Terms of Service

Effective Date: May 25, 2026

These Terms of Service (“Terms”) form a binding contract between you (“Customer,” “you,” or “your”) and JIE & P LLC(“Pulvo,” “we,” or “us”) and govern your access to and use of the Pulvo website, applications, and related services (collectively, the “Service”). By creating an account, clicking “I agree,” or using the Service, you agree to these Terms, our Privacy Policy, and any order form or plan you select.

1. Eligibility & Accounts

You must be at least 18 years old and have authority to bind the business you represent. You agree to provide accurate information, keep credentials confidential, and notify us promptly of unauthorized access. You are responsible for all activity under your account. We may suspend or terminate accounts that violate these Terms or pose risk to the Service or other users.

Geographic scope (v1 launch).The Service is currently offered to businesses organized and operating in the United States. Use of the Service by businesses organized outside the United States may be subject to additional terms, regional regulatory limitations, or feature restrictions (see §5A.2 regarding SMS scope and §11 regarding cross-border data-transfer mechanisms). Pulvo may decline service to, or restrict features for, users in jurisdictions where required regulatory registrations (e.g., local SMS-sender registration; data-residency obligations under mainland China’s PIPL, Russia’s 152-FZ, Vietnam’s Decree 13/2023, or the UAE’s Federal Personal Data Protection Law) have not been completed. By creating an account, you represent that the business you represent is eligible to receive the Service in its location of organization and that doing so does not violate the applicable export-controls or sanctions provisions identified in §18.

Language of agreement.These Terms are published in English. Pulvo’s user interface is available in multiple languages, but in the event of any inconsistency between an unofficial translation of these Terms and the English version, the English version governs.

2. The Service

Pulvo provides AI-assisted online reputation management for local small businesses, including review aggregation, AI-suggested replies, review-request messaging, alerts, insights, and related features. Features may change, expand, or be discontinued; we will use commercially reasonable efforts to give material-change notice for paid features.

3. Subscriptions, Free Trial, Auto-Renewal & Billing

3.1 Plans

Paid plans are billed in advance on a monthly or annual basis, as selected at checkout. Fees, billing cycles, and feature inclusions are described on the pricing page or in your order.

3.2 Free Trial

We may offer a free trial. Unless cancelled before the trial ends, your subscription will automatically convert to a paid plan and the payment method on file will be charged. You may cancel any time during the trial via the billing settings page. Trial-expiry warning communications will be sent approximately ten (10) and thirteen (13) days into the fourteen-day trial via the service-communication channels described in §5A.

3.3 Auto-Renewal Disclosure (FTC / State “ROSCA” Compliance)

• Your subscription renews automatically at the end of each billing cycle at the then-current rate until cancelled.
• You may cancel at any time through the in-product billing settings, with cancellation effective at the end of the current paid period.
• We will send renewal reminders for annual plans at least 30 days before renewal, or as otherwise required by applicable state law (e.g., California, New York).
• Material price changes will be communicated in advance and take effect on the next renewal.

3.4 Taxes & Refunds

Fees are exclusive of taxes. Except as required by law or expressly stated, fees are non-refundable, and partial-period charges are not pro-rated.

3.5 Failed Payments

If a payment fails, we may suspend the Service after reasonable notice. You agree to keep payment information current and to pay any outstanding balance, including reasonable collection costs.

4. Customer Content & License to Pulvo

“Customer Content” means data you upload, sync, generate, or otherwise make available via the Service (e.g., end-customer contact lists, business information, replies, attestations, and review data fetched at your direction). As between you and Pulvo, you retain all rights in Customer Content. You grant Pulvo a worldwide, royalty-free license to host, copy, transmit, display, and process Customer Content solely to provide, secure, and improve the Service for you, and as otherwise permitted by these Terms and the Privacy Policy.

You may also separately permit Pulvo to use de-identified, aggregated data derived from the Service for analytics, benchmarking, and product improvement. We will not use Customer Content to train third-party foundation models, and our AI vendors are contractually restricted accordingly.

5. End-Customer Contact Data; Outbound Messaging Compliance (TCPA / CAN-SPAM / 10DLC)

This Section addresses messages you send to your own end-customers through the Service (e.g., review-request SMS or email). For communications from Pulvo to your account holders, see §5A.

You represent, warrant, and covenant that:

• You have obtained all consents required by law (including the TCPA, CAN-SPAM, and applicable state mini-TCPA statutes) for any phone number, email address, or other contact data you upload, sync, or instruct Pulvo to message;
• You have provided your end-customers a clear privacy notice;
• You will comply with applicable carrier, CTIA, and 10DLC content/quiet-hour/opt-out rules;
• You will promptly process opt-out requests and maintain records of consent and opt-outs;
• You will not use the Service to send unlawful, harassing, deceptive, sweepstakes, gambling, regulated-substance, or otherwise prohibited content.

You are the “sender” for purposes of CAN-SPAM and the “maker” for purposes of the TCPA with respect to messages you send through the Service. You will defend, indemnify, and hold Pulvo harmless from any claim arising out of your messaging activities or your contact-list practices (see §14).

5A. Service Communications to You (Email & Optional SMS to Account Holders)

By using the Service, you consent to receive service communications from Pulvo about your account and the Service’s operation. These communications include, without limitation: new-review notifications, alerts you have configured, billing and renewal notices, security and authentication events, account changes, transactional confirmations, and notices we are required to send by law. Such communications are integral to the Service and are not marketing.

5A.1 Email (default channel; cannot be disabled while account is active)

We deliver service communications to your registered email address. You may set a separate notification email in Settings. You agree to keep your email address current and reachable; Pulvo is not liable for missed notifications resulting from invalid, full, blocked, or rejected mailboxes or from spam-filtering by your email provider.

5A.2 SMS to verified account-holder phone (opt-in only)

You may, at your option, add a mobile phone number in Settings, verify it via a one-time 6-digit SMS code, and explicitly opt in to receive critical service notifications by SMS as a secondary delivery channel. By opting in, you agree to the following:

• Frequency. Frequency is variable but estimated under normal operation to be fewer than five messages per month. Frequency may temporarily increase during high-activity events (e.g., a burst of negative reviews, security incidents, or trial-expiry windows).
• Carrier charges. Message-and-data rates from your wireless carrier may apply. Pulvo does not assess any per-message charge.
• Sender.SMS is delivered via 10DLC Application-to-Person (A2P) infrastructure operated by Pulvo’s SMS-gateway sub-processor. The sub-processor’s identity is provided in our Data Processing Addendum, available upon request.
• U.S. mobile numbers only. SMS opt-in is currently available only to U.S. mobile numbers; we have not completed Canada Anti-Spam Legislation (CASL), EU/EEA PECR, Japan / South Korea sender-registration, or Gulf-region requirements for the SMS channel. If you attempt to add a non-U.S. number, verification will fail. Email service communications under §5A.1 remain available globally subject to §11 cross-border-transfer terms.
• SMS does not substitute for legally required written notice. Where applicable law (including but not limited to California Automatic Renewal Law / FTC ROSCA, New York GBL §527-a) requires a notice to be in writing or sent to your registered email address (including auto-renewal reminders, material-change notices, and certain billing communications), SMS will not be relied upon to satisfy that requirement and Pulvo will deliver such notices by email regardless of your SMS opt-in status. SMS, if elected, is supplementary.
• HELP / STOP. Reply HELP for support contact; reply STOP to opt out. Opt-out takes effect within one business day and is irrevocable until you re-opt-in in Settings. You may also opt out by toggling SMS off in Settings → Notifications, or by removing or unverifying your phone number.
• Distinct scope.Your consent under this §5A.2 covers only Pulvo’s communications to you about your account. It is separate and independent from §5 (your messages to your end-customers) and from any other consent you may grant elsewhere in the Service.
• Records. Pulvo retains a record of your opt-in, the version of the consent text you accepted, timestamp, source IP, user-agent, and a one-way hash of the phone number, for the duration of your account plus seven (7) years post-closure, for TCPA-compliance and audit purposes. See Privacy Policy §6A.5.
• Escalation behavior. Unread critical-severity notifications older than approximately two hours may generate an SMS to your verified phone (if opted in). Unread critical notifications older than approximately four hours will also generate an email regardless of SMS opt-in status, because email is the default service-essential channel under §5A.1. Each notification produces at most one SMS escalation and at most one email escalation.

5A.3 Browser (Web Push) Notifications

If you grant Pulvo’s domain notification permission in your browser, Pulvo may deliver critical-severity service notifications via the browser’s native Web Notifications API. Permission is controlled by you within your browser’s site settings and may be revoked at any time, taking effect immediately. The web-push channel will not be used for marketing.

5A.4 No guarantee of delivery

Notification delivery depends on third parties (email providers, mobile carriers, operating systems, browsers) outside Pulvo’s control. Pulvo makes no warrantythat any individual notification will be delivered, displayed, or read in a timely manner, and disclaims liability for missed notifications to the maximum extent permitted by law (see §13–§15). You remain responsible for monitoring your account through the in-product notification history (see Privacy Policy §6B) and may not rely solely on push/SMS/email delivery as your means of staying informed.

5B. Review and Response Authenticity Warranty

Pulvo’s value proposition depends on the integrity of the review ecosystem on which our Customers compete. With respect to any review, reply, post, social-media content, citation, endorsement, or other publicly-facing representation that you (a) submit via the Service for publication on a third-party platform, (b) instruct the Service’s artificial-intelligence features to compose on your behalf and subsequently publish, or (c) direct Pulvo to publish on your behalf, you represent, warrant, and covenant the following:

• Truthful and accurate. The content is truthful, accurate, and not misleading, and does not contain any material misrepresentation or material omission.
• FTC Endorsement Guides compliance. Where the content includes any endorsement, testimonial, before-and-after claim, or implied recommendation, it complies with the U.S. Federal Trade Commission Endorsement Guides (16 CFR Part 255), including any required clear and conspicuous disclosure of incentives, sponsorships, employment relationships, or other material connections between you (or any speaker featured in the content) and the subject matter.
• No impersonation. The content does not impersonate any reviewer, end-customer, competitor, public figure, regulator, or other person, nor falsely attribute statements, opinions, or experiences to any person who did not make them. AI-generated replies must be attributable to your business as the speaker, not to a reviewer or customer.
• No fabricated testimonials. The content does not contain a false testimonial, a fabricated quotation, a fictional customer experience, or a review attributed to a person who did not actually receive the goods or services described.
• No coordinated inauthentic behavior.The content is not part of a coordinated campaign of fake or incentivized reviews, sock-puppet replies, brigading, retaliation against truthful negative reviewers, or other deceptive practices prohibited by the source platform’s terms of service or by 15 U.S.C. §45 (FTC Act §5) as interpreted by the FTC’s Final Rule on Use of Consumer Reviews and Testimonials (16 CFR Part 465, effective October 2024).
• Platform-policy compliance.The content complies with the publication policies of the destination platform (e.g., Google Business Profile’s prohibited and restricted content policies), and you possess any rights, permissions, or releases necessary for its publication.

Your indemnification obligation in §14 expressly extends to any third-party claim, regulatory enforcement action, platform-side suspension, or consumer-protection investigation arising from a breach of this §5B. Pulvo reserves the right (but assumes no obligation) to refuse publication of, suspend, or remove any content that we reasonably believe breaches this Section, without prior notice and without liability to you. Repeated or material breaches may result in termination of your subscription under §12.

6. Connected Third-Party Platforms

The Service connects to third-party platforms in two distinct categories: (a) review platforms you authorize via OAuth (currently Google Business Profile; additional review platforms may be added in future releases), and (b) Pulvo’s own sub-processors for payment, AI, messaging, and email delivery (described by category in Privacy Policy §8; specific vendor identities provided via DPA upon request). Pulvo does notcurrently integrate with Facebook / Meta or Yelp despite occasional references in marketing materials referring to features on the public roadmap. Your use of any connected platform is governed by that platform’s own terms. You are responsible for complying with each platform’s rules and for maintaining your authorization (including any OAuth grants you make). We are not liable for changes, outages, suspensions, rate-limiting, or termination by third-party platforms.

7. AI Outputs & Editorial Responsibility

Pulvo uses AI to generate suggested replies, summaries, insights, and similar outputs (“AI Outputs”). AI Outputs are suggestions only and may be inaccurate, outdated, biased, or otherwise unsuitable. You are solely responsible for reviewing, editing, approving, and publishing any AI Output before it is sent or posted. Pulvo is not the publisher of replies you choose to publish to a third-party platform. You will not use AI Outputs to:

• Make false, defamatory, deceptive, or misleading statements;
• Disclose third-party personal information without a lawful basis;
• Impersonate any person, including pretending to be a customer who left a review;
• Generate fake reviews, ratings, or social proof in violation of FTC endorsement rules or platform policies.

8. Acceptable Use

You agree not to:

• Reverse-engineer, decompile, or attempt to derive source code, except as permitted by law;
• Resell, sublicense, or provide the Service to third parties as a service bureau without our written consent;
• Interfere with, probe, or disrupt the Service or its security mechanisms;
• Use the Service to violate law, infringe rights, or transmit malicious code;
• Scrape, mass-extract, or build a competing product using our Service or its outputs;
• Submit benchmarks or evaluations of the Service for publication without our prior written consent;
• Use the Service to harass, threaten, dox, stalk, retaliate against, or disclose personal information about reviewers, end-customers, or any other individual whose data appears in the Service;
• Use any AI Output (see §7) to publish content falsely attributed to a reviewer or end-customer — for example, putting words in a customer’s mouth, fabricating quotations, or implying a reviewer said something they did not say. AI Outputs may only be used to compose Pulvo Customer’s own reply to a review or post;
• Generate, coordinate, or facilitate inauthentic behavioron any review platform, including (without limitation): fake reviews, sock-puppet replies, manipulated ratings, incentivized reviews concealing the incentive (in violation of the FTC’s Endorsement Guides 16 CFR Part 255), or fake business listings;
• Use the Service to seek the removal of truthful negative reviews through deception, intimidation, or legal threats not made in good faith;
• Train, fine-tune, or evaluate any large-language model or other AI system on Service prompts, prompt structures, AI Outputs received in error from the Service, or other Service intellectual property.

9. Intellectual Property

The Service, including all software, models, prompts, prompt templates, prompt-engineering methodologies, model-selection logic, AI configuration and tuning data, designs, text, graphics, and trademarks (other than Customer Content), is owned by JIE & P LLC or its licensors and is protected by intellectual-property laws. We grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Service during your subscription term solely for your internal business use. All rights not expressly granted are reserved.

Prompts and prompt engineering are Service IP.For the avoidance of doubt, any prompts, prompt templates, or system instructions used by Pulvo to compose Customer Content into large-language-model requests — including the manner in which inputs are combined, ordered, or annotated, and the specific model selected for a given request — constitute Service IP and remain the exclusive property of Pulvo. You may not extract, copy, reverse-engineer, scrape, or otherwise capture prompt content from debug interfaces, error messages, network traces, browser developer tools, or other surfaces; nor may you use any such content (whether obtained intentionally or inadvertently) to build, train, fine-tune, evaluate, or otherwise inform a competing AI service.

You may submit suggestions or feedback. You grant Pulvo a perpetual, irrevocable, worldwide, royalty- free license to use such feedback without restriction or obligation.

10. Confidentiality

Each party will protect the other’s confidential information using at least the same degree of care it uses for its own (and no less than reasonable care), and will not disclose it except to personnel and contractors with a need to know who are bound by confidentiality obligations.

11. Privacy

Our handling of personal information is described in the Privacy Policy, which is incorporated into these Terms by reference. With respect to Customer Content that constitutes personal information, you are the “controller” and Pulvo is the “processor” (or equivalent designations under applicable law).

Data Processing Addendum (DPA).Pulvo will make a DPA (incorporating the European Commission’s Standard Contractual Clauses where applicable) available upon written request to legal@pulvo.aifor Customers requiring one under applicable law, including GDPR Article 28 controllers, EEA / UK / Swiss data exporters, and processors of California consumer data under CCPA. Once requested, Pulvo’s standard DPA will be deemed executed and incorporated by reference upon the parties’ mutual countersignature. Until a DPA has been requested and countersigned, no DPA is in force between the parties; the rights and obligations described in the Privacy Policy and these Terms govern personal-information processing.

12. Suspension & Termination

Either party may terminate for material breach not cured within 30 days of written notice. We may suspend or terminate the Service immediately for non-payment, security risks, suspected abuse, legal requirement, or violation of §5 (messaging compliance) or §8 (acceptable use). Upon termination, your right to use the Service ends, and we may delete Customer Content as described in the Privacy Policy. Sections that by their nature should survive (including 4, 5, 7, 9, 10, 13–18) survive termination.

Customer-initiated deletion. You may request deletion of your account at any time from Settings. To prevent accidental loss of data, we require a two-step confirmation: (a) you must type your account email to initiate the request; and (b) you must click a verification link sent to that email address (valid 24 hours). After you confirm, your account enters a 30-day grace period during which subscriptions remain active and you may cancel the deletion by signing back in. After the grace period elapses without cancellation, your account and Customer Content are permanently deleted, your subscription is cancelled, and a final confirmation email is sent. Email confirmation is required to satisfy our identity-verification obligations under applicable consumer privacy laws (e.g., CCPA §999.323).

13. Disclaimer of Warranties

THE SERVICE AND ALL AI OUTPUTS ARE PROVIDED “AS IS” AND “AS AVAILABLE,” WITHOUT WARRANTIES OF ANY KIND, express or implied, including merchantability, fitness for a particular purpose, accuracy, non-infringement, and any warranty arising from course of dealing or usage of trade. We do not warrant that the Service will be uninterrupted, error-free, or secure, that AI Outputs will be accurate or appropriate, or that third-party platforms will remain available or compatible. Some jurisdictions do not allow exclusion of certain warranties; in those jurisdictions, the above exclusions apply to the maximum extent permitted.

14. Indemnification

You will defend, indemnify, and hold harmless Pulvo, its affiliates, and their officers, directors, employees, and agents from and against all third-party claims, damages, losses, liabilities, and expenses (including reasonable attorneys’ fees) arising out of or related to: (a) your Customer Content; (b) your use of the Service in violation of law, these Terms, or third-party rights; (c) your messaging activities and contact-list practices (including TCPA/CAN-SPAM/10DLC matters); (d) any AI Output you publish, send, or otherwise rely on; and (e) your relationship with end-customers, reviewers, or third-party platforms.

15. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, in no event will Pulvo, its affiliates, or their licensors be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, business, goodwill, data, or substitute services, whether based on contract, tort (including negligence), strict liability, or any other theory, even if advised of the possibility of such damages.

PULVO’S TOTAL CUMULATIVE LIABILITY arising out of or relating to these Terms or the Service will not exceed the greater of (a) the amounts you actually paid to Pulvo for the Service in the twelve (12) months preceding the event giving rise to the claim, or (b) USD $100. Multiple claims do not enlarge this limit.

16. Dispute Resolution; Binding Arbitration; Class-Action Waiver

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS.

16.1 Informal Resolution

Before filing a claim, the parties will attempt to resolve any dispute informally for at least 60 days after written notice describing the dispute and the relief sought is sent to legal@pulvo.ai (for claims against Pulvo) or to your account email (for claims against you).

16.2 Binding Arbitration

Any dispute, claim, or controversy arising out of or relating to these Terms or the Service that is not resolved informally will be resolved by binding individual arbitrationadministered by JAMS under its then-current rules. The arbitration will be conducted in English, in Spokane County, Washington, or by video conference at the consumer’s option where required by law. The arbitrator’s award is final and may be entered in any court of competent jurisdiction.

16.3 Class-Action & Jury Waiver

The parties waive the right to bring or participate in class, collective, or representative actions and the right to a jury trial. The arbitrator may award relief only in favor of the individual party seeking relief and only to the extent necessary to provide that relief.

16.4 Exceptions

Either party may bring an individual action in small-claims court for qualifying disputes or seek injunctive or equitable relief in court for misuse or infringement of intellectual property, confidentiality breaches, or violations of §5 or §8.

16.5 Opt-Out

You may opt out of arbitration by sending written notice to legal@pulvo.aiwithin thirty (30) days of first accepting these Terms — orwithin such longer period as the mandatory law of your jurisdiction may require — including your name, account email, and a clear statement that you wish to opt out. Opting out does not affect any other provisions of these Terms.

17. Governing Law & Venue

These Terms are governed by the laws of the State of Washington, without regard to its conflict-of-laws rules, and, where applicable, by the U.S. Federal Arbitration Act. Subject to §16, the parties consent to exclusive jurisdiction of the state and federal courts located in Spokane County, Washington.

18. Miscellaneous

• Entire agreement: these Terms, the Privacy Policy, and any order form or DPA constitute the entire agreement and supersede prior agreements regarding the Service.
• Assignment: you may not assign these Terms without our prior written consent; we may assign in connection with a merger, acquisition, or sale of assets.
• Notices: we may give notice via the Service or by email; notices to us must be sent to legal@pulvo.ai and 100 N Howard St, Ste R, Spokane, WA 99201.
• Force majeure: neither party is liable for delays or failures due to causes beyond its reasonable control.
• No waiver / severability: failure to enforce any provision is not a waiver; if any provision is unenforceable, the remainder remains in effect.
• Independent contractors: the parties are independent contractors; no partnership, agency, or joint venture is created.
• U.S. government rights: the Service is “commercial computer software” under FAR/DFARS.
• Export & sanctions:you represent and warrant that (a) you are not located in, organized under the laws of, or ordinarily resident in any country or region subject to comprehensive U.S. economic sanctions administered by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) — as of the Effective Date including (without limitation) Cuba, Iran, North Korea, Syria, the Crimea region, the so-called Donetsk People’s Republic, and the so-called Luhansk People’s Republic, as such designations may be updated by OFAC from time to time at ofac.treasury.gov; (b) you are not identified on any U.S. or international sanctioned-party or denied-party list, including OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List, the U.S. Department of Commerce’s Entity List or Denied Persons List under the Export Administration Regulations (EAR), or the U.S. Department of State’s debarred-parties list under the International Traffic in Arms Regulations (ITAR); and (c) you will not use the Service to facilitate any prohibited end-use or to circumvent applicable U.S. or other applicable export controls.
• Modifications: we may update these Terms; material changes will be notified via the Service or email and become effective on the date stated in the notice. Your continued use after the effective date constitutes acceptance.

19. Contact

Questions about these Terms? Contact:
JIE & P LLC
100 N Howard St, Ste R, Spokane, WA 99201
State of Incorporation: Washington
Legal: legal@pulvo.ai
Support: support@pulvo.ai