app.

The Service is provided "as is" and "as available" without warranties of any kind, either express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, non-infringement, and uninterrupted or error-free service.

We do not warrant that your verification will be accepted by all third parties. Connected services may have their own verification requirements beyond what CAIRL provides.

We do not warrant that biometric uniqueness checks will detect all duplicate accounts or prevent all fraud.

To the maximum extent permitted by law, reAPPlicate Incorporated shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, revenue, or data; business interruption; or cost of substitute services.

Our total liability for any claims arising from or related to these Terms or the Service shall not exceed the greater of (a) the amount you paid to us in the twelve (12) months preceding the claim, or (b) one hundred dollars ($100).

Some jurisdictions do not allow limitations on implied warranties or exclusion of certain damages. If these laws apply to you, some or all of the above limitations may not apply. Nothing in these Terms limits liability for fraud, gross negligence, or willful misconduct.

You agree to indemnify, defend, and hold harmless reAPPlicate Incorporated and its officers, directors, employees, and agents from any claims, damages, losses, or expenses (including reasonable attorneys' fees) arising from your use of the Service, your violation of these Terms, your violation of any third-party rights, any content or documents you submit to the Service, or, if you are a circle administrator, any misrepresentation of guardianship or custodial authority.

16.1 By You

You may close your account at any time through your account settings or by contacting us at support@cairl.app. Upon closure:

• Your access to the Service will be revoked
• Your data will be handled according to our Privacy Policy, including the destruction of biometric data within 30 days
• Active subscriptions will not be refunded for the remaining period
• Prepaid wallet balances are forfeited except as described in Section 8.3

16.2 By Us

We may suspend or terminate your account if you violate these Terms, engage in fraudulent activity, fail to pay applicable fees, or create unreasonable risk or legal exposure for us.

We will provide notice before termination when reasonably possible, except in cases of fraud, serious violations, or where notice would compromise the security of the Service or other users.

16.3 Effect of Termination

Upon termination, your right to use the Service ceases immediately. Sections that by their nature should survive termination will survive, including Intellectual Property, Disclaimer of Warranties, Limitation of Liability, Indemnification, and Dispute Resolution.

17.1 Informal Resolution

Before filing any formal dispute, you agree to contact us at legal@cairl.app and attempt to resolve the dispute informally for at least 30 days.

17.2 Binding Arbitration

If we cannot resolve the dispute informally, any dispute arising from these Terms shall be resolved through binding arbitration conducted by a single arbitrator under the rules of the American Arbitration Association. The arbitration shall take place in Broward County, Florida, unless otherwise agreed by the parties.

17.3 Biometric Privacy Carve-Out

To the extent prohibited by applicable law, the arbitration provision in Section 17.2 does not apply to claims arising under state biometric privacy statutes, including the Illinois Biometric Information Privacy Act (BIPA), Texas CUBI, or Washington's biometric identifier law.

17.4 Class Action Waiver

You agree to resolve disputes only on an individual basis and waive any right to participate in a class action lawsuit or class-wide arbitration.

17.5 Small Claims Exception

Either party may bring qualifying claims in small claims court.

These Terms shall be governed by the laws of the State of Florida, without regard to conflict of law principles. Any litigation not subject to arbitration shall be brought in the state or federal courts located in Broward County, Florida.

We may update these Terms from time to time. When we make material changes:

• We will notify you via email at least 30 days before changes take effect
• We will update the "Last Updated" date at the top of this page
• We will post the revised Terms on this page

Your continued use of the Service after changes take effect constitutes your acceptance of the revised Terms. If you do not agree to the revised Terms, you must stop using the Service before the changes take effect.

Entire Agreement — These Terms, together with our Privacy Policy and any applicable Infrastructure Agreement, constitute the entire agreement between you and reAPPlicate Incorporated regarding the Service.

Severability — If any provision of these Terms is found unenforceable, the remaining provisions remain in full effect.

No Waiver — Our failure to enforce any right or provision of these Terms does not constitute a waiver of that right or provision.

Assignment — You may not assign or transfer these Terms without our prior written consent. We may assign these Terms without restriction in connection with a merger, acquisition, or sale of assets.

Force Majeure — We shall not be liable for any failure or delay in performing our obligations under these Terms where such failure or delay results from circumstances beyond our reasonable control, including natural disasters, acts of government, pandemics, war, terrorism, labor disputes, infrastructure failures, or cyberattacks.

Notices — Notices to you will be sent to the email address associated with your account. Notices to us should be sent to legal@cairl.app.

For questions about these Terms, contact us:

• Legal inquiries: legal@cairl.app
• Security concerns: security@cairl.app
• General support: support@cairl.app
• Privacy inquiries: privacy@cairl.app
• Address: reAPPlicate Incorporated, 3200 NW 62nd Avenue #22, Margate, FL 33063