Acceptable Use Policy

1. Purpose and Scope

This Acceptable Use Policy (“AUP”) defines the permitted and prohibited uses of CFO Silvia, including the website, applications, AI-powered financial assistant, APIs, and all related products, features, and communication channels (collectively, the “Silvia Service”) provided by CFO Silvia, Inc. (“Silvia,” “we,” “us,” or “our”), a wholly owned subsidiary of ProCap Financial, Inc.

This AUP is incorporated by reference into the CFO Silvia Supplemental Terms of Service and applies to all users of the Silvia Service. Capitalized terms not defined here have the meanings assigned in the Supplemental Terms, the General Terms, or the Privacy Policy.

We may update this AUP from time to time. Material changes will be communicated through the mechanisms described in the Supplemental Terms. Your continued use of the Silvia Service after changes constitutes acceptance.

2. Guiding Principles

The Silvia Service exists to help individuals understand and manage their financial lives. This AUP is grounded in the following principles:

Lawful Use. The Silvia Service may only be used in compliance with all applicable laws, regulations, and these Terms.
Accuracy and Honesty. Users must provide truthful information and may not use the Silvia Service to deceive, defraud, or mislead anyone.
Respect for Others. Users may not use the Silvia Service in ways that harm, threaten, or violate the rights of other users, Silvia, or third parties.
Security and Integrity. Users may not compromise the security, availability, or integrity of the Silvia Service or the data within it.
Responsible AI Use. Users must interact with the AI assistant responsibly, understanding its limitations and not misrepresenting its Outputs as professional advice.

3. Prohibited Activities

The following activities are prohibited. This list is not exhaustive; Silvia reserves the right to determine, in its sole discretion, whether any conduct violates the spirit of this AUP.

3.1 Illegal and Harmful Activity

Using the Silvia Service to facilitate, promote, or engage in any illegal activity, including fraud, money laundering, terrorist financing, tax evasion, or other financial crimes.
Using the Silvia Service to evade sanctions, export controls, or trade restrictions imposed by the United States or any applicable jurisdiction.
Using the Silvia Service in connection with activity that violates the laws of any jurisdiction in which you operate or in which the Silvia Service is accessed.
Using the Silvia Service to stalk, harass, bully, threaten, defame, or intimidate any person.
Using the Silvia Service to generate, distribute, or store content that exploits minors in any way.
Using the Silvia Service to facilitate the sale or distribution of controlled substances, illegal weapons, or other prohibited goods or services.

3.2 Fraud, Deception, and Misrepresentation

Providing false, misleading, or inaccurate information when creating an account, linking financial accounts, or interacting with the Silvia Service.
Impersonating another person, entity, or organization, or falsely claiming affiliation with any person or entity.
Creating fake accounts or multiple accounts to circumvent usage limits or bans.
Using the Silvia Service to generate fraudulent financial documents, fabricated transaction records, or misleading financial statements.
Manipulating Inputs to elicit Outputs that misrepresent financial data, create fictitious scenarios for fraudulent purposes, or produce content intended to deceive third parties.
Representing AI-generated Outputs as certified, audited, or professionally verified financial advice, analysis, or opinions.
Using the Silvia Service to create synthetic identities or to perpetrate identity theft or fraud.

3.3 Misuse of AI Capabilities

Attempting to manipulate, bypass, or circumvent the AI assistant’s safety measures, content filters, guardrails, or system instructions through prompt injection, jailbreaking, or similar techniques.
Using the Silvia Service to generate content that constitutes individualized financial, investment, tax, or legal advice for third parties, or distributing AI-generated Outputs as if they were the product of a licensed professional.
Systematically extracting, harvesting, or collecting AI Outputs to build, train, fine-tune, or evaluate a competing AI model, machine learning system, or similar technology.
Using the Silvia Service to generate content intended to manipulate financial markets, engage in securities fraud, or disseminate false financial information.
Using the Silvia Service to create automated financial trading systems or generate real-time trading signals without independent professional oversight.
Using the AI assistant to process, analyze, or generate content related to protected health information subject to HIPAA or similar regulations.
Inputting data belonging to third parties without their knowledge or consent for the purpose of generating financial profiles, risk assessments, or other analyses of those third parties.

3.4 Technical Abuse and Security Violations

Attempting to gain unauthorized access to any part of the Silvia Service, other users’ accounts, or any connected systems, networks, or databases.
Reverse engineering, decompiling, disassembling, or otherwise attempting to derive the source code, algorithms, model weights, training data, or underlying technology of the Silvia Service.
Introducing viruses, malware, trojans, worms, ransomware, logic bombs, or other harmful code.
Using automated tools, bots, crawlers, scrapers, or scripts to access or interact with the Silvia Service, except through APIs expressly provided for such purposes and in compliance with applicable rate limits.
Circumventing, disabling, or interfering with any security, authentication, access control, rate-limiting, or content-filtering features.
Conducting vulnerability scans, penetration tests, or security assessments without prior written authorization. Report vulnerabilities to security@cfosilvia.com.
Overloading, flooding, or deliberately degrading the performance or availability of the Silvia Service.
Intercepting, monitoring, or modifying data transmitted to or from the Silvia Service without authorization.

3.5 Data and Privacy Violations

Collecting, harvesting, or scraping personal information of other users.
Using the Silvia Service to store, process, or transmit data subject to regulatory requirements that Silvia has not explicitly agreed to support, including protected health information (HIPAA), payment card industry data (PCI-DSS) beyond what is handled by our payment processors, classified government information, or data subject to ITAR.
Uploading or providing data that you do not have the legal right to collect, use, or disclose.
Using the Silvia Service to circumvent or violate data protection or privacy laws applicable to you.
Attempting to re-identify any individual from Anonymized Data or combining Anonymized Data with other data sources for re-identification.

3.6 Intellectual Property Violations

Using the Silvia Service in a manner that infringes the intellectual property or proprietary rights of Silvia or any third party.
Using Silvia’s name, logos, trademarks, or brand elements without prior written permission.
Framing, mirroring, or embedding any part of the Silvia Service on another website or application without express written consent.

3.7 Spam, Abuse, and Commercial Misuse

Using the Silvia Service to send unsolicited communications, advertisements, or spam.
Using the Silvia Service to generate bulk or automated content for distribution without clear human oversight.
Reselling, sublicensing, or providing access to the Silvia Service to third parties without written authorization.
Using the Silvia Service to operate a competing financial advisory, AI assistant, or financial data service.
Using the Silvia Service in a manner that consumes disproportionate resources or degrades the experience for other users.

4. Responsible Use of Financial Information

4.1 Your Financial Data

You are responsible for the accuracy and completeness of financial data you provide or link. Inaccurate input data produces inaccurate Outputs.
You should regularly review your linked financial accounts for accuracy and promptly disconnect accounts you no longer wish to share.
You should not link financial accounts belonging to other individuals without their knowledge and explicit consent.

4.2 AI-Generated Financial Analysis

AI-generated Outputs are informational tools, not substitutes for professional financial, tax, investment, or legal advice.
You should independently verify any AI-generated Output before making financial decisions.
You should not represent AI-generated Outputs to any third party as certified financial analysis, audited financial statements, or the product of a licensed financial professional.
You are solely responsible for financial decisions you make using or based on information from the Silvia Service.

4.3 Third-Party Financial Integrations

When you link third-party financial accounts, you authorize the transmission of your financial data from those services to Silvia.
You are responsible for ensuring your use of third-party integrations complies with those services’ terms and conditions.
Silvia is not responsible for the accuracy, availability, or security of data provided by third-party integration partners.

5. API and Developer Use

If API access is offered, the following additional terms apply:

Rate Limits: You must comply with all published rate limits, quotas, and usage restrictions.
Authentication: API keys and credentials are confidential. You are responsible for safeguarding them and for all activity conducted using them.
Output Attribution: You must not represent API Outputs as being generated by any source other than CFO Silvia unless expressly permitted.
No Competing Models: You may not use API Outputs to develop, train, or improve any competing AI system without explicit written authorization.
Personal Use: API access is for individual, personal use. Commercial or business use requires separate authorization.

6. Content Standards

Any content you submit through the Silvia Service must comply with the following:

Content must not be illegal, obscene, defamatory, threatening, harassing, discriminatory, or otherwise objectionable.
Content must not infringe any third-party intellectual property, privacy, publicity, or contractual rights.
Content must not contain viruses, malware, or harmful code.
Content must not be deceptive, misleading, or intended to facilitate fraud.
Content must not include sensitive personal information of third parties that you do not have the right to provide.

We reserve the right to remove or disable access to any content that violates this AUP, without notice.

7. Monitoring and Enforcement

7.1 Monitoring

We reserve the right, but are not obligated, to monitor use of the Silvia Service for compliance with this AUP. Monitoring may include automated systems, manual review of flagged activity, and analysis of usage data. Monitoring will be conducted in accordance with our Privacy Policy and applicable law.

7.2 Enforcement Actions

If we determine that a violation has occurred, we may take one or more of the following actions at our sole discretion and without prior notice:

Issuing a warning requiring you to cease the prohibited activity.
Temporarily suspending your access to some or all of the Silvia Service.
Permanently terminating your account and access.
Removing or disabling access to violating content.
Revoking API credentials and access.
Limiting or throttling your use of specific features.
Reporting the activity to law enforcement, regulatory authorities, or affected third parties.
Pursuing legal action, including claims for damages and injunctive relief.

7.3 Proportionality

We aim to apply enforcement actions that are proportionate to the severity and frequency of the violation. Minor or inadvertent violations may result in a warning. Serious, intentional, or repeated violations may result in immediate account termination.

8. Reporting Violations

If you become aware of any activity that violates this AUP, please report it promptly:

General Violations: abuse@cfosilvia.com
Security Vulnerabilities: security@cfosilvia.com
Privacy Concerns: privacy@cfosilvia.com
Legal and IP Concerns: legal@cfosilvia.com

When reporting, please include as much detail as possible, including the nature of the violation, supporting evidence, and the date and time of the incident.

9. Appeals

If you believe an enforcement action was taken in error, you may submit an appeal to legal@cfosilvia.com within thirty (30) days. Include your account information, a description of the enforcement action, and an explanation of why you believe it was unwarranted. We will review and respond within fifteen (15) business days. The enforcement action remains in effect during the appeal process unless we determine otherwise. Our decision on appeal is final.

10. Interaction with Other Policies

This AUP is part of a broader set of policies governing your use of the Silvia Service. In the event of a conflict, the following order of precedence applies:

CFO Silvia Supplemental Terms of Service (highest precedence)
ProCap Financial, Inc. Terms and Conditions of Use
Privacy Policy
This Acceptable Use Policy
AI and Algorithmic Transparency Statement

A violation of this AUP also constitutes a breach of the Supplemental Terms and the General Terms.

11. Contact Information

CFO Silvia, Inc.

A wholly owned subsidiary of ProCap Financial, Inc.

Abuse Reports: abuse@cfosilvia.com

Security: security@cfosilvia.com

Privacy: privacy@cfosilvia.com

Legal: legal@cfosilvia.com

General Support: support@cfosilvia.com

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