Terms and Conditions of Use

Effective Date: 22 April 2026

These Terms and Conditions of Use ("Terms") govern your access to and use of the Columns insurance policy aggregation and analysis platform (the "Platform"), operated by Columns Pte. Ltd. ("Columns," "we," "us," "our"), a company incorporated in the Republic of Singapore.

By accessing or using the Platform, you agree to be bound by these Terms and our Privacy Policy. If you are entering into these Terms on behalf of a company or other legal entity, you represent that you have the authority to bind that entity to these Terms, and references to "you" or "Client" refer to that entity. If you do not agree to these Terms, you must not access or use the Platform.

1. Definitions

"Authorised User"

means any individual granted access to the Platform by a Client.

"Client Data"

means all data, documents, and information uploaded to or processed through the Platform by or on behalf of a Client, including insurance policy documents, Meeting Recordings, Meeting Data, and any personal data contained therein.

"AI Features"

means the artificial intelligence-powered analysis, aggregation, gap identification, coverage review, and meeting assistant tools available within the Platform.

"Meeting Recording"

means any audio (and, where applicable, video) captured by the Platform's meeting assistant feature.

"Meeting Data"

means transcripts, AI-generated notes, summaries, and other derived outputs produced from a Meeting Recording.

"Subscription Period"

means the period during which the Client has an active, paid subscription to the Platform.

2. The Platform

2.1 Licence

Subject to compliance with these Terms and payment of applicable fees, Columns grants the Client a non-exclusive, non-transferable, revocable licence to access and use the Platform during the Subscription Period for the Client's internal business purposes, specifically for the management, aggregation, and analysis of insurance policy portfolios and for use of the meeting assistant feature in client-advisory workflows.

The Client may permit its Authorised Users to access the Platform, provided that the Client remains responsible for their compliance with these Terms. The licence does not permit the Client to sublicence, resell, distribute, or make the Platform available to any third party outside of its organisation.

2.2 Availability

We aim to make the Platform available at all times, but we do not guarantee uninterrupted access. We may suspend or restrict access to the Platform for scheduled maintenance, emergency repairs, security incidents, or circumstances beyond our reasonable control.

2.3 Updates

We may update, modify, or discontinue features of the Platform from time to time. Where a change materially reduces the functionality available to the Client under their current subscription, we will provide reasonable advance notice.

3. Client Obligations

The Client agrees to:

• Ensure that all Authorised Users comply with these Terms and use the Platform in accordance with all applicable laws and regulations.
• Maintain the confidentiality of all account credentials and promptly notify Columns of any unauthorised access to or use of its account.
• Ensure that all data uploaded to the Platform has been collected lawfully and is shared in compliance with applicable data protection laws, including the PDPA.
• Obtain all necessary consents from data subjects, including policyholders and beneficiaries, before uploading their personal data to the Platform.
• Not use the Platform for any purpose that is unlawful, fraudulent, or not authorised by these Terms.
• Not attempt to gain unauthorised access to any systems, networks, or data associated with the Platform.
• Not reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code of any part of the Platform.
• Not upload any content that contains malware, viruses, or any other harmful code.

4. Meeting Assistant Feature

4.1 Activation and Client Responsibility for Consent

The Platform's meeting assistant feature captures Meeting Recordings and generates Meeting Data when activated by an Authorised User. The feature is activated manually by the Client and is not used by default.

The Client is solely responsible for: (a) obtaining valid informed consent from all meeting participants prior to activating the feature, including consent to the recording, transcription, and processing of the meeting by Columns; (b) providing meeting participants with any notices required under the PDPA or other applicable laws; and (c) ensuring that use of the feature complies with all applicable confidentiality, professional conduct, fiduciary, and regulatory obligations applicable to the Client's business.

Columns does not independently verify participant consent. The Client indemnifies Columns against any claim arising from the Client's failure to obtain required consents or to comply with this Section 4.1.

4.2 Ownership and Use of Meeting Data

Meeting Recordings and Meeting Data constitute Client Data and are owned by the Client, subject to the limited processing rights granted to Columns under these Terms.

5. Data Ownership and Processing

5.1 Client Data Ownership

The Client retains all ownership rights in Client Data at all times. Nothing in these Terms transfers ownership of Client Data to Columns.

5.2 Limited Processing Rights

The Client grants Columns a limited, non-exclusive licence to process Client Data solely for the purpose of providing the Platform services, including AI-powered analysis and meeting transcription, and, subject to Section 6, for improving Columns' models and services. We will not use Client Data for any purpose other than those described in these Terms and our Privacy Policy.

5.3 Data Protection

The processing of personal data through the Platform is governed by our Privacy Policy and, where applicable, a separate data processing agreement negotiated between the parties. In the event of any conflict between these Terms and any such data processing agreement on matters relating to data protection, the data processing agreement shall prevail.

5.4 Data Portability and Export

The Client may export its data from the Platform at any time during the Subscription Period.

6. Use of Data to Improve Columns' Models and Services

6.1 Columns reserves the right to use de-identified and aggregated data derived from Client Data to improve the accuracy, performance, and functionality of Columns' proprietary models and services, including the AI Features.

6.2 Limitations. Any use of data for the purpose described in Section 6.1 is subject to the following limitations:

• Data is de-identified and aggregated before use. Direct identifiers are removed or masked.
• Raw Meeting Recordings (audio files) are not used for model training or improvement.
• Sensitive categories of personal data (including health, medical, and data relating to minors) are excluded.
• De-identified data used for improvement is not shared with third-party AI providers for their own training purposes.
• Improvement activities are conducted solely for the purpose of improving the Platform and related services.

6.3 Opt-Out. The Client may opt out of the use of its data for the purpose described in Section 6.1 at any time, at no cost, by (a) adjusting the relevant setting in the Platform's administrative console, or (b) contacting Columns' Data Protection Officer. Opt-out takes effect prospectively and applies to all of the Client's Authorised Users and to all Client Data uploaded or generated after the opt-out takes effect. We will give effect to opt-out requests within 14 days of receipt. Opting out does not affect the Client's access to or use of the Platform.

6.4 Third-Party AI Providers. Separately from Section 6.1, our third-party AI providers (currently Google Gemini, with Anthropic Claude under evaluation) are contractually prohibited from using Client Data to train, fine-tune, or improve their own models.

7. AI Features

7.1 Nature of AI Output

The AI Features are designed to assist licensed financial advisors by organising, analysing, and identifying potential gaps in insurance policy portfolios, and by generating transcripts and notes from meetings. The AI Features do not constitute financial advice, insurance advice, or any form of regulated advice. All AI output is intended as a decision-support tool for use by qualified professionals.

7.2 Accuracy and Limitations

AI-generated output (including transcripts, notes, summaries, and gap analyses) may contain errors, omissions, or inaccuracies. Columns does not warrant the accuracy, completeness, or reliability of any AI-generated content. The Client must independently verify all AI output before relying on it or communicating it to end clients.

8. Fees and Payment

The Client shall pay all fees as set out in the applicable order form, subscription agreement, or invoice issued by Columns. All fees are quoted in the currency specified in the applicable order form and are exclusive of applicable taxes unless stated otherwise. Fees are payable in advance on a monthly or annual basis unless otherwise agreed. If any payment is overdue by more than 14 days, Columns reserves the right to suspend access to the Platform upon 7 days' written notice.

9. Intellectual Property

All intellectual property rights in the Platform, including its software, algorithms, user interface, documentation, and branding, are and remain the exclusive property of Columns or its licensors. These Terms do not grant the Client any rights in the Platform other than the limited licence described in Section 2.1.

10. Confidentiality

Each party agrees to keep confidential any proprietary or confidential information disclosed by the other party in connection with these Terms. Confidential Information includes, without limitation, Client Data (including Meeting Recordings and Meeting Data), business plans, pricing, and technical specifications.

The receiving party shall use Confidential Information only for the purposes contemplated by these Terms and shall not disclose it to any third party without the disclosing party's prior written consent, except to employees, contractors, or advisors who need to know and are bound by obligations of confidentiality at least as protective as those in these Terms.

11. Warranties and Disclaimers

11.1 Columns Warranties

Columns warrants that it will provide the Platform with reasonable care and skill and in accordance with these Terms and its Privacy Policy. Columns further warrants that it will implement commercially reasonable security measures to protect Client Data.

11.2 Disclaimers

Except as expressly stated in these Terms, the Platform is provided "as is" and "as available." To the maximum extent permitted by applicable law, Columns disclaims all other warranties, whether express, implied, or statutory, including but not limited to implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

12. Limitation of Liability

12.1 To the maximum extent permitted by applicable law, Columns' total aggregate liability to the Client under or in connection with these Terms shall not exceed the total fees paid by the Client to Columns during the 12-month period immediately preceding the event giving rise to the claim.

12.2 In no event shall Columns be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits, revenue, data, business opportunity, or goodwill.

12.3 Nothing in these Terms excludes or limits liability for death or personal injury caused by negligence, fraud, or any other liability that cannot be excluded or limited under applicable law.

13. Indemnification

The Client agrees to indemnify and hold harmless Columns, its directors, officers, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or in connection with: (a) the Client's breach of these Terms; (b) the Client's use of the Platform in a manner not authorised by these Terms; (c) the Client's failure to obtain necessary consents from data subjects (including meeting participants) before uploading or recording their personal data; or (d) any third-party claim arising from the Client's use of the Platform.

14. Term and Termination

14.1 Term

These Terms commence on the date the Client first accesses the Platform and continue for the duration of the Subscription Period, renewing automatically for successive periods of the same length unless either party provides written notice of non-renewal at least 30 days before the end of the then-current period.

14.2 Termination for Convenience

Either party may terminate these Terms by providing 30 days' written notice to the other party.

14.3 Termination for Cause

Either party may terminate these Terms immediately upon written notice if the other party materially breaches these Terms and fails to remedy such breach within 14 days of receiving written notice, or becomes insolvent.

14.4 Effect of Termination

Upon termination, the Client's access to the Platform will be revoked. The Client may request an export of Client Data prior to the effective date of termination. Columns will delete all Client Data within 30 days of termination, unless retention is required by law.

15. Suspension

Columns may suspend the Client's access to the Platform, in whole or in part, without prior notice if the Client's use of the Platform poses a security risk, the Client is in material breach of these Terms, Columns is required to do so by law, or fees remain overdue. Columns will restore access promptly once the cause for suspension has been resolved.

16. Amendments

Columns may amend these Terms from time to time. We will notify the Client of material changes by email or through a notice on the Platform at least 30 days before the changes take effect. If the Client does not agree to the amended Terms, the Client may terminate these Terms by providing written notice before the effective date of the changes.

17. Governing Law and Dispute Resolution

These Terms are governed by and construed in accordance with the laws of the Republic of Singapore. Any dispute arising out of or in connection with these Terms shall first be referred to mediation administered by the Singapore Mediation Centre. If the dispute is not resolved within 30 days of the commencement of mediation, it shall be submitted to the exclusive jurisdiction of the courts of Singapore.

18. General Provisions

18.1 Entire Agreement

These Terms, together with the Privacy Policy and any applicable order form, services agreement, or data processing agreement, constitute the entire agreement between the parties with respect to the subject matter hereof.

18.2 Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect.

18.3 Waiver

No failure or delay by either party in exercising any right under these Terms shall operate as a waiver of that right.

18.4 Assignment

The Client may not assign or transfer its rights or obligations under these Terms without the prior written consent of Columns. Columns may assign its rights and obligations to an affiliate or in connection with a merger, acquisition, or sale of all or substantially all of its assets.

18.5 Notices

All notices under these Terms shall be in writing and shall be deemed given when delivered by email to the addresses specified in the applicable order form or subscription agreement.

18.6 Force Majeure

Neither party shall be liable for any failure or delay in performing its obligations under these Terms to the extent that such failure or delay is caused by circumstances beyond its reasonable control.

19. Contact

For questions about these Terms, please contact: