Terms of Service

1. The agreement

By creating an account or using the Service, you accept these Terms. If you use the Service on behalf of a company or other organization, you confirm that you are authorized to accept these Terms for it, and "you" includes that organization. The Service is for business use by people aged 18 or over. If your organization has a signed order form or master agreement with Graam, that document controls where it conflicts with these Terms.

2. Your account

Give us accurate signup information and keep it current. Accounts are personal: do not share your sign-in or let anyone else use your account. You are responsible for activity under your account. Tell us promptly at [email protected] if you suspect unauthorized access.

3. Your data

"Customer Data" means everything you or your users put into the Service, including loan tapes, documents, deal files, notebooks, queries and prompts, and the outputs generated from them.

You own it

You keep all rights in Customer Data. You grant Graam only the limited right to host, process and display it as needed to provide the Service to you, to keep the Service secure, and to meet legal obligations.

No training

Graam will not use Customer Data to train, fine-tune or otherwise improve any machine learning or AI model, whether ours or a third party's. We will not allow our AI providers to do so either. They process Customer Data under zero-retention terms and may use it only to return results to us.

No sharing or sale

Graam will not sell, rent, license or otherwise disclose Customer Data to any third party. Customer Data is never shown to another customer, and it never informs another customer's results. Graam discloses Customer Data only in three cases:

• to the sub-processors named in our Privacy Policy, solely to operate the Service;
• at your direction, for example when you share a notebook or deal;
• when the law compels it. In that case we will notify you first unless the law forbids notice, and disclose only what is required.

Export and deletion

You can export or delete Customer Data at any time. On deletion or account closure we delete it as described in the Privacy Policy.

4. Content you upload

When you upload material, you confirm that:

• You have the right to use it this way. This covers material licensed from others, such as Intex deal files, rating-agency reports, vendor data dictionaries and trustee reports. It is your responsibility to make sure your license permits loading the material into a third-party analytics service.
• You may lawfully share any personal data it contains. Loan tapes often contain consumers' nonpublic personal information. You are responsible for having a lawful basis to provide it, including under the Gramm-Leach-Bliley Act and your own privacy notices. Upload only the fields your analysis needs.
• It is free of malware and does not infringe anyone's rights.

5. Public and third-party data sources

The Service draws on data published by government agencies, government-sponsored enterprises, public records offices and licensed vendors ("Source Data"). Source Data is owned by, or licensed from, its publisher, and the publisher's own terms govern it. By using the Service you agree to comply with the terms of each source listed below for any Source Data you access, in addition to these Terms. Where a source's terms are stricter than these Terms, the source's terms apply.

† License restricts redistribution. See "Restricted sources" below.

What you may and may not do with Source Data

• Use it inside the Service for your own internal analysis. Graam's analytics, summaries and model outputs built from Source Data are yours to use in your business.
• Restricted sources (†). For these sources you receive Graam's analytics, not a license to the underlying data. You may not extract, export, bulk-download or redistribute their underlying records, or reconstruct those records from outputs, unless you hold your own license from the publisher. Some publishers, including Freddie Mac and Fannie Mae for certain datasets, require a direct agreement before you receive their data in raw form.
• Never re-identify anyone. Do not use Source Data, alone or combined with other data, to identify or contact individual borrowers, applicants or property owners. Agency, HMDA and EDGAR loan-level data are published on the condition that no one tries to.
• Keep attributions. When you publish material that cites Source Data, credit the original publisher as its terms require.

No affiliation; no guarantee

Fannie Mae, Freddie Mac, Ginnie Mae, the SEC, the FFIEC, the Federal Reserve, the EIA and the other publishers above are not affiliated with Graam, and none of them endorses the Service. Their names are used only to identify the data. Source Data is provided as published: it can contain errors, revisions or delays that Graam does not control. Graam may add, change or remove sources at any time. For example, we may remove a source if its publisher changes its terms.

6. Personal data in public records

County recorder and assessor records, HMDA data and some filings contain information about individuals, such as property owners' names. Graam uses these records to match loans to public filings and to analyze collateral. You agree that:

• Graam is not a consumer reporting agency, and the Service is not a consumer report. You will not use the Service, in whole or in part, to decide any individual's eligibility for credit, insurance, employment, housing or any other purpose covered by the Fair Credit Reporting Act.
• You will not use the Service for marketing to, collecting from, or contacting individuals identified in public records.
• You will comply with fair-lending and anti-discrimination laws in how you use any output.

7. AI outputs; no advice; not a rating

The Service uses AI to analyze data, build models and produce forecasts. Outputs may contain errors, inaccuracies or omissions. You are responsible for independently verifying any output before relying on it.

• Nothing in the Service is financial, investment, legal, tax or accounting advice. Graam is not a registered investment adviser or broker-dealer, and it does not recommend any security or transaction.
• Ratings, rating-stress results and credit-enhancement levels the Service produces are model estimates. They are not credit ratings, and Graam is not a nationally recognized statistical rating organization. Where the Service applies a rating agency's published criteria, it is Graam's approximation of them. The agency has not reviewed or endorsed it.
• Do not present Service outputs to investors or regulators as anything other than your own analysis.

8. Acceptable use

You may not:

• scrape, crawl or extract data from the Service by automated means. Programmatic access is allowed only through interfaces Graam provides for it, or with our written permission;
• resell, sublicense or redistribute the Service or its data, except your own Customer Data and outputs as section 5 allows;
• reverse-engineer the Service, probe or bypass its security, access another customer's data, or exceed usage limits;
• use the Service to build a competing product or dataset, or to train AI models on its outputs or Source Data;
• use it for market manipulation, misleading disclosure, or any other unlawful purpose; or
• use it in violation of U.S. export-control or sanctions laws, or from a sanctioned country or by a sanctioned person.

9. Fees

Paid plans are billed as described on our pricing page or in your order form. Fees are non-refundable except where the law or your order form says otherwise, and they exclude taxes. We will give you at least 30 days' notice of a price change before it applies to your next renewal.

10. Graam's property and feedback

Graam owns the Service, including its software, models, recipes, data cards and compiled datasets. Customer Data is excluded. These Terms give you a limited, non-exclusive, non-transferable right to use the Service while your account is active. If you send us suggestions, we may use them freely, without obligation to you. Feedback never includes your Customer Data.

11. Confidentiality

Each party will protect the other's non-public information with at least reasonable care, use it only for purposes of this agreement, and disclose it only to people who need it and are bound by similar duties. Customer Data is always your confidential information. Information that is public, already known, independently developed, or rightfully received from someone else is not confidential.

12. Suspension and termination

You can close your account at any time. We may suspend or close an account that breaches these Terms, is used in a way that threatens the Service or other customers, or that the law requires us to stop serving. Where possible we will warn you first. After closure you have 30 days to export Customer Data. After that we delete it, as described in the Privacy Policy. Sections 3, 5 to 7, 10, 11, and 13 to 18 survive termination.

13. Disclaimers

Except as expressly stated in these Terms, the Service, Source Data and all outputs are provided "as is" and "as available," without warranties of any kind, express or implied. These include merchantability, fitness for a particular purpose, accuracy and non-infringement. Graam does not warrant that the Service will be uninterrupted or error-free.

14. Limitation of liability

To the fullest extent permitted by law, neither party is liable for indirect, incidental, special, consequential or punitive damages, or for lost profits, revenue, trading losses or data, arising from these Terms or the Service. Each party's total liability is limited to the greater of the fees you paid Graam in the 12 months before the claim, or US$100. These limits do not apply to your indemnity obligations, to a party's breach of section 11 (confidentiality), to Graam's breach of section 3 (your data), or to liability that cannot be limited by law.

15. Indemnification

You will defend and indemnify Graam against third-party claims arising from your Customer Data, from your breach of sections 4 through 8, or from your breach of a data source's terms. Graam will defend and indemnify you against third-party claims that the Service, as provided by Graam, infringes their intellectual property.

16. Governing law and disputes

These Terms are governed by the laws of the State of New York, without regard to its conflict-of-laws rules. The state and federal courts in New York County, New York have exclusive jurisdiction, and each party consents to them. Either party may seek an injunction anywhere to protect its confidential information or intellectual property.

17. Changes to these terms

We may update these Terms. For a material change, and in particular any change to section 3, we will email account holders at least 30 days before it takes effect. That gives you time to export your data or close your account. Continuing to use the Service after a change takes effect means you accept it. We will never weaken the commitments in section 3 for data you uploaded before the change.

18. General

These Terms, the Privacy Policy and any order form are the entire agreement on this subject. You may not assign them without our consent. We may assign them to a successor in a merger or sale, and that successor remains bound by section 3. If any provision is unenforceable, the rest still applies. Neither party is liable for delays caused by events beyond its reasonable control. Not enforcing a right is not a waiver of it.

19. Contact

Graam AI, LLC
New York, NY, United States
Questions about these Terms: [email protected]