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Terms of Service

Trusted Life Circle, Inc. Last Updated: May 19, 2026 Effective Date: May 19, 2026

1. Agreement to Terms

These Terms of Service (“Terms”) form a binding contract between you and Trusted Life Circle, Inc., a Wisconsin corporation (“TLC,” “we,” “us,” or “our”). They govern your access to and use of the Trusted Life Circle mobile application, our website at tlcapp.io, and related services (collectively, the “Service”).

BY CREATING AN ACCOUNT, ACCESSING, OR USING THE SERVICE, YOU AGREE TO THESE TERMS AND OUR PRIVACY POLICY. IF YOU DO NOT AGREE, DO NOT USE THE SERVICE. PLEASE READ SECTION 25 (DISPUTE RESOLUTION AND ARBITRATION) AND THE CLASS ACTION WAIVER IN SECTION 25(d) CAREFULLY. THEY AFFECT YOUR LEGAL RIGHTS.

2. Definitions

“VIP” means an individual living with Mild Cognitive Impairment (MCI), Alzheimer’s disease, or another form of dementia who is the central member of a Circle.

“Guardian” means a User who administers a Circle, typically a primary caregiver or family member of a VIP.

“Contributor” means a User who participates in a Circle by sharing content with the VIP.

“Circle” means a private, invitation-only group of Users centered around a single VIP.

“User” means any person who accesses or uses the Service.

“User Content” means any photos, videos, messages, captions, voice clips, or other content submitted to the Service by a User.

3. Description of Service

TLC is a private, permission-based communication platform designed to help families and caregivers stay connected with a loved one experiencing cognitive challenges. The Service enables Guardians to administer a Circle around a VIP and Contributors to share moments within that Circle in a dementia- informed interface. The Service is not a medical device, healthcare service, monitoring service, or emergency response system. See Sections 14 and 15.

4. Eligibility

You must be at least 18 years of age and capable of forming a binding contract under applicable law to register an account or serve as a Guardian or Contributor. A VIP may participate in a Circle subject to applicable children’s privacy law; accounts on behalf of a VIP must be established and administered by a Guardian. The Service is not directed to children under 13 (or under the age of digital consent set by your jurisdiction, which may be higher in the European Economic Area, United Kingdom, or elsewhere).

5. Account Registration and Security

You agree to: Provide accurate, current, and complete information during registration and keep it updated; Maintain the security and confidentiality of your credentials, including any passkey or biometric authentication; Notify us promptly at [email protected] if you suspect unauthorized access; Accept responsibility for activity occurring under your account. We may suspend, restrict, or terminate accounts that violate these Terms or that we reasonably believe pose a risk to other Users.

6. User Roles

The Service uses three User roles:

a. Guardian. A Guardian creates and administers a Circle, manages other Users’ access, and curates the VIP’s experience. By accepting the Guardian role, you represent that: You have the informed consent of the VIP (where the VIP retains capacity to give consent); or You have legal authority to act on the VIP’s behalf, including a power of attorney, healthcare proxy, court-appointed guardianship, or that you are an immediate family member acting in good faith and in the VIP’s best interest where no formal designation exists; and No other person has a superior legal right to administer matters relating to the VIP that would conflict with your use of the Service.

b. Contributor. A Contributor participates in a Circle at the invitation of a Guardian and agrees to share content appropriate for the VIP and the Circle.

c. VIP. A VIP is the central member of a Circle. The Service’s design assumes the VIP may have variable capacity and may rely on a Guardian for administrative decisions. Where a VIP retains capacity, they may withdraw consent to participate at any time by contacting their Guardian or TLC directly at [email protected].

If you act as a Guardian for a VIP, you represent and warrant that you act in good faith and in the VIP’s best interest, and that you have authority under applicable law to: Establish and administer the Circle; Manage Contributors’ access; Determine what content is appropriate for the VIP to view; Process information about the VIP through the Service. If there is a dispute among family members or other interested parties regarding authority over a VIP, TLC reserves the right to suspend the Circle pending resolution of the dispute or, at our discretion, to require documentation of legal authority. If a VIP later regains or asserts capacity and withdraws consent, the Circle must be modified or closed at the VIP’s direction.

8. Subscriptions, Billing, and Auto-Renewal

Certain features of the Service require a paid subscription. Subscription titles, billing periods, pricing, and feature inclusions are disclosed within the Service before purchase.

a. Auto-Renewal. Subscriptions automatically renew at the end of each billing period for the same duration at the then-current price unless cancelled at least 24 hours before the end of the current period. You authorize us (through Apple, Google, or another payment processor) to charge your payment method on each renewal.

b. Cancellation. You may cancel a subscription at any time through your Apple ID Subscription settings (iOS) or Google Play Subscription settings (Android). Cancellation takes effect at the end of the current billing period; you retain access to subscription features until that time. We do not provide refunds for partial periods except where required by law or in accordance with the platform provider’s refund policy.

c. Free Trials. Free trials, if offered, automatically convert to a paid subscription at the trial’s conclusion unless cancelled before that date. To avoid charges, cancel at least 24 hours before the trial ends.

d. Price Changes. We may change subscription prices. Material changes will be communicated in advance, and continued use after the change constitutes acceptance.

9. User Content and License

You retain ownership of User Content you submit. By submitting User Content, you grant TLC a worldwide, non-exclusive, royalty-free, sublicensable (to our service providers) license to host, store, reproduce, transmit, display, format, modify (for technical compatibility), back up, and otherwise use such User Content solely as necessary to operate, provide, maintain, secure, and improve the Service. This license terminates when you delete the User Content, except as required for backups, legal compliance, or established service-provider retention windows. You represent and warrant that you own or have all necessary rights, consents, and permissions to submit the User Content, including any depiction of the VIP or other identifiable individuals, and that submission and use within the Service does not violate any third party’s rights. We do not use User Content to train artificial intelligence or machine learning models.

10. Acceptable Use

You agree not to: Submit content that is unlawful, defamatory, harassing, threatening, obscene, hateful, or that infringes another’s rights; Submit content depicting or directed at minors in any sexual or suggestive way; Impersonate another person or misrepresent your relationship with the VIP; Use the Service for commercial purposes, advertising, or solicitation; Attempt unauthorized access to other accounts, Circles, or systems; Probe, scan, or test the Service for vulnerabilities except under a written security research agreement with TLC; Use automated means to access or extract data from the Service; Use the Service to exploit, harm, or financially abuse the VIP or any other User; Use the Service in violation of any law or regulation.

11. Content Moderation

We may, but are not obligated to, review, restrict, or remove User Content that we believe in good faith violates these Terms, harms a User, or violates law. Where moderation features are enabled by a Guardian, we may apply automated content analysis to detect potentially harmful content. We are not responsible for User Content shared within a Circle.

TLC complies with the Digital Millennium Copyright Act. If you believe content within the Service infringes your copyright, send a notice containing the elements required by 17 U.S.C. § 512(c)(3) to our Designated Agent: TLC Designated Agent Trusted Life Circle, Inc. 309 N Water St Ste 203 Milwaukee, WI 53202 Email: [email protected] We will respond to valid notices and may terminate the accounts of repeat infringers.

13. Privacy

Our collection and use of personal information is described in our Privacy Policy, incorporated into these Terms by reference.

14. No Medical Advice or Diagnosis

The Service is informational and social in nature. It is not a substitute for professional medical, psychological, legal, or financial advice, diagnosis, or treatment. Information shared through, displayed in, or derived from the Service is not clinical data. Engagement patterns, posting frequency, response times, or any other metric available through the Service must not be interpreted as a clinical assessment of the VIP’s condition. Always seek the advice of a qualified healthcare professional regarding any medical condition.

15. Not for Emergencies

THE SERVICE IS NOT DESIGNED OR INTENDED FOR USE IN EMERGENCIES. DO NOT USE THE SERVICE TO REPORT, RESPOND TO, OR SEEK ASSISTANCE WITH MEDICAL EMERGENCIES, SAFETY EMERGENCIES, OR ANY OTHER URGENT SITUATION. IF YOU OR A VIP IS EXPERIENCING AN EMERGENCY, CALL 911 (IN THE UNITED STATES) OR YOUR LOCAL EMERGENCY NUMBER.

16. Account Termination

We may suspend or terminate your account if: You materially breach these Terms; Your use creates risk to the VIP, other Users, or TLC; Required by law or to comply with legal process; The Service is discontinued. You may close your account at any time through in-app settings or by contacting [email protected]. On account closure, your User Content will be deleted in accordance with our Privacy Policy, subject to retention required for legal compliance.

17. Death or Incapacity

If a User dies, we will, on receipt of acceptable documentation (such as a death certificate), close the account and delete personal data subject to our retention obligations. If a VIP dies, the Guardian remains responsible for the Circle and may close it, archive its contents, or designate a successor administrator where appropriate. If a Guardian becomes incapacitated or dies, a successor Guardian may be designated by the VIP (where the VIP retains capacity), by the prior Guardian’s legal representative, or by TLC at its discretion based on reasonable evidence of authority. We may require documentation.

18. Service Availability

We do not guarantee that the Service will be available, uninterrupted, error-free, or secure. We may modify, suspend, or discontinue features at any time with or without notice.

19. Third-Party Services

The Service incorporates services provided by third parties, including Apple (App Store, in-app purchases, push notifications, Sign in with Apple), Google (Google Play, in-app purchases, push notifications, Sign in with Google), Stripe (payment processing on the web), Postmark (transactional email), Telnyx (SMS verification), Cloudflare (content delivery and object storage), and OVH (server hosting). Use of those features is subject to the third party’s terms. We are not responsible for third- party services.

20. Apple-Specific Terms

If you accessed the Service through the Apple App Store, the following also apply, and prevail over any conflicting provisions in these Terms: These Terms are between you and TLC, not Apple. Apple is not responsible for the Service or its content. Your license to use the iOS app is limited to a non-transferable license to use the app on Apple- branded devices you own or control and as permitted by the Apple Media Services Terms. Apple has no obligation to provide maintenance or support for the Service. In the event of any failure of the Service to conform to an applicable warranty, you may notify Apple, and Apple will refund the purchase price; to the maximum extent permitted by law, Apple has no other warranty obligation with respect to the Service. Apple is not responsible for addressing claims by you or third parties relating to the Service or your possession or use of it, including product liability, failure to conform to legal requirements, and claims under consumer protection or similar legislation. If a third party claims the Service or your use of it infringes intellectual property rights, TLC, not Apple, is responsible for the investigation, defense, settlement, and discharge of such claims. You represent that you are not located in a country subject to a U.S. Government embargo or designated as a “terrorist supporting” country and are not on any U.S. Government list of prohibited or restricted parties. Apple and its subsidiaries are third-party beneficiaries of these Terms with respect to your license to use the iOS app, and on accepting these Terms Apple has the right (and is deemed to have accepted the right) to enforce these Terms against you.

21. Google Play-Specific Terms

If you accessed the Service through Google Play, your use of the Android app is also subject to the Google Play Terms of Service.

22. Disclaimer of Warranties

THE SERVICE IS PROVIDED “AS IS” AND “AS AVAILABLE.” TO THE FULLEST EXTENT PERMITTED BY LAW, TLC DISCLAIMS ALL WARRANTIES, EXPRESS, IMPLIED, AND STATUTORY, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE. TLC DOES NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, SECURE, OR FREE OF ERRORS, VIRUSES, OR HARMFUL COMPONENTS.

23. Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY LAW: (a) TLC AND ITS OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS WILL NOT BE LIABLE

FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING LOSS OF DATA, GOODWILL, OR PROFITS, WHETHER ARISING OUT OF CONTRACT, TORT, STATUTE, OR OTHERWISE. (b) TLC’S TOTAL LIABILITY ARISING OUT OF OR RELATED TO THESE TERMS OR THE SERVICE WILL NOT EXCEED THE GREATER OF (i) THE AMOUNT YOU PAID TLC IN THE TWELVE MONTHS PRECEDING THE CLAIM, OR (ii) ONE HUNDRED U.S. DOLLARS. (c) NOTHING IN THESE TERMS LIMITS LIABILITY THAT CANNOT BE LIMITED UNDER APPLICABLE LAW.

24. Indemnification

You agree to indemnify and hold harmless TLC and its officers, directors, employees, and agents from any claim, loss, liability, damage, or expense (including reasonable attorney fees) arising from (a) your User Content, (b) your use of the Service, (c) your breach of these Terms, (d) your violation of any third party’s rights, or (e) any representation regarding your authority as a Guardian.

25. Dispute Resolution and Binding Arbitration

PLEASE READ THIS SECTION CAREFULLY. IT REQUIRES MOST DISPUTES TO BE RESOLVED BY BINDING ARBITRATION AND ON AN INDIVIDUAL (NOT CLASS) BASIS.

a. Informal Resolution. Before filing arbitration, you and TLC agree to attempt informal resolution by contacting [email protected] with a written description of the dispute. The parties will negotiate in good faith for at least 60 days.

b. Binding Arbitration. Any dispute, claim, or controversy arising out of or relating to these Terms or the Service, except as excluded below, will be resolved by binding arbitration administered by the American Arbitration Association under its Consumer Arbitration Rules. The arbitration will be held in Milwaukee, Wisconsin, or by video conference at the claimant’s election. The arbitrator’s award is final and may be entered in any court of competent jurisdiction.

c. Exceptions. Either party may bring (i) small-claims actions in a court of competent jurisdiction or (ii) actions seeking injunctive relief to protect intellectual property rights.

d. Class Action Waiver. YOU AND TLC AGREE THAT EACH MAY BRING CLAIMS AGAINST

THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS PLAINTIFF OR CLASS MEMBER IN A PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. THE ARBITRATOR MAY NOT CONSOLIDATE OR JOIN MORE THAN ONE PERSON’S CLAIMS AND MAY NOT PRESIDE OVER ANY CONSOLIDATED OR CLASS PROCEEDING.

e. 30-Day Right to Opt Out. You may opt out of this Section 25 by sending written notice to [email protected] within 30 days of first accepting these Terms. Notice must include your name, account email, and a clear statement that you opt out of arbitration.

26. Governing Law and Venue

These Terms are governed by the laws of the State of Wisconsin, without regard to its conflict-of-laws principles. Any dispute not subject to arbitration must be brought in the state or federal courts located in Milwaukee County, Wisconsin, and you consent to personal jurisdiction there.

27. Changes to These Terms

We may revise these Terms from time to time. Material changes will be communicated through the Service or by email. Continued use of the Service after the effective date of the revised Terms constitutes acceptance. If you do not accept the revised Terms, you must stop using the Service.

28. General

Entire Agreement. These Terms and the Privacy Policy are the entire agreement between you and TLC regarding the Service. Severability. If any provision is held unenforceable, the remaining provisions remain in effect. No Waiver. Our failure to enforce a provision is not a waiver of our right to do so later. Assignment. You may not assign these Terms without our written consent. We may assign them in connection with a merger, acquisition, or sale of assets. Notices. Notices to you may be sent through the Service or to the email associated with your account. Notices to TLC must be sent to [email protected]. Force Majeure. Neither party is liable for delays or failures due to causes beyond reasonable control, including natural disasters, pandemics, network outages, supply-chain interruptions, or governmental actions. Survival. Sections that by their nature should survive termination will survive, including Sections 9 (License), 22–25 (Disclaimers, Liability, Indemnification, Arbitration), and 26 (Governing Law).

29. Contact

Trusted Life Circle, Inc. 309 N Water St Ste 203 Milwaukee, WI 53202 [email protected]