Generative AI Use Policy

Last updated: 28/12/2025

1. Scope

This Generative AI Use Policy applies solely to ORCA.

2. Use of Generative AI

ORCA may use generative and AI-assisted technologies to support certain platform functionalities, including analytical tools, automation, summaries, and informational insights. Generative AI is used as a supportive, non-autonomous tool and operates under defined system controls and human oversight.

3. No Advice or Determinations

AI-assisted outputs generated within ORCA are provided for informational purposes only and do not constitute financial, investment, tax, legal, or compliance advice, opinions, or determinations.
ORCA does not provide regulated advice through AI-assisted features and does not replace professional judgment, independent review, or external advisors.

4. User Responsibility

Users remain solely responsible for:

• Reviewing and validating AI-assisted outputs.
• Determining whether and how to rely on such outputs;
• Ensuring compliance with applicable laws, regulations, contractual obligations, and internal policies.

Any decisions or actions taken based on AI-assisted outputs are made at the user’s discretion and responsibility.

5. Data Protection and Confidentiality

ORCA does not permit customer data, investor data, financial records, or other confidential information to be used to train public or third-party AI models.

Where AI tools are used, they are configured to prevent data retention or secondary use beyond the provision of ORCA services, in accordance with ORCA’s Privacy Policy and applicable data protection laws.

6. Governance and Controls

Use of generative AI within ORCA is limited to approved use cases and governed by internal controls. ORCA reserves the right to modify, restrict, or discontinue AI-assisted features at any time to address legal, regulatory, security, or operational considerations.

7. Updates

This policy may be updated from time to time to reflect changes in technology, regulation, or ORCA’s practices. Continued use of ORCA constitutes acceptance of the then-current version of this policy.