Terms & Conditions

Cultioo Business App

United States

Terms of Service (TOS)

Cultioo Business App — Seller Side

Effective Date: January 1, 2026

Last Updated: January 1, 2026

Version: 1.0

Governing Entity: Cultioo Inc., a Delaware Corporation

IMPORTANT NOTICE: These Terms of Service contain provisions that limit our liability, include a binding arbitration agreement, and waive your right to participate in class action lawsuits. Please read these carefully before using the platform.

Table of Contents

1. General Provisions and Contract Formation

2. Account Management and Seller Obligations

3. Product Listing and Seller Responsibility

4. Payment Processing and Financial Terms

5. Logistics, Product Pickup, and Risk Transfer

6. Tax Obligations and Compliance

7. Insurance and Risk Management

8. Claims and Refunds

9. Indemnification and Limitation of Liability

10. Privacy and Security

11. Intellectual Property

12. Termination of Use

13. Dispute Resolution and Arbitration

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14. Governing Law

15. Severability Clause

16. Amendments to the TOS

17. Contact Information

18. Confirmation and Consent

1. General Provisions and Contract Formation

1.1 Acceptance of Terms and Scope of Application

By accessing, using, or registering a seller account on the Cultioo Business App (the "App" or "Platform"), you ("Seller," "you," or "your") fully, irrevocably, and unconditionally accept these Terms of Service (the "TOS"), the Cultioo Business Privacy Policy, and the terms of our external payment service provider Stripe, Inc. ("Stripe Terms").

Your consent is provided through a clickwrap procedure: Before activating your seller account or conducting your first transaction, you must actively click a checkbox or press a button confirming your acknowledgment and acceptance of these TOS. This procedure ensures the legal enforceability of these TOS, including the arbitration agreement in Section 13. IMPORTANT NOTICE: These TOS contain provisions that limit our liability, include a binding arbitration agreement, and waive your right to participate in class action lawsuits. Please read these carefully.

1.2 Cultioo's Role as Technology Intermediary

Cultioo functions exclusively as a technology platform for listing, discovering, and facilitating transactions between sellers and buyers. Cultioo is NOT:

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• A reseller, agent, broker, or manufacturer of your products
• A contracting party to the purchase agreement between you and the buyer
• Responsible for the execution, fulfillment, or enforcement of purchase contracts
• A "Merchant of Record" for your transactions

You as the seller are the "Seller of Record" and solely responsible for all aspects of the sale, including product quality, legality, warranties, and customer service.

Cultioo expressly disclaims any responsibility or liability for the fulfillment of purchase contracts, compliance with applicable laws by sellers, or disputes arising from direct transactions between users.

1.3 Platform Description

The Cultioo Business App is the dedicated seller and operations suite of the Cultioo ecosystem. It serves three distinct user roles within the same application:

Role Access Level Core Responsibilities

Admin (Group

Founder)

Member (Sales

& Inventory)

Operator

(Gatekeeper)

Full dashboard —

revenue, invoices, group

configuration, Order

Approval Protocol

Listing management,

inventory, order

processing

Scanner interface only —

no financial or admin

data

All revenue from group members

consolidated to the Admin's verified

account. Authority to download all

invoices and financial reports.

Creating product listings, managing

inventory, processing seller orders.

Financial settlement governed by

Admin configuration.

Gate verification via Cultioo Scanner

App: driver identity verification, cargo

inspection, QR handshake.

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These TOS apply to all roles operating under the Seller Side of the Cultioo Business App. The Delvioo™ Driver Portal is governed by separate terms.

1.4 Geographic Scope — United States of America

These TOS apply exclusively to sellers who:

• Are resident or conduct business in the United States of America
• Sell products through the Cultioo platform to buyers in the USA
• Comply with all applicable U.S. federal and state laws

2. Account Management and Seller Obligations

2.1 Registration and Verification

a) Registration Requirements

You must provide true, current, and complete information during registration.

For Individuals:

• Full legal name
• Social Security Number (SSN)
• Residential address
• Email address and phone number
• Bank account information for payouts

For Businesses:

• Legal business name
• Employer Identification Number (EIN)
• Business address
• Name of authorized representative

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• Business bank account information

Business Portal Upgrade: The Business Portal is an upgrade layer on top of a standard Cultioo User Account. In addition to the above, sellers must also provide:

Field Description

Company Name Legal registered business name

Official Website Company web presence

Professional Description Concise description of the business and product range

Corporate Profile Picture

/ Logo Operational Scale Security Verification Visual identity for the seller profile Declaration of workforce size (employee count)

Mandatory 8-digit email verification code to finalize

the Business Upgrade

b) Verification and KYC/AML

You are required to undergo the verification process through Stripe Connect. This process includes:

• Know Your Customer (KYC) Verification: Identity verification through submission of a government-issued photo ID
• Anti-Money Laundering (AML) Checks: Screening against sanctions lists and terrorism databases
• Business Verification: Proof of business legitimacy (for businesses) Verification is required to publish listings, receive payouts, protect the platform from fraud, and comply with financial regulations. Browsing and group hierarchy setup are available without completed verification; all commercial activity requires it.

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Cultioo reserves the right to request additional documentation or deny verification if the information provided is incomplete or suspicious. c) INFORM Consumers Act Compliance

If you become a High-Volume Seller (200+ transactions AND $5,000+ gross revenues in any 12-month period), you are required to:

• Provide additional business information
• Consent to disclosure of your identity and contact details to buyers
• Submit to annual verification of your information

This serves consumer protection pursuant to the INFORM Consumers Act (15 U.S.C. § 45f). See Section 2.1(d) and the Business Privacy Policy for full details.

d) Seller Groups — Three-Tier Role System

The Cultioo Business App supports organizational hierarchy for industrial facilities, warehouses, and large-scale merchant operations. Each seller account is restricted to one active group membership at any given time. Role Financial Authority Data Access

Admin (Group

Founder)

All member revenues consolidated to

Admin's verified Stripe account. Full access

to invoices and financial reports. Configures

Order Approval Protocol.

Full dashboard

Member (Sales

& Inventory)

Financial settlement governed by Admin

configuration.

Operator

(Gatekeeper) No financial access.

Listing and order

management

Scanner interface

only

Order Approval Protocol: Group Founders may activate an Order Approval Protocol under which all orders placed by group members are held in a Terms & Conditions

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pending state until the Founder or an authorized Group Host explicitly approves them.

2.2 Data Integrity and Updates

You are solely responsible for:

• The accuracy and currency of your account information
• Immediate updates upon changes (address, bank details, business structure)
• The security and confidentiality of your login credentials and passwords
• All activities conducted under your account

False or outdated information can lead to:

• Delays in payouts
• Account suspension
• Tax and legal consequences
• Termination of your seller agreement

2.3 Suspension and Termination by Cultioo

Cultioo reserves the right to suspend, restrict, or terminate your account at any time and at its sole discretion, particularly in cases of:

• Violation of these TOS, the Privacy Policy, or the Stripe Terms
• Non-compliance with verification requirements
• Suspicion of fraud, money laundering, or illegal activities
• Repeated customer complaints about product quality or service
• Sale of prohibited or restricted products
• Manipulation of reviews or abusive behavior
• Non-payment of fees, commissions, or chargebacks
• Violations of tax laws or licensing requirements

Account termination may occur without prior notice. In the event of suspension or termination:

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• Outstanding payouts will be withheld until all open claims are resolved
• You lose access to all account data and transaction histories
• You have no entitlement to refund of fees paid
• You remain liable for all obligations incurred before termination

3. Product Listing and Seller Responsibility

3.1 Sole Product Responsibility

You as the seller bear SOLE AND EXCLUSIVE responsibility for: a) Product Quality and Safety

• All products you list and sell must be safe, merchantable, and free from defects
• Products must comply with applicable federal laws (FDA, USDA, CPSC) and state regulations
• You are liable for all product recalls, safety warnings, or regulatory actions b) Product Information and Descriptions

All product descriptions, images, prices, and specifications must be truthful, complete, and not misleading. You must disclose all material information including:

• Complete ingredient list
• Allergens (nuts, gluten, dairy, etc.)
• Expiration date / best-by date
• Weight / quantity / serving size
• Country of origin
• Storage instructions

False or misleading information can lead to customer complaints, refunds, and legal consequences.

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c) Legality and Compliance

You warrant that all your products are legally acquired, manufactured, and permitted to be sold. You possess all required licenses, permits, and certificates including Food Handler's Permit, Cottage Food License (if applicable), agricultural certifications (Organic, etc.), and liquor license (if applicable). You do not sell prohibited or restricted products. d) Storage and Handling

You are responsible for proper storage, especially for perishable products:

• Compliance with cold chain for temperature-sensitive products
• Hygienic storage conditions
• Prevention of contamination or spoilage
• Products must be properly packaged and ready for shipment until pickup

3.2 Product Listing — Mandatory 6-Page Workflow

All listings on the Cultioo platform must pass through a structured 6-page publishing workflow. Sellers are required to provide accurate and complete data across all fields before a product enters the live marketplace: Page Category Required Data

Product Title, Subtitle, Category classification for search

General

indexing, comprehensive Description covering unique

Information

selling points and technical specifications

Visual

Evidence

Commercial

Terms

Up to 5 high-resolution photographs — primary visual

verification for buyers

Unit Price, Unit of Measure (Metric Tons, Liters, Pallets),

Supply Logic (Always Available vs. Fixed Stock), Minimum

Order Quantity (MOQ)

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Page Category Required Data

Standardized Nutritional Data (per 100g / per serving),

4 Regulatory

Compliance

Origin, Organic Status, Bio Control Numbers, Ingredients,

Allergens, and Terpenes for regulated industries

Incoterms (EXW / FCA / DDP), required Vehicle/Wagon Type

(Refrigerated, Grain Hopper, Tanker), Cleaning Certificate

5 Transport

Matrix

toggle, Temperature Requirements, Special Handling, Pickup

Location and Delivery Area — addresses auto-convert to

GPS coordinates

6 Final Audit Full data review before deployment as Draft (staging) or live publication

Listings may be edited in real time without deactivation. All updates must maintain full accuracy. Listings may be saved as Drafts in the staging area and published when ready. The platform supports two inventory states:

• Online (Active): Goods currently live on the global marketplace — visible to all potential buyers
• Draft (Staging): Secure staging area for listings awaiting final scan data, administrative approval, or commercial review

3.3 Warranty Disclaimer Toward Cultioo

CULTIOO MAKES NO EXPRESS OR IMPLIED WARRANTIES OR GUARANTEES

REGARDING PRODUCTS LISTED ON THE PLATFORM.

PRODUCTS ARE SOLD BY THE SELLER TO THE BUYER ON AN "AS-IS" BASIS. Liability for product quality, conformity with description, fitness for a particular purpose, and accuracy of product information lies SOLELY AND EXCLUSIVELY with the seller, NOT with Cultioo.

This comprehensive warranty disclaimer means Cultioo does not verify the quality, safety, or legality of your products, does not guarantee the Terms & Conditions

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accuracy of your product descriptions, and is not liable for product defects, injuries, or damages.

3.4 Prohibited and Restricted Products

You may NOT sell the following products on the Cultioo platform: Absolutely Prohibited:

• Illegal drugs, narcotics, or controlled substances
• Weapons, ammunition, or explosives
• Counterfeit or stolen products
• Products that violate third-party intellectual property rights
• Tobacco products
• Live animals (except licensed livestock with permits)
• Prescription medications
• Hazardous or toxic substances
• Pornographic or offensive materials
• Humans, body parts, or bodily fluids

Restricted (only with approval/license):

• Alcoholic beverages (requires liquor license)
• Cannabis/CBD products (only in licensed states)
• Raw milk products (depending on state law)
• Wild game and game meat (requires USDA inspection)
• Dietary supplements with medical claims

Cultioo reserves the right to remove product listings without notice if they violate our policies.

3.5 Pricing and Changes

You have full control over pricing of your products, discounts and special offers, and availability and inventory management.

You commit to:

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• Setting fair and competitive prices
• Not engaging in price manipulation or price gouging
• Updating price changes promptly in the app
• Not offering misleading discounts or "fake sales"

4. Payment Processing and Financial Terms

4.1 External Payment Service Provider (Stripe Connect)

All payment processing on the Cultioo Business App — including collection of the purchase price, deduction of commissions, and payout to you — is conducted exclusively through our external service provider Stripe, Inc. (Stripe Connect).

BY USING THE PAYMENT FUNCTION, YOU AUTOMATICALLY AGREE TO THE STRIPE TERMS (STRIPE CONNECTED ACCOUNT AGREEMENT), which are

hereby incorporated by reference into these TOS.

Stripe Terms available at: https://stripe.com/legal/connect-account You are expressly informed that the Stripe Terms may contain potentially onerous clauses, and you are obligated to review them carefully. CULTIOO ASSUMES NO LIABILITY for failures, delays, errors, or decisions by Stripe or associated financial service providers, unless they result from gross negligence or willful misconduct by Cultioo.

4.2 Commissions and Fees

Cultioo reserves the right to charge commissions and service fees on your transactions.

Current Fee Structure:

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Sales

Commission

Fee Amount Charged To

5% of gross sales price

Seller — automatically deducted

(before taxes)

from each transaction

Payment

Processing Fee

Typically 2.9% + $0.30

per transaction Instant Payout

Fee 1.5% processing fee

According to Stripe fees

Seller — for on-demand manual

payout (minimum $10 balance)

A detailed breakdown of all deductions is available in your seller dashboard. Commissions already paid out are not refunded in case of subsequent refunds.

Fee Changes: Cultioo reserves the right to change the fee structure with 30 days' notice. Continued use after changes means acceptance of the new fees.

4.3 Payouts

Payout Schedule:

You may configure your payout schedule as follows:

Daily Weekly Schedule Description

Maximum liquidity — optimized for high-volume operations

requiring continuous cash flow

Standard business operations and mid-size merchant

workflows

Monthly Manual (On-

Demand)

Consolidated monthly reporting and accounting

reconciliation cycles

Minimum $10 balance required — 1.5% processing fee applies

for instant transfer

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Payout Method: Payouts are made via ACH transfer (Automated Clearing House) to your verified U.S. bank account at a licensed bank or credit union. Payment rails also include SEPA (Europe) and Wire (United States) — all secured via Stripe's encrypted infrastructure.

Payout Statements: You receive detailed payout statements through the Stripe Dashboard. These serve as the basis for your tax return. Payment Release Mechanism: Payment to you as the seller is not released until the buyer explicitly confirms receipt of the goods within the Cultioo App. This escrow mechanism protects both parties: you from non-payment after dispatch, and the buyer from premature payment release. Depending on the applicable Incoterms: If you are the seller under DDP terms, the Delvioo™ transport cost may be automatically deducted from your account — no manual payment required.

4.4 Chargebacks, Disputes, and Refunds

a) Chargebacks

If a buyer initiates a chargeback through their bank or credit card company (e.g., for non-receipt of goods, unauthorized transaction, defective goods), YOU as the seller are liable for:

• The full transaction amount
• Chargeback fees (typically $15–$25 per case)
• All associated costs

Cultioo/Stripe will deduct the amount from your seller account or withhold it from future payouts.

Your Defense Rights: You have the right to submit evidence to defend against unjustified chargebacks including:

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• Proof of delivery (Delvioo™ confirmation — QR scan timestamps, digital signatures, weight records, and dispatch photographs)
• Communication with the buyer
• Product photos and documentation captured during the gate verification process

Stripe forwards your defense to the card company.

Repeated Chargebacks: A high chargeback rate (>1% of transactions) can lead to account suspension, increased fees, payout delays, and termination of your seller account.

b) Disputes and Complaints

Buyers can report disputes through the Cultioo platform (e.g., wrong items, damaged goods, missing items).

Your Obligations:

• Respond to disputes within 48 hours
• Negotiate in good faith with the buyer
• Offer reasonable solutions (replacement, partial refund, etc.) Cultioo may, at its sole discretion:
• Enforce refunds in favor of the buyer
• Withhold amounts from your account
• Suspend your account for repeated violations

4.5 Authorization of Bank Data

You expressly consent that Stripe may process your bank data for:

• Compliance Purposes: Compliance with Bank Secrecy Act (BSA) and Anti- Money Laundering (AML) regulations
• KYC Verification: Identity verification and risk assessment
• Payout Processing: ACH transfers to your account

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• Recoveries: Deduction of chargebacks, fees, or negative balances This authorization enables Stripe to obtain necessary information about you and your business from third-party providers (credit bureaus, databases).

5. Logistics, Product Pickup, and Risk Transfer

5.1 Pickup Readiness and Packaging

You are obligated to:

Make products pickup-ready:

• Products must be fully packaged, labeled, and ready for shipment at the agreed pickup time
• Perishable products must be appropriately refrigerated/insulated
• Fragile products must be properly protected

Provide precise pickup location:

• You must specify a precise pickup location in the Transport Matrix of each product listing — addresses are automatically converted to GPS coordinates
• The pickup location must be accessible to the Delvioo™ Driver
• You or an authorized representative (Operator) must be present for handover

Adequate packaging:

• Products must be delivered in safe, hygienic, and industry-standard packaging
• Food must comply with food-safe packaging
• You are liable for damages due to inadequate packaging

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5.2 Incoterms and Delivery Terms

All transactions on the Cultioo platform are processed under clearly defined Incoterms, specified in the product listing's Transport Matrix and confirmed at checkout. The following Incoterms are supported: Incoterm Risk Transfer Point Seller Obligations

EXW (Ex Works) At seller's premises Goods made available; buyer assumes all transport responsibility

FCA (Free

Carrier)

DDP (Delivered

Duty Paid) At buyer's destination

At named

carrier/handover point

Seller delivers to named carrier; risk

passes upon handover

Seller bears all costs and risks

including duties until delivery

Under DDP terms, the seller is financially responsible for the Delvioo™ transport cost — this fee is automatically deducted from the seller's account with no manual payment required.

5.3 Risk Transfer (Point of Risk Transfer)

THE SELLER RETAINS FULL LIABILITY AND RESPONSIBILITY for product quality and condition until the moment of physical handover to the Delvioo™ Driver OR a third-party shipping service provider privately organized by you.

From the moment of handover to the carrier:

• The risk of accidental loss or deterioration passes to the carrier or buyer
• You are no longer liable for transport damages (except for inadequate packaging)
• The carrier bears responsibility for safe delivery

This risk transfer corresponds to the commercial practice "FOB Origin" (Free On Board — shipping point).

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5.4 Gate Verification — Seller-Side Check-In and Check-Out

All Delvioo™ pickups at seller facilities must pass through a mandatory two-stage gate verification protocol executed by your designated Operator via the Cultioo Scanner App. This protocol generates the legally binding chain of custody record.

Stage 1 — Check-In (Driver Arrives, Vehicle Empty)

Your Operator completes the following steps before any loading activity begins:

Step Action

1 Gate and loading bay assignment — transmitted instantly to the driver's Delvioo™ app

2 Driver identity verification (face vs. KYC profile photo), license plate scan, vehicle type confirmation — mismatch blocks check-in

3 PPE compliance check — High-Visibility Vest and Safety Footwear. Non- compliance blocks check-in and is permanently recorded

4 Vehicle type suitability — refrigeration unit status, compartment type match, multi-section assignment confirmed

5 Load compartment hygiene inspection — visual cleanliness, odor, moisture, prior cargo residue. Pass / Fail permanently recorded

6 Cleaning Certificate validation — Valid / Missing / Expired. Missing certificate blocks check-in for cargo types requiring one

Pre-loading damage inspection — exterior and interior photographs (2–3 images, timestamped, geotagged, transmitted to buyer-side operator) 8 Tare weight entry — empty vehicle weight measured on facility scale. Value locked upon confirmation, cannot be modified

9 Arrival timestamp — detention timer elapsed time recorded

10 QR Code check-in confirmation — driver scans QR Code on Operator's screen; digital handshake confirmed, loading begins

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Stage 2 — Check-Out (Vehicle Loaded, Ready for Departure)

Step Action

1 Gross weight entry — fully loaded vehicle measured on facility scale Net weight calculation — Gross minus Tare = Net Load (legally binding delivery weight). CullyAI™ deviation alert if net load deviates from ordered quantity

Batch and compliance data — Production Date, Best Before / Expiry Date, Batch Number, Storage Number, optional Notes — transmitted to driver and buyer-side operator

4 Temperature protocol (cold chain) — departure temperature measured before sealing, compared against order's Min/Max range

Load security confirmation — load straps, pallet stability, hazardous material placards if applicable. Liability for load security transfers to driver from this point

Dispatch condition photographs — 2–3 images of loaded cargo

(timestamped, geotagged, permanently stored, transmitted to buyer-side operator)

Seal number — physical tamper-evident seal applied, seal number scanned or entered, transmitted in real time to buyer-side operator and driver

Document upload — Organic Certification, Origin Certificate, Analysis Reports, Bill of Lading, and other compliance documents. All mandatory documents must be uploaded before check-out can proceed

9 Automated digital delivery note — auto-generated from all check-out data and distributed to buyer, driver, and seller admin

Digital signatures — Operator signs digitally (certifying cargo accuracy); Driver signs digitally (accepting cargo as documented). Refusal by either party blocks departure

11 Departure QR scan — driver scans final QR Code; order status advances to In Transit

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All data captured during seller-side check-out is stored immediately in the platform database and transmitted in real time to the buyer-side operator — forming the immutable dispatch record that is cross-referenced upon arrival at the buyer facility.

5.5 Fulfillment Options — Delvioo™ Toggle

From the Order Details screen, you choose between two fulfillment modes: Option A — Delvioo™ Fulfillment (Active)

The order proceeds through the standard Transport Auction workflow. Once a Delvioo™ driver has been assigned and compensated, the toggle locks permanently — the order is committed to Delvioo™ fulfillment with no further modification permitted.

Option B — Self-Arranged Delivery

When Delvioo™ is disabled (prior to any driver assignment or payment), you provide:

Field Description

Date the goods were produced or harvested

Production Date Best Before / Expiry

Date Shelf life endpoint for the product

Storage Number Warehouse or storage unit identifier for pickup coordination

Once a driver has accepted a self-arranged order, you must also confirm Best Before Date, Production Date, Batch Number, and optional Notes before the driver gains access to full order details.

5.6 Delvioo™ Driver as Independent Contractor

IMPORTANT CLASSIFICATION:

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When transport is performed by a Delvioo™ Driver, the Driver acts EXCLUSIVELY AS AN INDEPENDENT CONTRACTOR of Delvioo™/Cultioo, and NOT as an employee, agent, or direct representative.

Driver Liability: The Delvioo™ Driver is liable for safe and professional pickup of goods, compliance with delivery time, all damages or losses that occur during transport, and traffic accidents or incidents during delivery. No Joint Liability: You as the seller are NOT liable for the actions or omissions of the Delvioo™ Driver after proper handover of the goods. Cultioo and you are not responsible for delays, improper handling (after proper handover), or accidents caused by the Driver.

5.7 Multi-Section Vehicle and Order Split Logic

The Cultioo platform natively supports vehicles divided into multiple independent load compartments (sections). Each section can carry a separate order assigned to a different buyer — enabling LTL (Less Than Truckload) optimization.

If a driver's section capacity is insufficient for the full order:

• The driver loads the portion their section can accommodate
• The remaining quantity is automatically separated and published as a new independent order on the Delvioo™ marketplace — immediately available for bidding by other qualified drivers
• The buyer is notified in real time

Each section receives its own independent check-out workflow, its own seal number, and its own chain of custody record. A tamper event or compliance failure in one section does not affect other sections. Terms & Conditions

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5.8 Self-Organized Shipping (Third Party)

If you privately organize shipping through a third-party shipping service provider (e.g., UPS, FedEx, own delivery), sole liability for the following aspects rests with you:

• Selection of a reliable shipping service provider
• Smooth shipping and timely delivery
• Compliance with all delivery terms
• Communication with the buyer about shipping status
• Tracking information

Cultioo assumes NO logistics liability in this case.

5.9 Notification Obligations in Case of Problems

In case of unforeseen delays, breakdowns, or delivery problems, you are obligated to:

1. Inform the buyer immediately

2. 3. Coordinate a solution directly with the buyer

Notify Cultioo of serious incidents

Failure to inform the buyer can lead to customer complaints, negative reviews, refund demands, and account suspension.

6. Tax Obligations and Compliance

6.1 State Sales Tax

a) Marketplace Facilitator Responsibility

IMPORTANT CLARIFICATION:

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In accordance with Marketplace Facilitator (MPF) laws that apply in the overwhelming majority of U.S. states, Cultioo Inc. assumes the statutory obligation to collect and remit state sales and use taxes for transactions processed through the platform.

What this means for you:

• Cultioo automatically collects sales tax from the buyer at the time of transaction
• Cultioo remits sales tax to the appropriate state authorities
• You do NOT need to separately collect or remit sales tax for transactions through Cultioo

Your Obligations: Correct product categorization (some products are tax- exempt or have reduced tax rates), providing accurate product information, and cooperation during tax audits or inquiries.

b) Exceptions and Special Cases

Sales tax may not apply to certain food items (tax-exempt in some states), agricultural products (depending on state), and transactions below certain thresholds.

You are responsible for knowledge of the tax treatment of your products, compliance with state special regulations, and transactions outside the Cultioo platform.

6.2 Income Tax and Self-Employment Tax

You are solely responsible for:

• Proper reporting of all income from sales through Cultioo on your Federal Income Tax Return
• Payment of Self-Employment Tax on your net profits
• Maintenance of proper accounting records
• Remittance of estimated quarterly tax payments (Estimated Tax Payments), if required

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6.3 IRS Reporting Requirements and Form 1099-K

a) Stripe as Payment Settlement Entity (PSE)

Stripe, as a "Payment Settlement Entity" (PSE), is legally obligated to report transaction information to the Internal Revenue Service (IRS). Form 1099-K Reporting: Stripe will issue you and the IRS a Form 1099-K if your gross transactions exceed the statutory threshold (currently $600 as of tax year 2024).

b) Your Obligations

You are required to:

• File a correct IRS Form W-9 (for U.S. persons) or W-8BEN (for non-U.S. persons) with Stripe
• Provide your Tax Identification Number (TIN) — SSN for individuals, EIN for businesses
• Consent to electronic delivery of 1099-K documents via the Stripe Dashboard

Failure: If you do not provide a valid TIN, Stripe is required to apply Backup Withholding (currently 24%) from your payouts and remit these withheld amounts to the IRS.

6.4 State Income Tax

In addition to federal income tax, state income taxes may apply depending on your state of residence and states in which you conduct business (Economic Nexus).

You are responsible for compliance with your state's income tax laws, registration and reporting in states with Economic Nexus, and payment of estimated state tax payments.

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6.5 Licenses and Permits

Depending on your products and location, you may need:

General Business Licenses: Business License, Seller's Permit, Zoning Permits (for home-based businesses)

Food-Specific Licenses: Food Handler's Permit, Cottage Food License (for homemade foods), Commercial Kitchen License (for commercial kitchens), Health Department Inspections

Special Licenses: Organic Certification, Liquor License, USDA Inspection (for meat and poultry)

You warrant that you possess all required licenses and permits and that they are current.

7. Insurance and Risk Management

7.1 Mandatory Insurance Requirement

You as the seller are required to obtain and maintain adequate insurance to cover risks associated with your business.

a) Commercial General Liability (CGL) Insurance

Coverage Type Minimum Limit

Per Occurrence $1,000,000

General Aggregate $2,000,000

Covered Risks: Product Liability, Bodily Injury, Property Damage, Personal & Advertising Injury

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b) Product Liability Insurance

Required if you sell food products, manufacture or process products, or sell products under your own brand.

Minimum Coverage: $1,000,000 per occurrence

c) Cultioo as Additional Insured

IMPORTANT: Cultioo Inc. MUST be named as "Additional Insured" on your insurance policy.

This means:

• Cultioo is directly protected by your insurance
• In claims against Cultioo arising from your products, the insurance can defend and indemnify Cultioo
• This secures the indemnification obligation under Section 9.4 d) Proof of Insurance

You are required to:

• Submit a Certificate of Insurance (COI) to Cultioo
• Maintain insurance throughout the duration of your seller activity
• Inform Cultioo of changes or cancellations of insurance (at least 30 days' notice)

Failure: If you do not provide proof of adequate insurance, your account may be suspended, you cannot list or sell products, and you are personally and unlimitedly liable for all claims.

7.2 Transport Insurance

For higher-value shipments, we strongly recommend Cargo/Transit Insurance and coverage for loss, theft, or damage during transport. This is your responsibility if you organize shipping yourself.

Terms & Conditions

Cultioo Business App

United States

8. Claims and Refunds

8.1 Contractual Reporting Period for Problems

30-DAY REPORTING PERIOD:

The period for reporting a problem, defect, or complaint via the Cultioo App is strictly 30 DAYS FROM THE DATE OF DELIVERY of the goods.

AFTER EXPIRATION OF THIS CONTRACTUAL PERIOD, DEFECTS CAN NO

LONGER BE REPORTED OR CLAIMED VIA THE CULTIOO APP.

This short reporting period forces buyers to promptly inspect received goods, enables quick problem resolution, and protects against stale claims.

Note: Statutory claims subject to longer statutes of limitations remain fundamentally unaffected but must be asserted outside the platform directly against you.

8.2 Evidence Base for Claims

The Cultioo platform generates comprehensive digital documentation throughout every transaction that constitutes the primary evidence base for all claim evaluations:

• Pre-loading and dispatch photographs — timestamped, geotagged, and permanently stored; transmitted to buyer-side operator for direct before/after comparison
• Digital delivery note — auto-generated at check-out, cross-referenced against buyer-side receipt data
• Weight records — tare weight, gross weight (loaded), and calculated net weight; cross-referenced against ordered quantity by CullyAI™ Terms & Conditions

Cultioo Business App

United States

• Seal number record — entry timestamped at dispatch and cross- referenced at buyer arrival; mismatch constitutes documented tamper event
• QR scan timestamps — each check-in and check-out event permanently recorded with timestamp and geolocation
• Digital signatures — legally binding electronic signatures from both your Operator and the driver at dispatch, closing your liability at the defined transfer point
• Cold chain temperature records — departure temperature measured before sealing, compared against arrival temperature at buyer facility Sellers are encouraged to maintain all platform-generated records as their primary defense in any chargeback or dispute scenario.

8.3 Primary Resolution of Disputes

BUYER AND SELLER RESPONSIBILITY:

The primary resolution and settlement of product, quality, or delivery problems must occur directly between you and the buyer.

Cultioo is NOT obligated to:

• Participate in these primary negotiations
• Act as mediator
• Make decisions about refunds

Cultioo may, at its sole discretion:

• Provide communication mechanisms
• Offer voluntary dispute resolution

This does not create a legal obligation to intervene.

Terms & Conditions

Cultioo Business App

United States

8.4 Refund Processing

For legitimate complaints (e.g., defective goods, wrong items, prematurely expired products):

Your Obligations:

• Offer reasonable solutions (full refund, partial refund, replacement delivery, credit for future purchases)
• Initiate the refund within 7 business days after agreement

Financial Processing:

• The financial burden of the refund rests exclusively with you
• Cultioo will deduct the refund amount from your seller account
• Commissions already paid out are not refunded

Repeated Refunds: A high refund rate can lead to account review, increased fees, account suspension, and termination.

8.5 Customer's Right to Refund

The buyer is entitled to a refund for:

• Product defects: Spoiled, damaged, or unsafe products
• Wrong item: You delivered the wrong item
• Missing items: Parts of the order are missing
• Prematurely expired products: Products with an already exceeded expiration date
• Not as described: Significant deviations from the product description
• Not delivered: Product was never delivered after reasonable waiting time Terms & Conditions

Cultioo Business App

United States

9. Indemnification and Limitation of Liability

9.1 Exclusion of Consequential Damages

TO THE MAXIMUM EXTENT PERMITTED BY LAW, CULTIOO IS NOT LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, OR CONSEQUENTIAL

DAMAGES arising from use of the App or transactions, including but not limited to Lost Profits, Lost Revenue, Business Interruption, Loss of Data, Damage to Reputation, and Loss of Business Opportunities.

This comprehensive exclusion is a central element of risk minimization and is permissible and enforceable in commercial contract law between business partners.

9.2 Limitation of Total Liability (Liability Cap)

MAXIMUM LIABILITY:

Cultioo Inc.'s total liability to you for all claims arising from these TOS or use of the platform is limited to the greater of:

(a) All commissions and fees you paid to Cultioo in the six (6) months immediately preceding the event giving rise to the claim; OR

(b) Five Hundred U.S. Dollars ($500.00 USD)

Exceptions to the Liability Cap: This limitation does NOT apply to damages or losses caused by Cultioo Inc.'s:

• Gross Negligence
• Willful Misconduct
• Fraud

Terms & Conditions

Cultioo Business App

United States

9.3 Warranty Disclaimer for the Platform

THE CULTIOO BUSINESS APP AND ALL ASSOCIATED SERVICES ARE PROVIDED "AS-IS" AND "AS-AVAILABLE."

CULTIOO MAKES NO EXPRESS OR IMPLIED WARRANTIES OR GUARANTEES

REGARDING the availability, reliability, or error-free nature of the App, fitness for a particular purpose, non-infringement of third-party rights, security or error-free nature of software or technology, or accuracy of data or information.

You accept all risks associated with using the technology.

9.4 Indemnification

You agree to indemnify, defend, and hold harmless Cultioo Inc., its directors, officers, employees, contractors, and affiliated companies from all claims, losses, damages, liabilities, costs, and expenses (including reasonable attorney's fees) arising out of or related to:

a) Your Products

• Product liability claims (injuries, illnesses, damages from your products)
• Product defects or errors
• Misrepresentations or misleading product information
• Allergic reactions or health damages
• Violations of food safety laws b) Your Violation of These TOS
• Breach of contract clauses
• Violation of prohibited product policies
• Failure to fulfill obligations

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Cultioo Business App

United States

c) Your Non-Compliance with Laws

• Violations of federal laws (FDA, USDA, FTC)
• Violations of state regulations
• License or permit violations
• Tax violations d) Infringement of Third-Party Rights
• Infringement of intellectual property rights (trademarks, copyrights, patents)
• Violation of privacy or data protection rights
• Defamation or libel e) Your Negligent or Intentional Acts
• Fraud or intentional misrepresentation
• Gross negligence

This indemnification includes: all attorney's fees and legal costs, court costs and settlement amounts, damages and punitive payments, and regulatory fines.

Cooperation Obligation: You are required to notify Cultioo immediately of potential claims, cooperate in the defense against claims, and provide all necessary information and documents.

Enforceability: The enforceability of this indemnification obligation is directly tied to your financial strength. Therefore, mandatory insurance with Cultioo as "Additional Insured" (Section 7.1) is essential.

Terms & Conditions

Cultioo Business App

United States

10. Privacy and Security

10.1 Privacy Policy

Your use of the platform is subject to the Cultioo Business App Privacy Policy, which describes how we collect, use, and protect your personal information.

By accepting these TOS, you also accept the Privacy Policy.

Privacy Policy available at:

https://cultioo.com/en/en_cultioo_business_app_info#privacy

10.2 Data Processing

You consent that Cultioo may process your data for:

• Account management and authentication
• Transaction processing
• Compliance with legal obligations (KYC, AML, taxes, INFORM Consumers Act)
• Communication with you
• Platform improvement and analytics
• Fraud prevention and security

10.3 Disclosure of Seller Data

You expressly consent that Cultioo may disclose your seller information: To Buyers: Name/username, contact details (email, phone), business address (for high-volume sellers pursuant to INFORM Act)

To Delvioo™ Driver: Name, pickup location (GPS coordinates from Transport Matrix), contact details (for emergency contact only) Terms & Conditions

Cultioo Business App

United States

To On-Site Operators (via Scanner App): Driver identity data, QR Code and Security Code, weight records, seal numbers, batch data, and dispatch photographs — all necessary for gate verification and chain of custody To Authorities: Tax authorities (IRS, State Tax Departments), law enforcement (for legal requests), regulatory authorities (FDA, USDA, FTC, etc.)

10.4 Data Security

Cultioo commits to implementing appropriate technical and

organizational measures to protect your data, including:

• Encryption of data transmission (HTTPS/TLS)
• Secure storage of sensitive data with industry-standard cryptographic hashing (bcrypt/Argon2)
• Tokenization of all financial data via Stripe — Cultioo never stores complete bank or card numbers
• Strict internal access control
• Regular security reviews and penetration testing

11. Intellectual Property

11.1 Ownership of the Platform

All content, trademarks, logos, software, designs, and other intellectual property displayed on the platform are owned by Cultioo Inc. or its licensors and are protected by copyright, trademark, and other intellectual property laws. This includes the Cultioo name and logo, Delvioo™, CullyAI™ ,

and Monioo™

.

You may not, without prior written consent from Cultioo:

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Cultioo Business App

United States

• Reproduce, copy, or duplicate platform content
• Distribute or publicly display platform elements
• Modify or create derivative works
• Conduct reverse engineering of any part of the platform

11.2 Your Intellectual Property

You retain ownership of:

• Your product images and descriptions
• Your trademarks and logos
• Your copyrighted content

License to Cultioo: You grant Cultioo a worldwide, non-exclusive, royalty- free, transferable license to:

• Display your products on the platform
• Use your images and descriptions for marketing
• Share with buyers and Delvioo™ for transaction purposes

This license ends when you remove your product listings or delete your account.

11.3 No Infringement

You warrant that:

• You are the lawful owner of all content or have the rights to use it
• Your products and content do not infringe third-party rights (trademarks, copyrights, patents)
• You do not sell counterfeit or imitation products

Violations of intellectual property rights can lead to: immediate removal of listings, account suspension, legal consequences, and damage claims. Terms & Conditions

Cultioo Business App

United States

12. Termination of Use

12.1 Termination by You

You may terminate your seller account at any time by using the deletion function in the app (requires password confirmation) or informing us in writing via the contact details in Section 17.

After termination:

• You lose access to your account and all associated data
• Outstanding payouts will be processed according to the regular schedule, after deduction of all open claims
• You remain liable for all obligations incurred before termination Note: Transaction records and tax forms are subject to legal retention obligations of up to 10 years and will be locked (restricted to compliance purposes only) following account deletion — see Business Privacy Policy Section 16 for full details.

12.2 Termination by Cultioo

Cultioo may terminate or suspend your account pursuant to Section 2.3 of these TOS.

In the event of termination by Cultioo for cause:

• There is no entitlement to refund of fees paid
• Outstanding payouts may be withheld until all claims are resolved
• You may be excluded from future use of the platform

12.3 Surviving Provisions

Provisions of these TOS that by their nature should survive termination remain in effect after termination of your use, including:

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Cultioo Business App

United States

• Liability limitations (Section 9.2)
• Indemnification obligations (Section 9.4)
• Warranty disclaimers (Sections 3.2 and 9.3)
• Arbitration agreement (Section 13)
• Governing law (Section 14)
• Intellectual property provisions (Section 11)

13. Dispute Resolution and Arbitration

13.1 Informal Dispute Resolution Attempt

Before initiating arbitration or a lawsuit, you commit to first attempting informal dispute resolution.

Procedure: Send a detailed written complaint to:

Cultioo Inc.

Attn: Legal Department — Dispute Resolution

8 The Green, Ste A, Dover 19901, United States

Email: privacy@cultioo.com

The complaint must include your full name and contact details, a description of the nature and basis of the claim or dispute, and the desired remedy.

60-Day Negotiation Period: After receipt of the complaint, both parties will attempt in good faith to resolve the dispute informally. This 60-day period is mandatory before initiating arbitration.

13.2 Binding Arbitration Agreement

MANDATORY ARBITRATION AGREEMENT:

Terms & Conditions

Cultioo Business App

United States

ALL DISPUTES, CONTROVERSIES, OR CLAIMS arising out of or relating to these TOS, use of the Cultioo Business App, transactions, or Cultioo's services SHALL BE RESOLVED EXCLUSIVELY AND FINALLY BY BINDING ARBITRATION, rather than in court.

YOU HEREBY EXPRESSLY WAIVE YOUR RIGHT TO LITIGATE A DISPUTE IN COURT AND TO BE JUDGED BY A JURY.

13.3 Arbitration Rules and Administration

The arbitration will be administered by the American Arbitration Association (AAA) in accordance with its Commercial Arbitration Rules and Supplementary Procedures for Consumer-Related Disputes.

AAA Rules available at: www.adr.org or by phone: 1-800-778-7879

13.4 Arbitrator and Procedure

• Arbitrator: A single neutral arbitrator selected according to AAA Rules. The arbitrator has exclusive authority to decide all disputes, including interpretation and enforceability of this arbitration agreement.
• Location: Delaware, USA (or by phone/video by agreement)
• Procedure: May be conducted orally (hearing), by phone, by video conference, or based on written submissions. The arbitrator decides on the appropriate form.
• Award: The arbitrator's decision is final and binding. The award may be entered as a judgment in any court of competent jurisdiction.

13.5 Costs and Fees

Claim

Fee Allocation

Amount

Under

$10,000

Cultioo pays all AAA filing fees, administrative costs, and arbitrator fees, unless the arbitrator finds your claims were frivolous

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Cultioo Business App

United States

Claim

Amount

$10,000 or

more

Fee Allocation

Attorney's

fees

Fees allocated according to AAA Rules

Each party bears its own, unless applicable law or the arbitrator orders otherwise. Cultioo will not seek attorney's fees from you unless your claims were frivolous.

13.6 Class Action Waiver

YOU AND CULTIOO AGREE THAT EACH PARTY MAY BRING CLAIMS AGAINST THE OTHER ONLY IN ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, CONSOLIDATED, OR

REPRESENTATIVE ACTION.

YOU HEREBY WAIVE YOUR RIGHT TO PARTICIPATE IN CLASS ACTIONS.

The arbitrator may not consolidate the claims of multiple persons or preside over any form of representative action.

Invalidity of this Clause: IF THIS SPECIFIC PROVISION IS FOUND TO BE UNENFORCEABLE, THE ENTIRE ARBITRATION AGREEMENT IS NULL AND VOID, and all disputes will be litigated in court.

13.7 Opt-Out Right (30-Day Window)

You have the right to opt out of this arbitration agreement by sending a written notice to:

Cultioo Inc.

Attn: Legal Department — Arbitration Opt-Out

8 The Green, Ste A, Dover 19901, United States

Terms & Conditions

Cultioo Business App

United States

The opt-out notice must be sent within thirty (30) days of your first use of the platform or acceptance of these TOS, whichever is earlier. The notice must include:

• Your full name
• Your address
• Your email address associated with your Cultioo account
• A clear statement that you wish to opt out of the arbitration agreement If you opt out, all other terms of these TOS continue to apply.

14. Governing Law

These Terms of Service and all disputes arising therefrom are governed by and construed in accordance with the laws of the State of Delaware, USA, without regard to its conflict of laws provisions.

The choice of Delaware law is made because of its well-developed and business-friendly commercial legislation.

15. Severability Clause

If any provision of these TOS is found to be invalid, unlawful, or unenforceable, the remaining provisions shall remain in full force and effect. The invalid provision shall be replaced by a valid provision that most closely approximates the intent and economic purpose of the original provision.

The parties commit to negotiating in good faith to replace the invalid provision with a legally permissible provision.

Terms & Conditions

Cultioo Business App

United States

16. Amendments to the TOS

Cultioo reserves the right to amend or update these TOS at any time. We will notify you of material changes via email or through a prominent notice on the platform.

Continued use of the platform after changes take effect constitutes your acceptance of the revised TOS. If you do not agree with the amended terms, you must cease using the platform and terminate your account.

17. Contact Information

For questions about these TOS, complaints, or concerns, please contact us at:

Cultioo Inc.

A Delaware Corporation

8 The Green, Ste A

Dover, DE 19901

United States of America

Department Contact

Main / General Support support@cultioo.com

Legal Department support@cultioo.com

Disputes / Privacy privacy@cultioo.com

Website www.cultioo.com

We strive to respond to all inquiries within five (5) business days. Terms & Conditions

Cultioo Business App

United States

18. Confirmation and Consent

BY CLICKING "I ACCEPT", CHECKING THE CORRESPONDING BOX, OR USING THE CULTIOO BUSINESS APP, YOU CONFIRM AND DECLARE:

• That you have fully read and understood these Terms of Service
• That you agree to be bound by all provisions of these TOS
• That you waive your right to litigate disputes in ordinary courts and instead agree to the binding arbitration agreement
• That you waive your right to participate in class action lawsuits
• That you understand and accept the liability limitations and warranty disclaimers
• That you accept the integration of the Stripe Terms by reference
• That you accept the mandatory insurance requirement with Cultioo as Additional Insured
• That you are of legal age and have the legal capacity to enter into this agreement
• That all information provided during registration is true, accurate, and complete

IF YOU DO NOT AGREE TO THESE TERMS, YOU MAY NOT USE THE CULTIOO BUSINESS APP.

Last Updated: January 1, 2026 · Version: 1.0

© 2026 Cultioo Inc. All Rights Reserved.

Governing Entity: Cultioo Inc., a Delaware Corporation

Terms & Conditions

Delvioo

United States

Privacy Policy

Delvioo™ Driver App

Valid for: United States of America

Effective Date: January 1, 2026

Last Updated: January 1, 2026

Version: 1.0

Governing Entity: Cultioo Inc., a Delaware Corporation

Cultioo Inc., a Delaware corporation, understands that privacy and the security of personal data are fundamental concerns for its independent contractor drivers. This Privacy Policy describes in detail Delvioo™'s data collection, usage, disclosure, and security practices in compliance with United States privacy laws, including the Delaware Personal Data Privacy Act (DPDPA), the Federal Trade Commission (FTC) regulations, and the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

Delvioo™ is committed to maintaining the trust of its drivers by prioritizing privacy, implementing comprehensive technical and organizational measures (TOMs) to secure driver data, and ensuring complete transparency regarding all data processing activities.

Table of Contents

1. Scope and Application

2. Controller and Contact Information

3. Definitions

Terms & Conditions

Delvioo

United States

4. Consent and Data Basis

5. Categories of Information Collected and Processing Purposes

6. Data Storage and Data Security

7. Payment Processing, Bank Data, and Tax Compliance

8. Data Disclosure and Emergency Scenarios

9. Location Data (Precise Geolocation)

10. Payout Rules and Proof of Delivery

11. Your Privacy Rights

12. Data Retention Policy

13. Privacy of Minors

14. Do Not Track and Tracking Technologies

15. Changes to This Privacy Policy

16. Contact Information

1. Scope and Application

1.1 Scope

This Privacy Policy applies to all independent contractors (drivers) who use the Delvioo™ Driver Mobile App and associated services within the United States of America. Delvioo™ functions as the logistics and delivery execution layer of the Cultioo ecosystem, facilitating transportation of agricultural and commercial goods between sellers and buyers.

1.2 What Is the Delvioo™ Driver App?

The Delvioo™ Driver Portal is a standalone professional mobile environment for the transport sector embedded within the Cultioo Business App. It supports both independent operators and full fleet structures. Key capabilities include:

Terms & Conditions

Delvioo

United States

Feature Description

Transport Discovery

Bid Workflow

Active Order

Management

End-to-End Delivery

Cycles

CullyAI™ In-

Navigation

Intelligence

Fleet Group

Management

CO₂ & Sustainability Detention Billing Real-time geospatial map of open transport assignments — interactive pins at seller pickup locations, sortable by

vehicle compatibility and contract value

Step-by-step route evaluation, vehicle compatibility check,

capacity confirmation, and price submission — fixed total

price or per km/mi rate

Simultaneous management of multiple active deliveries

with CullyAI™ automated route optimization

Dual QR-code verification at both seller (pickup) and buyer

(delivery) facilities — two mirrored check-in / check-out

cycles

Proactive real-time discovery of compatible open orders

while navigating — popup alerts with route, distance, fuel,

and price data

Fleet Admin / Member role system with consolidated

earnings and invoice access

Monthly CO₂ reporting and Sustainability Certificate

generation

Automated waiting time billing with geofenced arrival

trigger and configurable hourly rates

Note: The Delvioo™ Driver Portal is mobile-only. Desktop access is not available for drivers.

1.3 Legal Framework

Delvioo™'s commitment to privacy is guided by:

• Delaware Personal Data Privacy Act (DPDPA) — Privacy law of the State of Delaware
• Federal Trade Commission (FTC) Act — Federal requirements for fair data practices

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Delvioo

United States

• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) — As best-practice standards for sensitive data
• Virginia Consumer Data Protection Act (VCDPA)
• Colorado Privacy Act (CPA)
• Connecticut Data Privacy Act (CTDPA)
• Other applicable state privacy laws

1.4 Driver Status

Delvioo™ drivers operate as independent contractors with 1099 status and are not employees of Cultioo Inc.

Although the DPDPA in Delaware may exclude individuals in an employment relationship from protection, Delvioo™ grants all drivers the comprehensive rights prescribed by the CPRA, regardless of their location or employment status.

1.5 Consent Through Use

By registering for or using the Delvioo™ Driver App, you provide explicit consent to the collection and processing of your data in accordance with this Privacy Policy.

2. Controller and Contact Information

Responsible Company:

Cultioo Inc.

A Delaware Corporation

8 The Green, Ste A

Dover, DE 19901

United States of America

Terms & Conditions

Delvioo

United States

Contact: privacy@cultioo.com

Privacy Office: privacy@cultioo.com

Online Request Portal: www.cultioo.com

3. Definitions

3.1 Personal Information (PI)

Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, including but not limited to: names, email addresses, physical addresses, phone numbers, IP addresses, driver's license numbers, financial account information, tax identification numbers, and location data.

3.2 Sensitive Personal Information (SPI)

A subcategory of Personal Information requiring enhanced protection, including:

• Precise location data (GPS geolocation that can identify a person within 1,850 feet / approximately 564 meters)
• Financial account information and credentials
• Tax identification numbers (SSN, TIN)
• Driver's license numbers
• Other highly sensitive government identifiers

3.3 Sale

The selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to another business or third party for monetary or other valuable consideration.

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Delvioo

United States

3.4 Sharing

The sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to a third party for cross-context behavioral advertising.

3.5 Service Provider

A business that processes personal information on behalf of Delvioo™ and is contractually bound to use the data exclusively for agreed-upon purposes.

4. Consent and Data Basis

4.1 Basis for Data Processing

The processing of your data is based on two main pillars:

1. 2. Contractual Necessity: Processing is necessary to provide the logistics

service, facilitate orders, and enable payouts.

Explicit Consent: Particularly for sensitive data (precise location data, financial information), you provide your explicit, revocable consent.

4.2 Consent Mechanism

Registration on the Delvioo™ platform, as well as subsequent updates to settings and use of services, constitute explicit consent to the processing of personal information in accordance with this policy.

This form of consent is:

• Electronically documented

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Delvioo

United States

• Clear and unambiguous
• Revocable at any time

4.3 Right to Withdraw

You have the right to withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal. IMPORTANT NOTICE: Since the processing of certain data (particularly precise location data) is strictly necessary for contract performance, withdrawal of this consent may result in Delvioo™'s inability to provide the logistics service.

4.4 Data Storage Upon Registration

All data shared or modified in the app is stored in a secure database by Delvioo™

.

Password Security:

• Passwords are hashed (irreversibly encrypted) before storage in the database
• Delvioo™ employees have no access to your original passwords
• Industry-standard cryptographic hash functions are used (e.g., bcrypt, Argon2)

5. Categories of Information Collected and Processing

Purposes

In accordance with CCPA/CPRA and DPDPA, Delvioo™ discloses the following categories of personal information collected in the last 12 months: Terms & Conditions

Delvioo

United States

5.1 Detailed Overview of Data Categories

CCPA/CPRA

Category

A: Identifiers

B: Personal

Records

Information

D:

Commercial

Information

F: Internet /

Network

Activity

Examples of

Data Collected

Full name,

email address,

physical

address, phone

number, driver's

license number,

device ID, IP

address

Name, address,

phone number,

driver's license

information

Order history,

transaction

records, payout

history,

earnings and

performance

statistics

Interaction with

app, session

duration,

settings

changes,

device/OS

details

Source Primary

Purpose

Driver

registration,

transactional

input, device

Driver input,

verification

process

Transactions,

driver activity

Device, app

usage

Account

management,

identification,

security, order

processing

Order

processing,

verification,

emergency

contact

Order

processing,

billing, payout,

internal

analysis

Debugging,

quality

assurance,

service

improvement,

security

monitoring

Disclosed to Third

Parties

Yes (service

providers, buyers

during active

orders)

Yes (service

providers,

buyers/sellers in

emergencies)

Yes (payment

processors)

Yes (analytics

providers/service

providers)

Terms & Conditions

Delvioo

United States

CCPA/CPRA

Category

G:

Geolocation

Data

K: Sensitive

Personal

Information

(SPI)

Examples of

Data Collected

Precise GPS

coordinates,

real-time truck

location

Precise

location,

financial

account

information, tax

identification

numbers (SSN,

TIN), driver's

license number

Source Primary

Purpose

Device (with

explicit

consent)

Device, driver

input,

verification

process

Order

fulfillment,

tracking, route

optimization,

status display

Service

provision,

payment

processing, tax

compliance,

identity

verification

Disclosed to Third

Parties

Yes (buyers,

Delvioo™ dispatch

team during

active orders)

Yes (Stripe for

payments/taxes,

buyers for

tracking)

5.2 Detailed Description of Data Categories

A. Identifiers

Data Collected:

• Full name (first and last name)
• Email address
• Physical address (residential address)
• Phone number
• Driver's license number
• Device ID and unique identifiers
• IP address

Processing Purposes:

• Creation and management of your driver account
• Authentication and access control

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Delvioo

United States

• Identification during order handover and gate verification
• Communication with you
• Fraud prevention and security

Sources: Direct input by driver upon registration; automatic collection by device.

B. Commercial Information

Data Collected:

• Order history and delivery details
• Transaction records
• Payout history
• Earnings and performance statistics
• Distance tracking data (Today / This Week / This Month)
• Fuel efficiency and CO₂ emission data per order

Processing Purposes:

• Processing orders
• Calculating and disbursing compensation (95% of agreed transport price per completed delivery)
• Performance analysis
• Sustainability Certificate generation
• Internal analysis to improve the platform

Sources: Driver activity within the app, order processing.

C. Internet and Network Activity

Data Collected:

• Interaction data with the app
• Pages and features visited
• Click and navigation behavior
• Session duration
• Device type, operating system

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Delvioo

United States

• App version

Processing Purposes:

• Ensuring app functionality
• Identifying and fixing errors (debugging)
• Analyzing usage to improve user experience
• Security monitoring

Sources: Automatic collection during app usage.

D. Precise Geolocation Data (Sensitive Personal Information) Data Collected: GPS coordinates of the truck, precise geographic location in real-time

Processing Purposes:

• Strictly necessary for contract performance: real-time delivery tracking, route optimization, status display for buyers
• Transparent communication of delivery status to buyers and seller
• Emergency management
• Geofenced Arrival Trigger: activating the Arrived button and initiating the detention billing timer upon entry within 5 km/mi of the declared delivery address
• CullyAI™ proximity-based discovery of nearby open orders during active navigation

IMPORTANT NOTICE: This data is classified as Sensitive Personal Information (SPI) and requires your explicit consent. However, processing is strictly necessary to fulfill the logistics order.

Temporal Limitation: Real-time tracking is exclusively active during active orders. No tracking outside working hours.

Sources: Driver's device (with explicit device permission and consent). Terms & Conditions

Delvioo

United States

E. Financial Account Information and Tax Data (Sensitive Personal Information)

Data Collected:

• Complete bank account numbers
• Credit card information
• Tax identification numbers (SSN for U.S. citizens, TIN for businesses)
• W-9 forms (for U.S. persons)
• W-8 forms (for foreign contractors)

Processing Purposes:

• Disbursement of compensation
• Compliance with U.S. tax reporting laws (IRS regulations)
• Fraud prevention and anti-money laundering (AML)

Special Note: This data is processed and stored exclusively by Stripe Inc. (see Section 7).

Sources: Driver input during the 10-stage registration process (Stage 07 — Stripe Connect KYC workflow).

F. Vehicle and Fleet Data

Data Collected:

• Vehicle Make, Model, Production Year, VIN (Vehicle Identification Number)
• License plate (front and back photographs — international format support: US, Mexico, Canada, EU, Russia)
• Vehicle Registration and Insurance Proof
• Wagon / Trailer Type (Grain Hoppers, Oil Bunkers, Refrigerated Wagons, etc.)
• Multi-section compartment configuration
• Cargo and payload capacity
• Fuel economy (MPG or L/100km)
• Internal cargo dimensions (Length, Width, Height)

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• Cold chain temperature range (Min/Max °F or °C — for refrigerated vehicles)

Processing Purposes:

• Vehicle compatibility checks against Transport Matrix requirements for each order
• Automatic blocking of incompatible or out-of-range assignments
• Fuel efficiency and profitability analysis
• CO₂ emission calculation and Sustainability Certificate generation
• LTL (Less Than Truckload) multi-section optimization

Sources: Driver input in Vehicle Management settings; photograph capture.

6. Data Storage and Data Security

6.1 Highest Priority

Privacy and Security Are Our Priority.

Delvioo™ treats data security as a core business function and implements comprehensive technical and organizational measures (TOMs) to protect driver data from unauthorized access, use, or disclosure.

6.2 Technical and Organizational Measures (TOMs)

a) Cryptography and Password Security

• Irreversible Hashing: All driver passwords are immediately encrypted upon creation using an irreversible hashing process
• No Plain Text Storage: Passwords are never stored in plain text
• No Employee Access: Even Delvioo™ employees and administrators have no access to your original passwords

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• Industry Standard: Use of cryptographic standards (e.g., bcrypt, Argon2) b) Encrypted Data Transmission
• Transport Layer Security (TLS): All data transmissions between your app and Delvioo™ servers occur over encrypted HTTPS/TLS connections
• End-to-End Protection: Protection against eavesdropping and man-in- the-middle attacks
• At-Rest Encryption: Sensitive Personal Information (SPI), including geolocation data and financial data, is stored encrypted c) Access Control
• Strict Internal Access Policies: Only authorized employees with legitimate business needs have access to personal information (need-to-know basis)
• Driver-Exclusive Modifications: Personal data and payment settings can only be changed by the authenticated driver via the secure app
• Multi-Factor Authentication: Critical operations (account deletion, password change, payment changes) require additional confirmation d) Data Loss Prevention (DLP)
• Implementation of systems to monitor and prevent unauthorized transmission or storage of sensitive data
• Automatic detection and blocking of data leaks e) Infrastructure Security
• Secure Server Environment: Use of professional, certified data centers
• Regular Security Audits: Conducting penetration tests and security reviews
• Incident Response Plan: Established procedures for handling security incidents
• Regular Backups: Secure data backups to ensure data integrity f) Employee Training
• Regular training of all employees on privacy and data security Terms & Conditions

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• Commitment to confidentiality

6.3 Secure and Irreversible Deletion

• Final Data Deletion: When you delete your account, all associated data is finally and irrevocably removed from the database (subject to legal retention obligations)
• No Recovery Possible: Deleted data cannot be restored
• Secure Deletion Protocols: Use of secure deletion methods that prevent recovery

6.4 Navigation Privacy

Drivers may delete all historical navigation data directly from the account settings at any time — clearing sensitive pickup locations, route history, and destination data from the device.

6.5 No Disclosure to Third Parties for Marketing

Your data is fundamentally not disclosed to third parties for advertising or marketing purposes.

7. Payment Processing, Bank Data, and Tax Compliance

7.1 Exclusive Use of Stripe Inc.

Cultioo Inc. partners with Stripe Inc., a leading PCI-DSS certified payment service provider. All payment processing and storage of financial data is conducted exclusively through Stripe.

7.2 Security of Your Financial and Tax Data

Secure Storage:

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• All provided bank accounts and credit card data are stored exclusively securely and encrypted by Stripe Inc.
• Delvioo™ never receives or stores your complete bank account numbers or credit card data
• PCI-DSS Compliance: Stripe meets the highest security standards of the payment card industry (PCI-DSS Level 1)

W-9/W-8 Tax Compliance:

• W-9 data (for U.S. citizens and residents) and W-8 data (for foreign contractors) are stored encrypted by Stripe
• Collection of this data is a legal obligation to comply with U.S. tax reporting laws (IRS regulations)
• This processing cannot be circumvented

7.3 Driver Earnings and Payout Structure

Fee Structure:

• Delvioo™ deducts a 5% service fee from every completed assignment payout — retained by Cultioo™ as the platform commission
• The driver receives 95% of the agreed transport price for every completed delivery — credited automatically upon buyer-confirmed order completion Payout Schedule Options:

Schedule Description

Standard

Settlement

Accumulated earnings transferred on the first day of every

month — predictable monthly revenue stream

Instant Payout

On-demand immediate payout for a nominal processing fee —

covers urgent operational costs such as fuel or maintenance

Bank Linking: One primary bank account per driver — single-source logic simplifies the audit trail and secures the fund destination. Fleet Group Payouts: Admins have exclusive visibility into total earnings for all group members and can download all official fleet invoices. Terms & Conditions

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7.4 Payout Trigger — Proof of Delivery

Payment is only released for payout when:

• The driver has completed the full delivery cycle at the buyer facility, AND
• The buyer-side operator has executed the final departure QR scan authorizing departure

Processed Data at Payout Trigger:

• Location and timestamp of successful final QR scan
• QR code / Security Code validation
• Digital signatures (buyer-side operator and driver)
• Delivery confirmation status

Legal Basis: Contract performance (Contractual Necessity). Processing of Proof of Delivery data is a necessary prerequisite for financial settlement.

7.5 Stripe as Independent Controller

• Independent Responsibility: Stripe Inc. acts as an independent data controller for the personal information it processes
• Separate Privacy Policy: You are subject to Stripe's separate privacy policy and terms of service
• Stripe Privacy Policy: https://stripe.com/privacy

7.6 Fraud Prevention and Anti-Money Laundering

Stripe uses the transmitted personal information for:

• Fraud detection and loss prevention
• Anti-money laundering (AML) compliance
• Identity verification (Know Your Customer — KYC)

This use serves the legitimate interests of the company and ensures the security of the payment system.

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7.7 Tax Retention Obligations

Delvioo™ and Stripe are obligated to comply with specific retention periods for tax documents:

• W-9/W-8 forms: Minimum 7 years
• Financial and payout records: Minimum 4 years

These periods comply with the requirements of the Internal Revenue Service (IRS) and the Federal Acquisition Regulation (FAR).

7.8 Disclaimer

Delvioo™ assumes no responsibility or liability for the security or use of data processed by Stripe. Use of Stripe occurs as a third-party service.

8. Data Disclosure and Emergency Scenarios

8.1 Principle of Non-Disclosure

Delvioo™ commits to not forwarding driver personal information to uninvolved third-party organizations, except in the following explicitly disclosed exceptions.

This serves to comply with the prohibition of unauthorized sale or disclosure of data without driver consent, as prescribed by DPDPA and CPRA.

8.2 Operational Disclosure (Standard Logistics)

To transparently process orders, certain minimal necessary information is operationally disclosed:

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a) To the Buyer (Recipient)

Data Purpose Temporal Limitation

Driver's first and last

Identification and delivery

name

confirmation

Only during active

orders

Real-time truck

location (GPS)

Transparent delivery status

communication

Exclusively during an

active order

Legal Basis: Contract performance.

Privacy Principle: Disclosure is strictly limited to the duration of service to respect privacy outside working hours.

b) To the Seller (Pickup Facility)

Data Purpose Temporal Limitation

Driver's first and

Gate identification Only during active orders

last name

Real-time truck

location (GPS)

ETA display to seller and

on-site operator

From order acceptance until

departure confirmation

The seller's live GPS display of the truck's position is continuously transmitted throughout the transit, enabling real-time tracking of the truck's movement from pickup to delivery.

c) To On-Site Operators (Cultioo Scanner App)

During active gate verification cycles, the following driver data is retrieved by on-site operators via QR scan:

Data Purpose

Driver Full Name (from KYC

record) Driver Profile Photo (from KYC

record)

Verbal identity confirmation at the gate

Visual cross-reference against physical driver

present

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Data Purpose

Must match exactly — mismatch blocks check-

License Plate (from order

assignment)

Order ID QR Code / Security Code in

Reference for all documentation and dispute

records

Dual-authentication mechanism for physical

cargo access

This data is retrieved exclusively during active gate verification and constitutes part of the chain of custody record.

d) Delvioo™ Dispatch Team

Data Purpose Temporal Limitation

Real-time

location

Route optimization, emergency

management

Only during active order

time

Contact details Emergency management Only during active order time

Legal Basis: Legitimate interest / Vital interest.

8.3 Obligation to Disclose in Emergency Scenarios

In critical and unforeseen situations, Delvioo™ is obligated to disclose driver data (first name, last name, phone number, email) to the buyer and/or seller team.

Emergency scenarios include:

1. 2. Product picked up but not arrived: Delivery was picked up from seller but

has not arrived at destination; agreed delivery time exceeded Suspicious truck movement: Buyer reports truck driving in wrong direction; truck stops for extended period without apparent reason; unusual route deviations

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3. Breakdown or unforeseen event: Technical problems with vehicle; traffic

accident; weather conditions or road closures critically affecting delivery time

Legal Basis:

• Vital Interest: Safety of driver and cargo
• Legitimate Interest: Loss prevention, ensuring contract fulfillment
• Contract Performance: Necessary communication for order processing

8.4 Legal Obligation (U.S. Standard)

Delvioo™ is obligated to disclose data to state or federal authorities when required by valid, formal legal process.

Requesting Entities: Law enforcement agencies, Courts, Regulatory agencies

Legal Instruments: Valid subpoena, Search warrant, Court order, Other legally mandated requests

Scope of Disclosure: Delvioo™ will only disclose data to the extent strictly necessary to comply with the legal obligation.

Transparency Commitment: Where legally permissible, Delvioo™ will inform the driver of such an order before data is disclosed.

8.5 Data Disclosure Overview

Recipient Data Categories Purpose Legal Basis Limitations

Stripe Inc.

Financial data,

tax data (W-

9/W-8)

Payout, tax

compliance,

fraud prevention

Contract

performance /

Legal

obligation

Refer to Stripe

Privacy Policy;

encrypted

storage

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Recipient Data Categories Purpose Legal Basis Limitations

Buyer

(Delivery

Recipient)

Seller

(Pickup

Facility)

On-Site

Operators

(Scanner

App)

Seller Team

Delvioo™

Dispatch

Team

U.S.

Authorities

First name, last

name; real-time

location

First name, last

name; real-time

location

KYC profile data,

license plate,

QR/Security

Code

Contact details

(emergencies

only)

Real-time

location, contact

details

All relevant data

(per request)

Identification,

Contract

status

performance

transparency

Gate

Contract

identification,

ETA display

performance

Gate verification,

chain of custody

Contract

performance

Emergency

management

Vital interest /

Legitimate

interest

Route

optimization,

emergency

management

Legitimate

interest / Vital

interest

Response to

valid legal

processes

Legal

obligation

(subpoena,

court order)

Only during

active order

time

Only during

active order

time

Only during

active gate

verification

cycles

Only during

critical

incidents

Only during

active order

time

Disclosure only

when legally

required

9. Location Data (Precise Geolocation)

9.1 Classification and Special Nature

Precise geolocation data is classified in leading U.S. states as Sensitive Personal Information (SPI).

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Definition: Precise geolocation identifies a person within 1,850 feet (approximately 564 meters) or more precisely.

The processing of this data is therefore subject to enhanced due diligence and special driver rights.

9.2 Strict Necessity for Contract Performance

Collection of precise truck location data is strictly necessary to fulfill the logistics order.

Use Purposes:

• Real-time delivery tracking
• Route optimization
• Transparent status display for buyers and sellers
• Emergency management
• Geofenced Arrival Trigger: the Arrived button is exclusively activated within a 5 km/mi geofence radius of the declared delivery address — ensuring accurate timestamping for detention billing and preventing premature arrival declarations
• CullyAI™ proximity-based discovery: continuously scanning for compatible open orders within the driver's pre-configured search radius during active navigation

Without this data, Delvioo™ cannot:

• Process orders transparently
• Provide delivery status display
• Activate the Arrived geofenced trigger
• Intervene in emergencies
• Enable CullyAI™ proactive order matching

9.3 Explicit Consent and Limitations

Consent: The driver provides explicit, revocable consent to the collection of precise location data.

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This consent is granted:

• During registration (device permissions)
• At the start of each order

Purpose Limitation and Data Minimization:

• Data is used only for order fulfillment, route optimization, transparent status display, detention billing, and CullyAI™ proximity features
• Location tracking is exclusively limited to the duration of an active order
• No tracking outside working hours

9.4 Driver Rights Regarding Location Data

a) Right to Limit Use (Right to Limit Use of SPI)

Under CPRA, you have the right to limit the use of your precise location data to purposes that are strictly necessary to provide the service. Practical Implementation:

• Location data is used exclusively for order fulfillment, route optimization, status display, and detention billing
• Delvioo™ does not use your location data for advertising purposes, profiling, or other non-operational purposes b) Withdrawal of Consent

You can withdraw your consent to location collection at any time via device settings.

Consequence: Should you limit or withdraw the use of precise geolocation, Delvioo™ cannot transparently process the logistics order and is entitled to discontinue the service.

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9.5 Control Over Location Access

You have complete control over location access at all times:

• Device Settings: You can control the Delvioo™ App's access to your location data via your mobile device settings (iOS or Android)
• Options:
• Completely disable location access
• Allow location access only while using the app
• Disable precise location (approximate location only)

Note: Disabling location services makes execution of delivery orders impossible.

10. Payout Rules and Proof of Delivery

10.1 Purpose of Data Collection

Collection and processing of data related to delivery confirmation serves contract processing and authorization of compensation.

10.2 Delivery Execution — Dual QR Verification Cycles

All Delvioo™ deliveries pass through two mirrored verification cycles. The following data is generated and processed at each cycle:

Cycle 1 — Pickup (Seller Facility)

Event Data Generated

Check-

In

Operator scans driver QR Code — cross-referenced against Security Code. Entry authorized, detention timer stops, driver receives Gate Number, Weighing Instructions, and Loading Position. Timestamp permanently recorded.

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Event Data Generated

Check-

Out

Operator conducts second QR scan to authorize departure. Seal number, batch data, gross weight, dispatch photographs, and

compliance documents transmitted to driver's app. Order status advances to In Transit. Departure timestamp recorded.

Cycle 2 — Delivery (Buyer Facility)

Event Data Generated

Check-

In

Buyer-side operator scans QR Code, cross-references Security Code, confirms seal integrity. Entry authorized, unloading instructions transmitted to driver. Detention timer stops. Timestamp permanently recorded.

Check-

Out

Following unloading, operator executes final QR scan for departure authorization. Order status advances to Completed. Seller payment released from escrow. Driver earnings credited. Departure timestamp permanently recorded.

10.3 Payout Trigger (Proof of Delivery)

Payment is only released for payout when:

• The driver has brought the product to the final destination, AND
• The buyer-side operator has executed the final departure QR scan and both parties have signed digitally

Processed Data:

• Location and timestamp of successful final QR scan
• QR code / Security Code validation
• Digital signatures (buyer-side operator and driver)
• Delivery confirmation status

Legal Basis: Contract performance (Contractual Necessity).

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10.4 Transfer and Processing Time

Release for Transfer: Payment is released for transfer immediately after successful validation and is ready for payout.

Dependence on External Factors: Actual crediting to your account depends on Stripe processing times, your bank's processing times, and your chosen payout schedule.

Typical Processing Time: 1–3 business days after release.

10.5 Access to Payout Accounts

Only the driver has sole access to managing payout accounts in the app. Management Options:

• Adding bank accounts
• Changing payout method (Standard Monthly / Instant On-Demand)
• Viewing payout history
• Managing tax information

Security Measure: All changes to payment settings require password confirmation.

10.6 Multi-Order Management and CullyAI™ Route Optimization

When a driver manages multiple simultaneous active orders, CullyAI™ automatically optimizes the combined route across all active assignments — minimizing fuel consumption and maximizing revenue-per-kilometer. Additional assignments can be appended to an existing active order mid- transit; each appended order triggers a recalculation of the combined route and ETA updates to all customers.

Each active order maintains its own independent QR verification cycle and payout record. Navigation Lock Protocol: once navigation has been Terms & Conditions

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initiated for an open order, that order cannot be re-selected or reassigned, ensuring logistical integrity.

11. Your Privacy Rights

Depending on your state of residence, independent contractors in the U.S. have specific legal rights regarding their personal information. Delvioo™ is committed to facilitating the exercise of these rights through transparent and accessible mechanisms.

11.1 Applicable Laws

The following rights apply particularly to residents of:

• Delaware: DPDPA
• California: CCPA/CPRA
• Virginia: VCDPA
• Colorado: CPA
• Connecticut: CTDPA
• Utah: UCPA

Delvioo™ grants these rights to all drivers, regardless of state of residence, to ensure a uniformly high privacy standard.

11.2 Right to Know / Right to Access

You have the right to request from Delvioo™ information about:

• Which categories of personal information were collected about you
• From which sources the personal information originated
• For which business or commercial purposes the data was collected or disclosed
• To which categories of third parties the personal information was disclosed
• The specific personal information that Delvioo™ has collected about you Terms & Conditions

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Time Period: The disclosure relates to the preceding 12 months. Frequency: You can exercise this right up to twice within 12 months free of charge.

11.3 Right to Delete

You have the right to request deletion of your personal information that Delvioo™ has collected about you.

Self-Service Deletion:

1. Navigate to account settings

2. Select "Delete Account"

3. Confirm by entering your password

After confirmation, all data associated with your account is finally and irrevocably removed from the database. Data recovery is not possible. Exceptions to Right to Delete: Delvioo™ may deny deletion if data retention is necessary for:

• Completing the transaction for which the data was collected
• Detecting security incidents, protecting against fraudulent or illegal activities
• Debugging to identify and fix errors
• Complying with legal obligations (e.g., tax retention periods of 7 years)
• Internal uses reasonably aligned with expectations
• Asserting or defending legal claims

11.4 Right to Correct

You have the right to request correction of inaccurate personal information that Delvioo™ has stored about you.

Self-Service Correction:

• Navigate to account settings

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• Modify the desired information
• Save changes

Correctable Data: Name, Email address, Phone number, Address, Profile picture.

Verification Requirement: When requesting a correction, you must provide specific evidence or documents demonstrating the inaccuracy. The burden of proof lies with the driver. The request must specify the desired changes in detail.

11.5 Right to Limit Use of Sensitive Personal Information

You have the right to direct Delvioo™ to limit the use of your sensitive personal information (SPI) to what is necessary to provide the requested services.

Delvioo™'s SPI Practices:

a) Precise Location Data:

• Location data is used exclusively for order fulfillment, route optimization, status display, geofenced arrival detection, and CullyAI™ proximity features
• No use for advertising purposes or profiling
• Control: You can restrict or revoke location access at any time via your device settings b) Financial Account Information:
• Delvioo™ does not store complete financial data
• Complete financial data is managed exclusively by Stripe c) Tax Data (SSN, TIN):
• Used exclusively to fulfill legal obligations (IRS compliance)
• Stored encrypted by Stripe

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A clearly visible link "Limit the Use of My Sensitive Personal Information" is available in app settings.

IMPORTANT NOTICE: Since precise geolocation is strictly necessary for contract performance, limiting this use would make service provision impossible.

11.6 Right to Opt-Out of Sale or Sharing

Delvioo™ does not currently sell or share personal information under CCPA/CPRA. Therefore, an opt-out is not currently required.

Future Commitment: Should Delvioo™ introduce practices in the future that constitute sale or sharing:

• A clearly visible link "Do Not Sell or Share My Personal Information" will be provided
• You can opt-out at any time without affecting service quality Universal Opt-Out Mechanisms (UOOMs): Delvioo™ commits to respecting Universal Opt-Out Mechanisms such as Global Privacy Control (GPC).

11.7 Right to Data Portability

You have the right to receive the personal information concerning you in a structured, commonly used, and machine-readable format (e.g., JSON, CSV). Contact us using the contact details in Section 16 to request a copy of your data.

11.8 Right to Non-Discrimination

Delvioo™ expressly commits: You will NOT be discriminated against for exercising any of your privacy rights.

This specifically means:

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• Service will not be denied to you
• You will not be offered different prices or compensation
• You will not be provided a lower quality of service
• You will not be treated differently

Exception: Delvioo™ may offer you different terms if that difference is reasonably related to the value your data provides to Delvioo™ .

11.9 Exercising Your Rights

Submitting a Request: You can exercise your privacy rights through the following channels:

• Online Request Portal: https://cultioo.com/en/en_cultioo_business_app_info#privacy
• Email: privacy@cultioo.com
• Mailing Address: Cultioo Inc., Attn: Privacy Rights Department, 8 The Green, Ste A, Dover 19901, United States

Verification Process: To protect the security of your data, Delvioo™ must verify your identity:

1. 2. 3. 4. We match the information you provide with data stored in our records

For sensitive requests (e.g., deletion, access to specific data), additional verification steps may be required

Required Information: You must provide at least your full name, address, date of birth, and driver's license number

You can authorize a representative to submit a request on your behalf (written authorization required)

Response Time: Delvioo™ will process and respond to your request within 45 days of receipt. In complex cases, this period may be extended by an additional 45 days; you will be informed.

Free of Charge: Exercising your privacy rights is free of charge. Terms & Conditions

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12. Data Retention Policy

Delvioo™ stores personal information only as long as necessary to fulfill processing purposes or comply with legal retention requirements.

12.1 Criteria for Retention Period

The duration of data storage is determined by:

• Contractual Necessity: The time period required to maintain the business relationship and provide and settle agreed-upon services
• Legal Statutes of Limitations: Time periods during which Delvioo™ must be able to defend or assert legal claims
• Regulatory Obligations: Specific requirements from U.S. federal agencies (e.g., IRS for tax documents) or states for logistics and financial records

12.2 Specific Retention Periods

Data Category Retention Period

Tax data (W-9/W-8) 7 years

Financial and payout records 4 years

Invoices, bills of lading 4 years

Order and delivery data 4 years

Proof of Delivery records 4 years

Geolocation history 90–180 days after order completion

Identifiers (name, email, address) Until account deletion by driver Communication data 12–24 months

Logs, IP addresses, device IDs 12–24 months

12.3 Special Treatment of Geolocation Data

Precise Location Data is stored only as long as necessary (90 to 180 days) after order completion to enable billing disputes or fraud prevention. After Terms & Conditions

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this period expires, raw data is either securely deleted or anonymized so that it can no longer be associated with the driver.

12.4 Data Integrity and Secure Disposal

Audit Trail: When archiving and transferring data, Delvioo™ must maintain an audit trail to ensure the integrity, reliability, and security of original data. Secure Disposal: After the retention period expires, data is disposed of securely and irrecoverably:

• Electronic media: Irrecoverable deletion or overwriting to ensure no data can be recovered
• Physical documents: Burning or shredding

13. Privacy of Minors

13.1 Children's Online Privacy Protection Act (COPPA)

The Delvioo™ Driver App is directed to an adult audience and is not designed or intended for persons under 18 years of age.

Minimum Age for Drivers:

• Drivers must be at least 18 years old
• Possession of a valid driver's license is required

Commitment: Delvioo™ does not knowingly collect personal information from persons under 18 years of age. If we become aware that we have inadvertently collected personal information from a person under 18, we will take steps to delete that information as soon as possible. Terms & Conditions

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13.2 Parental Notice

Parents or legal guardians are encouraged to contact us if they believe a minor has provided Delvioo™ with personal information.

13.3 Age Verification

Upon registration, drivers must confirm they are at least 18 years old. Driver's license number is used for age verification as part of the 10-stage registration protocol (Stage 04–05).

14. Do Not Track and Tracking Technologies

14.1 Use of Cookies and Tracking Technologies

The Delvioo™ Driver App may use cookies and similar tracking technologies to ensure functionality and improve user experience.

14.2 Types of Tracking Technologies

Type Purpose Legal Basis Duration

Essential

Cookies

Enable basic functions

(e.g., login, session

management)

Contract performance

(necessary for service

provision)

Until session

end or up to 12

months

Analytics

Cookies

Analyze usage to improve

the app

Consent or legitimate

interest Up to 12 months

Functional

Cookies

Remember user

preferences and settings

Consent or legitimate

interest Up to 12 months

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14.3 Cookie Control

You can adjust your cookie settings at any time via app settings or your device. Disabling certain cookies may limit app functionality.

14.4 Do Not Track (DNT) Signals

Current Position: Delvioo™ currently does not honor traditional Do Not Track (DNT) browser signals, as there is no uniform industry standard. Transparency: We disclose that third-party tracking may occur through integrated service providers (e.g., analytics platforms).

14.5 Global Privacy Control (GPC)

Commitment to Honor GPC: In compliance with CCPA/CPRA and other state laws, Delvioo™ commits to recognizing and honoring the Global Privacy Control (GPC) signal as a valid opt-out request for:

• Sale of personal information
• Sharing for cross-context behavioral advertising

Implementation: When we detect a GPC signal from your browser or device, we will treat it as a request to opt-out on that browser/device.

14.6 Third-Party Trackers

The Delvioo™ Driver App may integrate third-party services that use their own tracking technologies:

Examples:

• Google Analytics (analytics)
• Firebase (crash reporting, analytics)
• Stripe (payment processing)

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Control: These third parties have their own privacy policies. You can manage third-party tracking through device privacy settings, browser settings, and third-party opt-out tools.

14.7 Advertising and Marketing

Current Status: Delvioo™ does not currently display third-party advertising within the app.

Future Disclosure: If third-party advertising is introduced, you will be informed and appropriate opt-out mechanisms will be provided.

15. Changes to This Privacy Policy

Delvioo™ reserves the right to update this Privacy Policy from time to time to reflect changes in legislation, business processes, or best practices in privacy.

15.1 Notification of Changes

Material changes to this Privacy Policy will be communicated clearly and conspicuously through:

• In-app notification
• Email to your registered email address
• Prominent notice on our website

15.2 Effective Date

The current version of this Privacy Policy is effective as of January 1, 2026. Terms & Conditions

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15.3 Review Recommendation

We recommend that you periodically review this Privacy Policy to stay informed about how we protect your information.

15.4 Continued Use

Your continued use of the Delvioo™ Driver App after changes to this Privacy Policy constitutes acceptance of the updated terms.

16. Contact Information

For questions, concerns, or to exercise your rights regarding your personal information, you can contact us through the following channels:

16.1 General Inquiries

Cultioo Inc.

A Delaware Corporation

8 The Green, Ste A

Dover, DE 19901

United States of America

Email: support@cultioo.com

16.2 Privacy-Specific Inquiries

Privacy Department

Email: privacy@cultioo.com

16.3 Online Request Portal

https://cultioo.com/en/en_cultioo_business_app_info#privacy

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16.4 Mailing Address

Cultioo Inc.

Attn: Privacy Rights / Legal & Compliance Department

8 The Green, Ste A

Dover, DE 19901

United States of America

16.5 Response Time

Request Type Response Time

Privacy Rights

45 days (may be extended to 90 days for complex requests

Requests

with notification)

General Inquiries 5–7 business days

Last Updated: January 1, 2026 · Version: 1.0

© 2026 Cultioo Inc. All Rights Reserved.

Governing Entity: Cultioo Inc., a Delaware Corporation

Cultioo Scanner App — Terms &

Conditions

Effective Date: January 1, 2026

Version: 1.0

Governing Entity: Cultioo Inc., a Delaware Corporation

Cultioo Inc., a Delaware corporation ("Cultioo," "we," "us," or "our") operates the Cultioo Scanner App ("App"), a professional logistics verification and cargo inspection tool for on-site operators at seller and buyer facilities within the Cultioo agricultural supply chain ecosystem. These Terms and Conditions ("Terms") govern your access to and use of the App. By downloading, installing, registering for, or using the App in any way, you confirm that you have read, understood, and agree to be bound by these Terms in their entirety. If you do not agree, you must immediately cease all use of the App.

Table of Contents

1. Scope and Application

2. Company Information

3. Definitions

4. Description of the Service

5. Account Registration and Requirements

6. Group Membership and Role-Based Access

7. Permitted and Prohibited Use

8. Operator Responsibilities and Professional Conduct

9. Verification Workflows — Seller Side (Orders Tab)

10. Verification Workflows — Buyer Side (Scanner Tab)

11. Multi-Section Vehicle Operations

12. Chain of Custody and Data Integrity

13. Department and Gate Management

14. Intellectual Property

15. Disclaimer of Warranties

16. Limitation of Liability

17. Indemnification

18. Termination and Suspension

19. Modifications to the Service

20. Governing Law and Dispute Resolution

21. Miscellaneous Provisions

22. Contact Information

1. Scope and Application

1.1 Scope

These Terms govern the access to and use of the Cultioo Scanner App on iOS and Android platforms, including all features, updates, and services provided through the App. The App functions as the physical-world verification layer of the Cultioo ecosystem, enabling operators to execute gate-level cargo verification, driver authentication, weight recording, compliance documentation, and digital Chain of Custody management.

1.2 Target Users

The App is designed exclusively for professional use by on-site operators at agricultural, food-grade, and logistics facilities participating in the Cultioo network. It is not a consumer product. Typical users include:

• Gate operators at seller facilities responsible for outbound cargo pickup management (Orders Tab)
• Gate operators at buyer facilities responsible for inbound delivery acceptance and verification (Scanner Tab)
• Facility managers and compliance officers overseeing logistics gate operations
• Operators working across both seller and buyer facilities simultaneously

1.3 Relationship to Other Cultioo Terms

These Terms apply specifically to the Cultioo Scanner App. Users who also access the Cultioo Business App (for sellers, drivers, and administrators) or the Cultioo App (for buyers) are additionally subject to the terms applicable to those platforms. In the event of a conflict, the terms specific to the applicable platform shall prevail.

1.4 Acceptance

Acceptance occurs upon any of the following: completing the registration process, tapping any "I Agree" or equivalent consent mechanism within the App, or commencing use of any feature of the App. Acceptance is binding on both the individual user and, where applicable, the legal entity on whose behalf the user acts.

2. Company Information

Cultioo Inc.

A Delaware Corporation

8 The Green, Ste A

Dover, DE 19901

United States of America

Legal Contact: legal@cultioo.com

Support: support@cultioo.com

Privacy: privacy@cultioo.com

Website: www.cultioo.com

3. Definitions

The following definitions apply throughout these Terms:

"App" — The Cultioo Scanner App, including all features, workflows, data systems, and updates made available on iOS and Android platforms. "Operator" — An individual user of the App who is employed by or authorized to act on behalf of a seller or buyer facility registered within the Cultioo ecosystem.

"Seller Group" — An organizational unit within the Cultioo platform representing a seller facility. Membership activates the Orders Tab and the full outbound cargo verification workflow.

"Buyer Group" — An organizational unit within the Cultioo platform representing a buyer facility. Membership activates the Scanner Tab and the full inbound delivery verification workflow.

"Group Founder" — The administrative account holder who created a Seller Group or Buyer Group and holds the highest level of authority within that group, as managed through the Cultioo Business App.

"Group Host" — A delegated administrative role within a group, enabling decentralized management across facility departments while the Founder retains ultimate authority.

"Order" — A confirmed commercial transaction within the Cultioo marketplace, requiring physical logistics execution and gate-level verification by Operators on both the seller and buyer sides.

"QR Code" — The order-specific machine-readable code displayed within the Cultioo Delvioo™ driver app, used to authenticate the driver and initiate formal gate check-in and check-out sequences at both seller and buyer facilities.

"Security Code" — The alphanumeric secondary authentication credential linked to a specific Order, verbally requested by the Operator from the driver at the gate as part of the dual-authentication protocol. "Chain of Custody Record" — The complete, chronological, tamper-evident digital record of all verification events, weight measurements, photographs, temperature readings, compliance documents, digital signatures, and timestamps associated with a specific Order, permanently stored in the Cultioo database.

"Delivery Note" — The automated digital document generated by the App upon completion of the seller-side check-out workflow, populated with verified cargo data, net weight, batch information, compliance documents, and digital signatures, and immediately distributed to all parties. "Delvioo™"

— The dedicated logistics and driver platform integrated within the Cultioo Business App, used by professional transport operators to accept, bid on, and execute deliveries verified through the Scanner App. "CullyAI™"

— The artificial intelligence logistics optimization and anomaly detection system integrated within the Cultioo platform, used to detect weight deviations between ordered quantity, seller net weight, and buyer net weight, and to surface transport opportunities to drivers. "Plombe / Seal" — A physical tamper-evident security seal applied to the load compartment doors or access points of a vehicle after loading is confirmed. The seal number is entered into the App, transmitted to the buyer-side Operator, and cross-referenced upon arrival to verify chain-of- custody integrity.

"Tare Weight" — The weight of the empty vehicle measured on the facility scale before loading commences. Used as the baseline for net load calculation.

"Gross Weight" — The weight of the fully loaded vehicle measured on the facility scale after loading is complete (seller side) or upon arrival before unloading (buyer side).

"Net Weight" — The calculated actual cargo quantity: Gross Weight minus Tare Weight. Constitutes the legally binding delivery weight for invoicing and dispute resolution.

"Department" — A named gate, loading bay, or facility section configured within the App by the Operator, which serves as the selectable gate assignment presented at the start of each check-in workflow.

"Personal Protective Equipment (PPE)" — Safety equipment required of drivers at food-grade loading facilities, including high-visibility vests and safety footwear.

4. Description of the Service

4.1 Platform Overview

The Cultioo Scanner App is the physical-world verification layer of the Cultioo ecosystem. It converts any standard iOS or Android device into a professional logistics inspection terminal, enabling operators to verify drivers, authenticate cargo, manage gate timing, and generate immutable digital records — with zero proprietary hardware investment.

Every delivery processed through the Cultioo network passes through a certified on-site Operator before cargo changes hands. The Operator verifies the driver's credentials, validates the cleaning certificate, confirms product weight, and executes the dual QR-code handshake that opens and closes each logistics cycle. This creates an unbroken, auditable Chain of Custody from seller gate to buyer facility.

4.2 Core Features

The App provides the following core operational capabilities:

• Home Tab: Real-time operational dashboard displaying trucks currently checked in, trucks within the facility geofence territory, and total orders scanned at the facility.
• Scanner Tab (Buyer Groups): Active QR Code scanning interface and Deliveries list for managing inbound delivery acceptance workflows.
• Orders Tab (Seller Groups): Live order list and outbound verification workflow for managing driver pickup and cargo dispatch.
• Department Management: Configuration of named gates, loading bays, and facility sections that serve as selectable gate assignments during check-in.
• Account Management: Profile management, group membership management, and app settings.

4.3 Tab Activation Logic

The Scanner Tab and Orders Tab remain locked until the Operator has joined at least one group using the 8-digit invitation code provided by the Group Founder. Full access is granted immediately upon valid code entry. The App supports simultaneous membership in one Seller Group (unlocking Orders Tab) and one Buyer Group (unlocking Scanner Tab), enabling dual- role operation from a single account.

5. Account Registration and Requirements

5.1 Registration Requirement

Use of the App requires the creation of a verified Cultioo account. You must provide accurate, complete, and current information during registration, including your full legal name, a valid email address, and a secure password. Cultioo reserves the right to refuse registration or terminate accounts based on false, misleading, or incomplete information.

5.2 Authentication Options

The App supports the following authentication methods:

• Email/Password Registration: Standard account creation with 8- digit email verification code activation.
• Google Login: One-tap authentication via Google account — no separate password required.
• Apple Login: One-tap authentication via Apple ID — compatible with Face ID and Touch ID for frictionless gate-side access.

5.3 Credential Recovery

If you forget your username or password, account recovery requires only your registered email address. A time-limited 8-digit security code is dispatched to that address. Upon valid code entry, you may reset your password or retrieve your username. No additional verification steps are required. Upon password reset, all prior active sessions are immediately and irreversibly invalidated.

5.4 Password Security

You are solely responsible for maintaining the confidentiality of your account credentials. You must not share your password with any other person. You must notify Cultioo immediately at support@cultioo.com upon becoming aware of any unauthorized access to your account.

5.5 Minimum Age

You must be at least 18 years of age to register for and use the App. By registering, you represent and warrant that you meet this requirement.

6. Group Membership and Role-Based Access

6.1 Group Types

Seller Group: Membership activates the Orders Tab and grants access to all outbound cargo verification workflows for that facility's active orders. The Operator performs check-in and check-out of Delvioo™ drivers collecting orders for delivery to buyers.

Buyer Group: Membership activates the Scanner Tab and grants access to all inbound delivery verification workflows for deliveries arriving at that facility from Delvioo™ drivers.

6.2 Operator Role Limitations

Operators may join existing groups using the invitation code but may not create new groups. Group creation is reserved for Admin-level accounts within the Cultioo Business App. Operators have no access to:

• Financial data, revenue figures, or invoices
• Group administration settings or invitation code management
• Listing management or product publishing functions
• Other Operators' personal account data

6.3 Multiple Group Memberships

An Operator may hold one active Seller Group membership and one active Buyer Group membership simultaneously. Joining a new group of the same type requires leaving the existing group, which immediately revokes access to that group's operational data within the App.

6.4 Revocation of Group Access

Group access may be revoked at any time by the Group Founder or authorized Admin via the Cultioo Business App. Access is also immediately revoked if the Operator leaves the group via Account Settings. Upon revocation, all operational records generated by the Operator while a group member remain permanently stored in the Cultioo database as part of the immutable Order records.

7. Permitted and Prohibited Use

7.1 Permitted Use

The App is licensed to you on a limited, non-exclusive, non-transferable, revocable basis solely for professional internal use in connection with logistics verification and cargo inspection at authorized facilities within the Cultioo ecosystem. Permitted uses include:

• Authenticating Delvioo™ drivers at facility gates using QR Code and Security Code verification
• Executing inbound and outbound cargo check-in and check-out workflows
• Recording and uploading cargo weights, photographs, batch data, temperature measurements, seal numbers, and compliance documents
• Managing gate and loading bay assignments and facility department configurations
• Reviewing and managing active orders assigned to your facility
• Configuring and maintaining the Department section with facility gate names and section assignments

7.2 Prohibited Use

You agree not to use the App for any of the following:

• Accessing, scanning, or verifying orders for which you are not an authorized Operator
• Falsifying, manipulating, or deliberately entering inaccurate verification data of any kind, including weights, photographs, batch numbers, temperatures, seal numbers, or compliance documents
• Bypassing, circumventing, or tampering with the QR Code or Security Code dual-authentication mechanism
• Applying or recording seal numbers that do not correspond to physically applied, genuine tamper-evident seals
• Reverse engineering, decompiling, disassembling, or creating derivative works based on the App
• Using the App for any illegal purpose or in violation of applicable food safety, transport compliance, or data protection laws
• Sharing account credentials with unauthorized individuals or permitting third-party access under your identity
• Introducing malicious code, viruses, or any software interfering with App functionality or security
• Commercially reselling, sublicensing, or redistributing access to the App

8. Operator Responsibilities and Professional

Conduct

8.1 Accuracy of Recorded Data

You are solely responsible for the accuracy, completeness, and truthfulness of all data you enter, photograph, upload, or confirm within the App. This includes without limitation:

• Vehicle tare and gross weights
• Batch numbers, production dates, best-before dates, and storage numbers
• Temperature measurements (departure and arrival)
• Seal numbers and seal condition assessments
• Hygiene inspection results and PPE compliance records
• Pre-loading and post-loading damage assessments and photographs
• Compliance document uploads

Deliberately entering false, inaccurate, or misleading data constitutes a material breach of these Terms and may give rise to civil liability and, where applicable, criminal prosecution.

8.2 Weight Verification Obligations

All weight entries must be measured on a properly calibrated, legally compliant scale. CullyAI™ deviation alerts are automated indicators only and do not replace your professional obligation to investigate weight discrepancies. If a CullyAI™ deviation alert is triggered, you must not proceed with check-out until the discrepancy has been investigated and resolved or formally documented.

8.3 Seal Application and Recording

Where your workflow requires physical seal application, you must physically apply a genuine, unbroken tamper-evident seal to all designated load compartment access points before entering the seal number in the App. Entering a seal number without applying a physical seal, or knowingly entering an incorrect seal number, constitutes a material breach of these Terms and falsification of the Chain of Custody Record.

8.4 Digital Signature Obligations

By applying your digital signature within the App, you certify that all data recorded during the relevant check-out workflow is accurate, complete, and truthfully reflects the physical condition and specification of the cargo at the point of dispatch or acceptance. Your digital signature constitutes a legally binding attestation. You must not apply your digital signature if you are aware of any material inaccuracy in the recorded data.

8.5 Regulatory Compliance

You are responsible for ensuring that all verification activities conducted through the App comply with all applicable federal, state, and local laws and regulations, including food safety laws (FSMA, FDA guidelines), temperature chain requirements, weight and measure laws, transport compliance regulations (DOT, FMCSA, ADR), and applicable occupational safety standards.

8.6 PPE Enforcement

Where your facility's policies or applicable regulations require drivers to wear PPE (high-visibility vest, safety footwear), you are responsible for enforcing this requirement before proceeding with check-in. Non- compliance must be recorded in the App. Cultioo does not assume liability for PPE enforcement failures at individual facilities.

9. Verification Workflows — Seller Side (Orders

Tab)

9.1 Overview

The Orders Tab is the outbound cargo management interface used by Operators at seller facilities to manage the pickup process for Delvioo™ drivers collecting orders on behalf of buyers. This tab is activated upon joining a Seller Group.

9.2 Orders List View

The Orders Tab displays a real-time list of all active orders assigned to the facility, sorted by scheduled driver arrival time. Each order entry displays current status (Awaiting Driver → Driver Assigned → Driver En Route → In Territory → At Gate → Checked In → Loading → Departed), ETA calculated from the driver's GPS position, driver name, vehicle type, license plate, vehicle section capacity, order summary (product, volume, weight, Incoterms), and Cleaning Certificate status.

Orders where the driver has declared Arrived status but has not yet been checked in are highlighted with the live elapsed detention time.

9.3 Stage 1 — Check-In (Driver Arrives, Vehicle Empty)

Before the QR Code is displayed to the driver, the Operator must complete the following verification steps. The driver cannot begin loading until the QR handshake is confirmed.

Step 1 — Gate & Department Assignment

Before any verification begins, the Operator selects the gate or loading bay the driver should proceed to from the list of pre-configured facility Departments. New sections can be added directly from this interface. The assigned gate is transmitted instantly to the driver's Delvioo™ app upon check-in confirmation.

Step 2 — Driver & Vehicle Identity Verification

The Operator visually compares the driver's face against the verified KYC profile photo from the Delvioo™ record. The vehicle license plate is scanned (barcode/QR) or manually entered and cross-referenced against the plate registered to this order. Mismatch blocks check-in and triggers an alert to seller admin and buyer admin. Vehicle type is confirmed against the Transport Matrix requirements.

Step 3 — PPE Compliance Check

The Operator visually confirms the driver is wearing a high-visibility vest and safety footwear. Non-compliance is recorded with a timestamp in the permanent order file. Check-in is blocked until PPE compliance is confirmed.

Step 4 — Vehicle Type Suitability Check

For temperature-sensitive cargo: the Operator confirms the vehicle is a refrigerated unit and that the cooling aggregate is actively running at the correct pre-load temperature. Compartment type is confirmed against cargo specification (grain-tight hopper for bulk grain, tanker for liquids, flatbed with curtain for palletized goods). For multi-section vehicles: the designated section for this order is confirmed.

Step 5 — Load Compartment Hygiene Inspection

The Operator opens and inspects the loading compartment. Surfaces must be clean, dry, and free of debris, residue, or contamination from prior cargo. Odor-free confirmation is required for food-grade cargo. Moisture and condensation on walls and floors are checked — critical for dry bulk agricultural products (grain, seeds, pulses). Residue from incompatible prior cargo (chemicals, allergens, non-food materials) triggers check-in blockage. Result recorded as Pass ✅ / Fail ❌ with timestamp.

Step 6 — Cleaning Certificate Validation

The App displays whether a Cleaning Certificate is mandatory for this cargo type. Digital certificate status is shown as Valid ✅ / Missing ❌ / Expired ⚠. If required and missing: check-in is blocked until the driver submits a valid certificate through the Delvioo™ app.

Step 7 — Pre-Loading Damage Inspection

The Operator performs a visual inspection of the vehicle's exterior and trailer. The load compartment interior is inspected for pre-existing damage. 2–3 photographs are taken before any loading activity begins,

timestamped and geotagged, stored in the permanent order record, and transmitted to the buyer-side Operator for direct before/after comparison upon arrival.

Step 8 — Tare Weight (Empty Vehicle)

The Operator enters the weight of the empty vehicle as measured on the facility scale before loading. The scale identifier or scale number may also be entered for audit and calibration traceability. This value is locked in the order record upon confirmation and cannot be modified after check-in is completed.

Step 9 — Arrival Timestamp

The system automatically captures the exact time of the driver's gate check-in. If the driver was already waiting before check-in, the detention timer that started at their Arrived declaration measures the total elapsed waiting time, used for automated detention billing.

Step 10 — QR Code Check-In Confirmation

Once all steps are confirmed, the Operator taps Display QR Code. The order-specific QR Code is displayed on the operator's screen. The driver scans the QR Code with the Delvioo™ app. Digital handshake confirmed — loading sequence officially begins. Detention timer stops, total elapsed detention time is recorded. Gate number, loading bay position, and weighing instructions are transmitted to the driver's app. Order status advances to Loading.

9.4 Stage 2 — Check-Out (Vehicle Loaded, Ready for Departure)

The check-out stage generates the complete digital cargo dispatch record. All data entered becomes part of the permanent, immutable Chain of Custody Record.

Step 1 — Gross Weight (Loaded Vehicle)

The Operator enters the weight of the fully loaded vehicle as measured on the facility scale after loading. The scale identifier is recorded. Value is locked upon confirmation. Cross-referenced at the buyer facility against the gross weight measured upon arrival, enabling detection of in-transit cargo loss or unauthorized unloading.

Step 2 — Net Weight Calculation & CullyAI™ Alert

The system automatically calculates Net Load = Gross Weight − Tare Weight. This is the legally binding delivery weight for invoicing, customs documentation, and dispute resolution. CullyAI™ automatically compares the net weight against the original order quantity. If the deviation exceeds the defined threshold: instant alert to operator, seller admin, and buyer. The Operator must confirm or dispute the deviation before check-out can proceed.

Step 3 — Batch & Compliance Data Entry

The Operator enters the following data, all transmitted to the buyer-side Operator and permanently stored:

• Production Date: Date the goods were produced or harvested
• Best Before / Expiry Date: Shelf life endpoint of the product
• Batch Number: Unique identifier for this specific production batch — enables full product traceability and recall capability
• Storage Number: Warehouse or storage unit identifier confirming physical dispatch location
• Notes: Optional handling instructions, special requirements, or observations

Step 4 — Temperature Protocol (Cold Chain Cargo)

Applies to all refrigerated, chilled, or frozen shipments. The Operator measures the temperature inside the load compartment and at the cargo core immediately before sealing. This departure temperature is transmitted to the buyer-side Operator and displayed on arrival alongside the buyer's arrival measurement, enabling instant identification of in-transit cold chain failures. If outside the defined range: CullyAI™ alert generated — operator must confirm or reject the shipment before check-out proceeds. The cooling aggregate running status and target temperature are recorded. Step 5 — Load Security Confirmation

The Operator confirms that all cargo is secured in accordance with applicable transport regulations (load straps, blocking bars, anti-slip matting, or other securing methods). From the moment this confirmation is recorded, liability for load security transfers to the driver. Pallet stability and ADR/DOT hazardous material compliance (markings, placards,

documentation) are also confirmed where applicable.

Step 6 — Photo Documentation

2–3 photographs of the loaded cargo inside the compartment are taken, capturing pallet condition, product state, load security configuration, and overall compartment fill. Photos must clearly show: cargo condition, load securing equipment in place, and the sealed compartment if applicable. The Operator cannot proceed until the minimum photo requirement is met. Photos are timestamped, geotagged, and permanently stored as legally attributable proof of cargo condition at dispatch.

Step 7 — Seal Number (Plombe)

After loading and compartment closure, the Operator physically applies a tamper-evident security seal to the load compartment doors. The seal number printed on the physical seal is scanned (barcode/QR) or manually entered. The entered seal number is immediately transmitted to: the buyer- side Operator's Deliveries list, the driver's order details screen, and the permanent order record. If the seal number on arrival at the buyer facility does not match, the buyer-side check-in is automatically blocked and a tamper event is recorded with full evidence.

Step 8 — Document Upload

The Operator uploads all required compliance documents:

• Organic Certification (required for certified organic cargo)
• Origin Certificate (required for cross-border shipments)
• Analysis Reports (moisture content, protein percentage, pesticide residue, microbiological testing)
• Bill of Lading (auto-populated from order data, operator confirms or amends)
• Other compliance documents required by cargo type, buyer requirements, or applicable regulations

The App displays a completeness checklist of all required documents. Check-out cannot be completed until all mandatory documents are uploaded or explicitly flagged as unavailable with a recorded reason. Step 9 — Automated Digital Delivery Note

Upon completion of all check-out steps, the system automatically generates the Digital Delivery Note populated with: verified net weight, batch data, production and expiry dates, Incoterms, seller and buyer identity, driver identity, vehicle details, departure timestamp, and seal number. The Operator reviews the auto-generated note before signing. Upon departure confirmation, distributed simultaneously to: buyer (order record), driver (active order), seller admin (Business App), and permanently archived in the immutable order record.

Step 10 — Digital Signatures

The seller-side Operator signs digitally on the device screen, certifying that all check-out data is accurate and reflects the true condition of the cargo at dispatch. This constitutes the seller's formal release of the cargo under the agreed Incoterms — the legal point of risk transfer from seller to carrier. The driver signs immediately after — formally accepting the cargo as documented. Refusal to sign by either party blocks check-out, opens a dispute record, and notifies all parties.

Step 11 — Departure QR Scan & Authorization

Both signatures confirmed — Operator taps Authorize Departure. Final order-specific QR Code displayed on the operator's screen. Driver scans QR Code. Order status advances to In Transit. Driver's Delvioo™ navigation activates toward the buyer facility. Seal number, dispatch photos, batch data, and Delivery Note transmitted to the buyer-side Operator. Departure timestamp recorded permanently. Transit time tracking begins — ETA calculated and displayed to the buyer-side Operator.

10. Verification Workflows — Buyer Side (Scanner

Tab)

10.1 Overview

The Scanner Tab is the inbound delivery verification interface used exclusively by Operators at buyer facilities to authenticate arriving Delvioo™ drivers, inspect cargo upon arrival, and formally close delivery orders. Activated upon joining a Buyer Group.

10.2 Scanner Sub-Page

The Scanner sub-page is the primary gate-side tool. The Operator activates the device camera full-screen and points it at the driver's order- specific QR Code displayed in the Delvioo™ driver app.

Data Displayed Immediately After QR Scan:

Data Point Source Purpose

Driver Full Name Delvioo™ KYC

record Verbal identity confirmation

Driver Profile Photo Delvioo™ KYC

record

Visual cross-reference against

physical driver

License Plate Order

Must match physical vehicle

assignment

exactly

Order ID Order record Reference for all documentation

Data Point Source Purpose

Product Type Order record Cross-reference against physical

delivery

Cross-reference against physical

Declared Volume Order record

delivery

Declared Weight Seller net weight Baseline for buyer-side weighing Security Code Order record Verbally requested from driver —

dual-authentication

Cleaning Certificate

Status

Order record Valid ✅ / Missing ❌

Seal Number

(Seller)

Departure

Temperature

Seller check-out

record

Cross-reference against physical

seal on vehicle

Seller check-out

record

Comparison baseline for arrival

temperature

Detention Timer Live system Stops upon confirmed check-in

Seal Integrity Check:

The seal number from the seller's check-out record is displayed prominently. The Operator reads the physical seal number on the vehicle and enters it into the App.

• Match ✅ — Seal intact. Check-in proceeds.
• Mismatch ❌ — Tamper event detected. Check-in blocked immediately. Automated alert to buyer admin, seller admin, and driver fleet admin. Dispute record opened. No unloading until resolved.
• Missing ⚠ — No seal present despite one recorded at dispatch. Buyer admin notified. Absence permanently recorded.

Check-In Confirmation:

Once QR scan is confirmed, the Check-In function is unlocked — allowing the Operator to enter and verify additional information before formally authorizing the driver's entry. Confirming check-in: stops the detention timer, transmits unloading instructions (bay assignment, unloading position, weighing sequence) to the driver's app, advances order status to Checked In at Buyer Facility.

10.3 Deliveries Sub-Page

The Deliveries sub-page provides a real-time overview of all inbound orders expected at the facility, including status, ETA, detention alerts, and quick-scan access.

10.4 Stage 1 — Check-In (Driver Arrives, Vehicle Still Loaded)

Step 1 — Driver & Vehicle Identity

Operator visually compares the driver's face against the KYC profile photo. License plate is scanned or manually entered and cross-referenced against the plate registered to this order. Mismatch blocks check-in. Security Code is verbally requested from the driver and confirmed. Step 2 — Seal Integrity Verification

Operator confirms the physical seal is present, scans or enters the seal number, and confirms the seal is intact and undamaged. A mismatch or tamper triggers immediate block and dispute record. A broken seal — even with a matching number — is flagged and recorded.

Step 3 — Arrival Vehicle Condition

Visual inspection of the vehicle and trailer for any new damage. The App displays the pre-loading damage photos taken at the seller facility — the Operator compares directly. Any new damage is photographed, described, and logged, creating a timestamped before/after transit damage record. Step 4 — Temperature Verification (Cold Chain)

Applies to all refrigerated, chilled, or frozen shipments. Operator measures the load compartment temperature before fully opening the doors. The App displays the seller's departure temperature alongside the buyer's arrival measurement. Breach outside the defined range triggers an immediate alert. Severe breach enables formal shipment rejection — payment automatically held.

Step 5 — Cleaning Certificate Validation

App displays whether a valid Cleaning Certificate was submitted for this order. Operator confirms the physical certificate matches the digital record. Discrepancy is flagged and permanently recorded.

Step 6 — Check-In Confirmation

Operator taps Confirm Check-In. Detention timer stops — total elapsed time recorded. Unloading instructions transmitted to driver's app. Order status advances to Unloading. Check-in timestamp recorded permanently.

10.5 Stage 2 — Check-Out (Vehicle Unloaded, Departure

Authorization)

Step 1 — Gross Weight (Arrival)

Operator enters the gross weight of the fully loaded vehicle on the buyer's facility scale upon arrival — before unloading. Cross-referenced against the seller's departure gross weight. Significant deviation flags potential in- transit loss, unauthorized unloading, or weighing discrepancy. Step 2 — Tare Weight (Post-Unload)

Operator enters the weight of the empty vehicle after unloading. Cross- referenced against the seller's tare weight. Significant difference flags potential vehicle modification or measurement error.

Step 3 — Net Weight & CullyAI™ Three-Point Alert

System calculates: Gross (arrival) − Tare (post-unload) = Net Weight Received. CullyAI™ simultaneously compares three values: ordered quantity, seller net weight dispatched, and buyer net weight received.

• Within tolerance ✅ — Logged, no action required.
• Minor deviation ⚠ — Alert sent to all parties. Manual confirmation required before payment release.
• Significant deviation ❌ — Payment automatically held. Dispute record opened. All parties notified immediately.

Step 4 — Cargo Condition Documentation

2–3 photographs of the unloaded cargo capturing pallet condition, product state, packaging integrity, and any visible damage — displayed alongside seller dispatch photos for direct before/after comparison. Operator selects condition: Good ✅ / Damaged ⚠ / Rejected ❌. Partial rejection supported: accepted and rejected quantities specified separately. Rejected quantities automatically excluded from the payment release calculation.

Step 5 — Batch & Compliance Verification

Production Date, Best Before / Expiry Date, and Batch Number are displayed from the seller record. For packaged or palletized goods: operator confirms each value matches the physical markings on packaging and pallets. For bulk goods (grain, oil, liquids, and other unpackaged agricultural products): no physical batch markings exist — verification is conducted exclusively against the digital seller record, the automated Delivery Note, and accompanying analysis reports or certificates. All required compliance documents are displayed for verification. Missing or mismatched documents are flagged — buyer admin notified, payment can be held. Step 6 — Delivery Note Reconciliation

System automatically reconciles the buyer's inbound receipt record against the seller's Delivery Note. If deviations exist, a discrepancy summary is auto-generated. A unified final Delivery Note is generated reflecting actual received quantity, confirmed condition, and all cross-referenced data points.

Step 7 — Digital Signatures

Buyer Operator signs digitally — formal acceptance of the cargo as documented, triggering payment release from escrow for the accepted quantity. Driver signs — confirms delivery completion and closes transport liability. Refusal to sign by either party: payment held, dispute record remains open.

Step 8 — Departure Authorization

Operator taps Authorize Departure. Final QR Code displayed — driver scans to confirm departure. Order status → Completed. Seller payment released from escrow (for accepted quantity). Driver earnings credited. All parties receive automated completion notification. Full transaction record permanently archived — immutable.

11. Multi-Section Vehicle Operations

11.1 Overview

A Delvioo™ driver may operate a vehicle divided into multiple independent load compartments (sections). Each section is registered independently in the driver's vehicle profile and can carry a separate order assigned to a different buyer. This enables Less Than Truckload (LTL) optimization.

11.2 Supported Scenarios

Scenario Description

Single Section Standard workflow — one section, one buyer, one complete independent dispatch record

Multiple

Sections,

Multiple

Orders

Driver arrives with 2+ sections pre-assigned to different

buyers. Each section has its own independent check-out

workflow in a single gate visit

Order Split

Mixed Load

Driver's section capacity is insufficient for the full order.

Accepted quantity is dispatched. Remaining quantity is

automatically separated and published as a new

independent order on the Delvioo™ marketplace

Different product types in different sections (e.g., grain in

Section 1, sunflower oil in Section 2), each with independent

requirements, temperatures, hygiene standards, and

compliance documentation

11.3 Check-In for Multi-Section Vehicles

Check-in begins at vehicle level: driver identity, PPE, arrival condition, and tare weight are verified once for the whole vehicle. Section-level verification (suitability, hygiene, cleaning certificate, pre-loading photos) is conducted independently per section. A failed section does not block the check-out of a compliant section. The single check-in QR scan covers the full vehicle visit — all active sections advance to Loading status simultaneously.

11.4 Check-Out — Independent Per Section

Each section has its own fully independent check-out workflow. The Operator selects a section from the occupancy display and completes the full workflow for that section before moving to the next. Each section independently produces: gross weight, net weight with CullyAI™ alert, batch data, temperature record, load security confirmation, dispatch photos, its own unique seal number, compliance documents, automated Delivery Note, digital signatures, and dedicated QR departure scan. The vehicle may only depart after all active sections have completed their individual QR departure scans.

11.5 Independent Seal per Section

Each section receives its own physical tamper-evident seal applied to its access point. The seal number is entered and transmitted per section to the corresponding buyer-side Operator. A tamper event in one section does not affect other sections — each section's chain of custody is completely independent.

11.6 Order Split Workflow

When a driver's section capacity is insufficient, the Operator confirms the accepted quantity. The system calculates the remaining quantity, automatically separates it from the original order, and publishes it as a new independent order on the Delvioo™ marketplace with identical product specifications and delivery requirements. The buyer is notified in real time. When the second driver arrives for the split order, a completely independent check-in and check-out workflow is processed.

12. Chain of Custody and Data Integrity

12.1 Immutability

Once the final QR departure scan has been executed and the check-out workflow is complete, the Chain of Custody Record for that Order is permanently sealed and cannot be modified or deleted by any party, including Cultioo employees, Group Founders, or Operators. This immutability is a core security and legal protection feature of the platform.

12.2 Tamper Detection

The App's seal verification mechanism compares the seal number entered by the buyer-side Operator against the seal number recorded by the seller-side Operator at dispatch. A mismatch automatically blocks check- in and opens a dispute record with full timestamp, photographic, and identity evidence. This tamper detection mechanism is a technical safeguard and does not guarantee detection of all instances of cargo interference.

12.3 Dispute Records

Automated dispute records are created in response to: seal number mismatches, cold chain temperature breaches, CullyAI™ significant weight deviations, missing compliance certificates, and rejected check-in or check-out signatures. Dispute records form part of the permanent Order record and are accessible to all authorized parties. Resolution of disputes is the responsibility of the relevant commercial parties.

12.4 Legal Status of Digital Records

The Chain of Custody Record, Digital Delivery Note, and digital signatures generated through the App are produced on the basis of data entered by the Operator. Cultioo makes no representation as to the legal validity or enforceability of these records under any particular jurisdiction. You are advised to consult legal counsel regarding the legal standing of digital logistics documentation in your applicable jurisdiction.

13. Department and Gate Management

13.1 Departments Sub-Page

The Departments Sub-Page (within the Orders Tab) allows Operators to define and manage the named gates, loading bays, and facility sections at their facility. These entries form the selectable options presented at the start of each check-in workflow.

13.2 Gate Configuration

Operators can enter the names of all active gates and loading positions (e.g., Gate A, Bay 3, Cold Storage Entrance). New sections can be added at any time from the check-in interface or from the Departments Sub-Page — no system restart required.

13.3 List Import and Export

Department and gate lists can be imported in bulk or exported for use across multiple facilities or for administrative record-keeping and audit purposes.

14. Intellectual Property

14.1 Ownership

The App, including its source code, design, user interface, technology, algorithms, CullyAI™ system, QR authentication framework, and all associated intellectual property rights, is the exclusive property of Cultioo Inc. and is protected by United States and international intellectual property laws. Nothing in these Terms transfers any ownership interest to you.

14.2 License Grant

Subject to your compliance with these Terms, Cultioo grants you a limited, non-exclusive, non-transferable, revocable license to install and use the App on devices you own or control, solely for the professional purposes described in Section 7.1.

14.3 Trademarks

"Cultioo," "Delvioo™," "CullyAI™," "Monioo™," and associated logos and marks are trademarks of Cultioo Inc. You may not use these marks without prior written consent. All other trademarks referenced in the App are the property of their respective owners.

14.4 Feedback

If you submit feedback or suggestions, you grant Cultioo a perpetual, irrevocable, royalty-free license to use and incorporate such feedback into any Cultioo product or service, without obligation of confidentiality or compensation.

15. Disclaimer of Warranties

THE APP IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTY OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED BY LAW, CULTIOO DISCLAIMS ALL WARRANTIES, INCLUDING:

• Any implied warranty of merchantability, fitness for a particular purpose, or non-infringement
• Any warranty that the App will be uninterrupted, error-free, or secure
• Any warranty that automated mechanisms (including CullyAI™) will detect all cargo discrepancies, fraud, or compliance failures
• Any warranty as to the legal validity or enforceability of digital delivery notes, digital signatures, or Chain of Custody records under any particular jurisdiction

The use of the App in connection with regulated activities does not relieve you of independent legal compliance obligations.

16. Limitation of Liability

16.1 Exclusion of Indirect Damages

TO THE MAXIMUM EXTENT PERMITTED BY LAW, CULTIOO SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING LOSS OF PROFITS, LOSS OF DATA, SYSTEM FAILURE, OR COST OF SUBSTITUTE SERVICES.

16.2 Cap on Direct Damages

CULTIOO'S TOTAL AGGREGATE LIABILITY SHALL NOT EXCEED THE GREATER OF (A) THE AMOUNT PAID TO CULTIOO IN THE TWELVE MONTHS PRECEDING THE CLAIM, OR (B) ONE HUNDRED US DOLLARS ($100.00).

16.3 Essential Basis

These limitations reflect a reasonable allocation of risk and are an essential element of the agreement between Cultioo and you.

17. Indemnification

You agree to defend, indemnify, and hold harmless Cultioo Inc. and its officers, directors, employees, agents, licensors, and service providers from any claims, liabilities, damages, or fees (including attorneys' fees) arising from:

• Your violation of these Terms
• Your violation of any applicable law or third-party right
• Any inaccurate, false, or misleading data entered through the App by you
• Any claim by a third party arising from verification activities performed by you
• Any unauthorized access to the App facilitated by your disclosure of credentials

18. Termination and Suspension

18.1 Termination by You

You may delete your account at any time via Account Settings → Delete Account. Password confirmation is required. Deletion is immediate and irreversible. Your personal account data will be removed in accordance with the Privacy Policy, subject to legal retention obligations for Chain of Custody Records.

18.2 Termination or Suspension by Cultioo

Cultioo may suspend or terminate your access, with or without notice, for:

• Material or repeated breach of these Terms
• Fraudulent or deliberately falsified use of any verification workflow
• Activity creating legal, regulatory, or reputational risk
• Receipt of a court order or law enforcement directive
• Cessation of the App service

18.3 Effect of Termination

Upon termination, your license is immediately revoked. Sections 14 (IP), 15 (Disclaimer), 16 (Liability), 17 (Indemnification), 20 (Governing Law), and 21 (Miscellaneous) survive termination.

19. Modifications to the Service

Cultioo may modify, update, suspend, or discontinue the App or any feature at any time. Where modifications materially affect your use, Cultioo will endeavor to provide advance notice via in-app notification or email.

20. Governing Law and Dispute Resolution

20.1 Governing Law

These Terms are governed by the laws of the State of Delaware, United States, without regard to conflict of law provisions.

20.2 Binding Arbitration

Any dispute arising from these Terms shall be resolved by binding individual arbitration administered by the American Arbitration Association (AAA) in Dover, Delaware.

20.3 Class Action Waiver

YOU WAIVE YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION LAWSUIT OR CLASS-WIDE ARBITRATION. DISPUTES ARE RESOLVED ONLY ON AN INDIVIDUAL BASIS.

20.4 Exceptions

Cultioo may seek injunctive or equitable relief in any court to protect intellectual property rights. Claims of $10,000 or less may be brought in small claims court.

21. Miscellaneous Provisions

Entire Agreement: These Terms, together with the Privacy Policy and any Group-specific agreements, constitute the entire agreement between you and Cultioo regarding the App.

Severability: If any provision is held invalid or unenforceable, the remaining provisions continue in full force.

Waiver: Failure to enforce any right does not constitute a waiver of that right.

Assignment: You may not assign your rights or obligations under these Terms without prior written consent. Cultioo may freely assign in connection with a merger or acquisition.

Force Majeure: Cultioo is not liable for failures due to causes beyond its reasonable control.

Updates to Terms: Material changes will be communicated 14 days in advance via in-app notification or email. Continued use constitutes acceptance.

22. Contact Information

Cultioo Inc.

Attn: Legal & Compliance Department

8 The Green, Ste A

Dover, DE 19901

United States of America

Legal: legal@cultioo.com

Support: support@cultioo.com

Website: www.cultioo.com

Last Updated: January 1, 2026 · Version: 1.0

Governing Entity: Cultioo Inc., a Delaware Corporation

© 2026 Cultioo Inc. All Rights Reserved.