1. Nature of the Service

MyWacc is a software platform that helps CFOs, founders, and investors structure and visualize financial analyses of their own companies or of companies of interest. The Service:

• Processes financial statements (manual, imported from Excel/PDF, or synced from ERPs authorized by the User).
• Calculates valuations, multiples, sensitivities, and projections from the data provided.
• Exposes findings and metrics; it does not constitute financial, legal, tax, investment, or audit advice. Business or investment decisions the User makes based on the Service are the User's sole responsibility.

Beta phase. The Service is currently in closed testing phase (beta). Its features may change, be suspended, or be discontinued without prior notice; its calculations may contain errors or limitations not yet documented; and we do not guarantee continued availability or persistence of input data, without prejudice to the retention and security commitments described in the Privacy Policy during normal operation of the Service. The User acknowledges and accepts the experimental nature of the Service during this phase.

2. Nature of outputs

The valuations, projections, sensitivities, scores, and other metrics produced by the Service are quantitative estimates based on data provided by the User, public third-party data, and generic model assumptions. Results are highly sensitive to those inputs and assumptions and may differ materially from valuations performed by independent professionals with access to additional information, human judgment, or situation-specific adjustments. No output shall be interpreted as a recommendation.

The "scores", "ratings", or internal grades the Service may display are analytical indicators for the User's internal use and do not constitute a risk classification under Chilean Law No. 18,045 (Securities Market Law), nor do they equate to the opinion of a risk-rating agency.

The User shall not use the Service's outputs as the sole basis for investment, credit, merger, acquisition, hiring, valuation of assets for audited financial reporting, or any decision requiring formal professional advice. We recommend contrasting outputs with independent financial, accounting, tax, or legal advisors before acting on them.

3. User qualification and eligibility

Business / B2B use. The Service is directed exclusively to legal entities and to natural persons contracting in the exercise of their business, commercial, or professional activity. By accepting these Terms, the User represents and warrants that they contract in such capacity and not as a consumer under Chilean Law No. 19,496 on Consumer Rights Protection. The foregoing is without prejudice to non-waivable rights that mandatory law may grant to anyone otherwise classified as a consumer.

Regulated entities. Banks, insurance companies, pension fund administrators (AFP), and other entities supervised by the Chilean Financial Market Commission (Comisión para el Mercado Financiero, CMF) or another sectoral authority may not contract the Service under these standard Terms. Their onboarding requires a separately negotiated specific contract addressing, among other things, audit rights, operational continuity, and confidentiality safeguards consistent with their regulatory regime. MyWacc assumes no obligation under these Terms with respect to such entities.

Capacity. The User must be over 18 years old and have legal capacity to enter into binding obligations, either on their own behalf or on behalf of the legal entity contracting.

4. Account and access

To use the Service the User must register an account with a valid email. The User is responsible for keeping their credentials confidential and for actions taken under their account.

5. Connections with third-party systems (ERPs)

The Service allows connections to third-party accounting systems (QuickBooks Online, Odoo, and others). By authorizing an OAuth connection:

• The User authorizes us to read financial statements, accounts receivable and payable, and related data of the entity they connected.
• We store access tokens only to maintain synchronization; we do not share the User's data with third parties except to process the analysis the User requests and as set forth in the Privacy Policy.
• The User may disconnect access at any time from the provider's dashboard (e.g., in QuickBooks Online) or by contacting support.

6. Processing of personal data and roles of the parties

With respect to personal data of third parties that the User uploads or syncs to the Service (e.g., identification of the User's own customers, suppliers, partners, or employees), the User acts as data Controller and MyWacc as data Processor, processing such data solely in accordance with the User's documented instructions and the provisions of Annex A (Data Processing Terms), which forms part of these Terms.

The User represents that it has a sufficient legal basis (consent of the data subject or another legal ground) to upload or connect such data to the Service, and shall be responsible vis-à-vis data subjects for informing them of the corresponding processing.

7. Acceptable use

The User undertakes not to:

• Connect third-party accounts without authorization of the legal holder of those accounts.
• Upload data that infringes third-party intellectual property or privacy rights, or for which the User lacks a legal basis.
• Attempt to access, reverse-engineer, or disrupt the Service's infrastructure.
• Use the Service for illegal, fraudulent activities or activities that violate applicable regulations.

8. Intellectual property and use of data for model improvement

The Service (including software, design, algorithms, and documentation) is owned by Mywacc SpA. Data uploaded by the User remains the User's property; the Service receives a limited license to process it and display the derived analyses.

Use of data for model improvement. MyWacc may use data derived from use of the Service to improve its proprietary artificial intelligence models, provided that such data is previously irreversibly anonymized —and, where appropriate, aggregated— in accordance with the process described in Section 4-bis of the Privacy Policy. Once irreversibly anonymized, such data ceases to constitute personal data. We do not use the User's identifiable data, nor the names of their company, related parties, or third parties, to train models. The User may opt out of this use as described in the Privacy Policy.

9. Limitation of liability

The Service is offered "as is", without express or implied warranties. To the maximum extent permitted by law:

• We are not liable for business or investment decisions taken based on the Service's outputs.
• We do not guarantee the absolute accuracy of calculations derived from data provided by the User or by connected systems.

Liability cap. MyWacc's total aggregate liability to the User for any claim related to the Service or these Terms, whatever its cause or basis, shall not exceed the lower of: (i) the total amount actually paid by the User to MyWacc during the twelve (12) months preceding the event giving rise to the claim; or (ii) US$500 (five hundred United States Dollars) or its equivalent in Chilean pesos at the time of the claim. Accordingly, with respect to free or trial plans where the User has paid no amount, such maximum liability shall be US$0.

Mandatory exceptions. The foregoing limitations of liability do not apply to damages caused by MyWacc's willful misconduct or gross negligence, nor to those liabilities that, under applicable mandatory law, may not be limited or excluded. These exceptions are also established to preserve the validity of the remainder of this clause.

10. Indemnification by the User

The User shall indemnify and hold harmless MyWacc, its directors, employees, and representatives, against any claim, demand, loss, reasonable defense expense, or judgment arising from:

• Connection of third-party accounts, systems, or data without authorization from the legal holder thereof.
• User's breach of these Terms, of applicable laws, or of third-party rights.
• Fraudulent, illegal, or out-of-scope use of the Service.
• Third-party claims arising from outputs of the Service that the User has communicated to such third parties as a basis for a decision.

11. Changes to the Service and to these Terms

We may modify the Service or these Terms at any time. We will notify active users by email when material changes occur, at least 30 days before they take effect.

If the User does not accept a material change, they may terminate their account without penalty before it takes effect. Continued use of the Service after the change takes effect shall constitute acceptance thereof.

12. Termination

The User may close their account at any time.

MyWacc may suspend or terminate the User's account for the following reasons: (a) material breach of these Terms; (b) illegal, fraudulent, or unauthorized use of the Service; (c) request of a competent authority; or (d) security risk to the Service or to third parties. Except in cases of urgency, illegality, or authority request, MyWacc will give prior notice and a reasonable cure period where possible.

13. Governing law and dispute resolution

These Terms are governed by the laws of the Republic of Chile.

• Users domiciled in Chile: any dispute shall be submitted to the ordinary courts of justice seated in the commune of Santiago.
• Users domiciled outside Chile: any dispute arising from these Terms shall be resolved by arbitration under the Rules of the Center for Arbitration and Mediation of the Santiago Chamber of Commerce (CAM Santiago), seated in Santiago, Chile, in Spanish. The award shall be final and enforceable under the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards.

Nothing herein deprives a User who is classified as a consumer under the mandatory law of their domicile of the non-waivable rights granted by such legislation.

14. General provisions

Severability. If any provision of these Terms is held void, illegal, or unenforceable, the remaining provisions shall remain in full force. The affected provision shall be interpreted or replaced, to the extent possible, by a valid one that most closely reflects its original intent.

Survival. Provisions relating to intellectual property, nature of outputs, limitation of liability, indemnification, data processing (Section 6 and Annex A), and governing law survive termination of the account or contract.

Force majeure. MyWacc shall not be liable for breaches or delays arising from acts of God or force majeure, including failures of infrastructure providers, network outages, third-party cyberattacks, or acts of authority.

Assignment. The User may not assign these Terms without MyWacc's prior written consent. MyWacc may assign them to a successor in the context of a corporate reorganization, merger, or sale of assets, by notifying the User.

Entire agreement. These Terms and the Privacy Policy constitute the entire agreement between the parties regarding the Service and supersede any prior agreement on the same subject matter.

Acceptance and versions. The User accepts these Terms by an affirmative action (ticking a box or clicking accept) upon registration. MyWacc maintains a dated version history; the current version is available at mywacc.com.

15. Contact

For inquiries about these Terms, write to contacto@mywacc.com.

Definitions

For purposes of this Policy and the Terms of Use:

• Personal data: any information relating to an identified or identifiable natural person, directly or indirectly.
• Processing: any operation or set of operations on personal data —collection, storage, use, disclosure, deletion, among others—, whether automated or not.
• Data subject: the natural person to whom the personal data refer.
• Controller: the party who determines the purposes and means of processing.
• Processor: the party who processes personal data on behalf of the Controller and according to its instructions.
• Irreversible anonymization: a procedure that permanently prevents identification or re-identification of the Data Subject; once applied, the information ceases to constitute personal data.

1. Data we collect

1.1 Account data

• Email and name of the User upon registration.
• Company or organization to which they belong.
• Role within the platform (CFO, accountant, investor, etc.).

1.2 Financial data the User uploads or connects

• Financial statements (income statement, balance sheet, cash flow) in CSV/Excel/PDF.
• Operational drivers and projection assumptions (margins, capex, etc.).
• Data synced from authorized ERPs (accounts, invoices, balances, partners).

1.3 Technical data

• IP address, browser, operating system (standard server logs).
• Platform usage events for product analytics, stored in MyWacc's own infrastructure. We do not use third-party tracking services (Google Analytics, Mixpanel, PostHog, or equivalents).

2. Legal bases, purposes, and roles

We process data for the following purposes, on the legal bases indicated:

• Operating the Service (contract performance): computing valuations, displaying reports, and syncing with authorized ERPs.
• ERP sync (contract performance and consent): only when the User expressly authorizes the connection.
• Improving the platform (legitimate interest): aggregated and anonymous statistics on feature usage.
• Training proprietary models: we use data derived from use of the Service after irreversible anonymization (a state in which they cease to be personal data), in accordance with Section 4-bis. The User has a right to object (opt-out) as described in that section.
• Support (contract performance / legitimate interest): answering inquiries and resolving reported issues.
• Compliance with legal obligations (legal obligation): when applicable law so requires.

Roles. With respect to personal data of third parties uploaded or synced by the User, the User acts as data Controller and MyWacc as Processor, in accordance with Annex A of the Terms of Use.

We do not sell User data. We do not use one client's financial data for the benefit of another.

3. Where data are stored

User data are stored on Amazon Web Services infrastructure, US East (Virginia) region. This includes:

• PostgreSQL database (RDS) — transactional and user data.
• S3 — uploaded files (PDFs, Excels).
• EC2 — compute servers.

OAuth tokens for connected ERPs are stored encrypted.

International transfer. Since processing occurs in the United States, MyWacc implements contractual safeguards with its providers (including data-protection commitments and, where applicable, standard contractual clauses) and technical safeguards (encryption in transit and at rest). For EU/EEA residents, such transfers are supported by the mechanisms provided by the GDPR for international transfers (e.g., the European Commission's standard contractual clauses). As Chilean Law No. 21,719 enters into force, international transfers will be aligned with the regime established by that law. By using the Service, the User acknowledges that their data will be processed on infrastructure located in the United States.

4. Third-party processing (subprocessors)

MyWacc uses the following third-party services as subprocessors to operate the platform:

Changes to the subprocessor list. MyWacc shall give at least 15 days' prior notice of any addition or change of subprocessor that processes User data; the User may object within that period for substantiated data-protection reasons.

Own analytics. Platform usage events for product analytics (mentioned in Section 1.3) are stored on MyWacc's own infrastructure. We do not use external tracking services (Google Analytics, Mixpanel, PostHog, Segment, or equivalents) for those events.

4.1 Expert mode of the chat (opt-in / inference)

The "Expert mode" of the chat is opt-in and sends to external providers (Mistral AI / Anthropic Claude) a structured summary of the active valuation to perform advanced analysis —not the original client documents—, only when the User explicitly activates it. This channel corresponds to inference and is distinct from the model training described in Section 4-bis.

What the summary includes and excludes. The structured summary does not include the User's email or name, the company tax ID (RUT or equivalent), nor names of customers, suppliers, shareholders, or other counterparties. It may include country, industry (Damodaran classification), relative size, and financial metrics and assumptions of the active valuation (revenue, margins, drivers, WACC, EV, multiples, comparables, etc.). If this is not acceptable to your organization, keep Expert mode disabled — the chat by default uses our self-hosted LLM.

4-bis. Anonymization of data for model training

Legal consequence. When we use data derived from use of the Service to train our artificial intelligence models, we previously apply an irreversible anonymization process. Once anonymized in this way, the data ceases to constitute personal data and falls outside the scope of data-protection legislation; training is performed solely on data in that state.

The process specifically includes:

• Removal of direct identifiers: the User's name and email, internal user ID, the company's name and tax ID (RUT or equivalent), stock ticker if applicable, specific location.
• Removal of related-party identifiers: names of customers, suppliers, shareholders, and other counterparties that the User has uploaded or synced.
• Preservation of structure only: data entering the model consists of financial ratios, distributions, time series, and structural patterns.

Methodology and risk threshold. MyWacc applies a documented anonymization methodology designed to reduce the risk of re-identification to an insignificant level, expressly considering the risk of singularization by combination of attributes (e.g., financial trajectories of companies in small markets). The methodology is reviewed periodically.

Governance. Anonymization occurs on MyWacc's internal infrastructure and is validated internally before data enters the training pipeline, under the responsibility of the Data Protection Officer. Identifiable data are not exported to the training dataset through controls designed to prevent this; training may run on cloud infrastructure different from production, receiving only already-anonymized data.

Model safeguards. The resulting models are designed with safeguards intended to minimize memorization or retrieval of individual records from the training set.

Opt-out. If the User prefers that no data derived from their use, even anonymized, be used for training, they may opt out by writing to contacto@mywacc.com. Opt-out applies from the date of request going forward; data already anonymized and integrated into the model cannot be reverted, but will not be associable with the User's account.

5. Retention

• Account data: while the account is active and up to 90 days after closure.
• Inactive accounts: accounts without activity for 24 months will be notified to the registered email and, if not reactivated within 30 days, will be deleted together with their associated data.
• Uploaded financial data: under the User's control; deleted when the analysis is deleted or the account is closed.
• OAuth tokens: until the User revokes them or they expire.
• Technical logs: 30 days.

6. Rights of the User and of data subjects

We comply with Chilean Law No. 19,628 and, as of its entry into force, with Chilean Law No. 21,719. For EU/EEA residents, GDPR rights additionally apply. The User and data subjects may at any time:

• Access the data associated with their account.
• Request rectification of inaccurate data.
• Request cancellation or deletion of their data ("right to be forgotten").
• Object to processing and request its restriction.
• Export their data in a structured format (portability).
• Not be subject to decisions based solely on automated processing with significant effects, without human intervention.
• Revoke access to connected systems.

Complaint to authority. The User may file complaints with the Chilean Personal Data Protection Agency (once operational) and, if resident in the EU/EEA, with the supervisory authority of their jurisdiction. To exercise any of these rights, write to contacto@mywacc.com; we will respond within applicable legal deadlines.

7. Security

• Communications encrypted in transit (HTTPS / TLS 1.2+).
• Sensitive data encrypted at rest (AWS KMS).
• Access to production infrastructure restricted by IAM and MFA.
• ERP tokens encrypted before storage.

No system is perfectly secure. In the event of a security incident affecting personal data of the User, we will notify affected users and, where applicable, the competent data protection authority, without undue delay and, at the latest, within applicable legal deadlines (which under Chilean Law No. 21,719 and the GDPR is generally within 72 hours of becoming aware of the breach), including the nature of the incident, the data affected, the measures taken, and recommendations for the User.

8. Cookies

We use strictly technical cookies (user session, language preference). We do not use advertising tracking cookies.

9. Minors

The Service is not directed to minors under 18 years of age. If we detect an account of a minor, we close it.

10. Data governance: DPO, register, and impact assessments

• Data Protection Officer (DPO). MyWacc designates a Data Protection Officer as point of contact for data subjects and authorities, reachable at contacto@mywacc.com.
• Record of processing activities. MyWacc maintains a dated record of its processing activities, in accordance with Chilean Law No. 21,719.
• Impact assessments (DPIA). High-risk processing —in particular the use of data for training AI models— is subject to prior data-protection impact assessment and periodic review.

11. Changes to this policy

We will notify by email of material changes at least 30 days in advance.

12. Contact

Any inquiry about this policy: contacto@mywacc.com.