Legal & Governance

Last updated: Janary 16, 2026

This Legal & Governance page governs use of the CLARVS™ platform, including all current and future products, services, applications, software, reporting tools, portals, analytics, and features provided by CLARVS (collectively, the “Platform”).

By accessing or using the Platform, you agree to the terms described below.

1. Platform Purpose & Scope

CLARVS™ provides artificial intelligence–enabled software designed to assist private equity firms, fund managers, administrators, and related organizations with Limited Partner reporting, investor communications, data organization, workflow support, and operational efficiency.

The Platform is intended to support reporting and operational processes. It is not designed to replace professional judgment, fiduciary responsibility, regulatory compliance obligations, or required approvals.

2. AI Disclosure & Human Oversight

CLARVS™ uses artificial intelligence technologies solely to assist with the organization, structuring, summarization, analysis, and presentation of investor-related and fund-related information provided by users or integrated systems.

AI functionality:

  • Operates under human direction and oversight

  • Does not function autonomously

  • Does not make final decisions

  • Does not act independently of user control

All outputs generated by the Platform must be reviewed, validated, and approved by users prior to use or distribution. Users remain solely responsible for interpretation of information, communications with Limited Partners, and any actions taken based on Platform outputs.

3. No Professional Advice

The Platform does not provide legal, tax, accounting, investment, valuation, fiduciary, or regulatory advice, recommendations, certifications, or decisions.

Any outputs, summaries, analyses, calculations, or automated workflows generated by the Platform are provided for informational, operational, and reporting support purposes only. Users should consult qualified legal, tax, accounting, and investment professionals before making decisions involving regulatory, fiduciary, or compliance considerations.

4. AI Governance & Responsible Use

CLARVS™ is developed in alignment with responsible AI principles, including:

  • Transparency

  • Human oversight

  • Accountability

  • Data protection

  • User control

Where applicable, development considers relevant U.S. laws and emerging regulatory frameworks related to artificial intelligence, including applicable state-level AI governance requirements.

AI capabilities are designed to augment reporting workflows and internal processes, not to replace professional judgment, fiduciary responsibility, or accountability. Users are responsible for ensuring that use of the Platform complies with applicable laws, regulations, fund governing documents, and internal policies.

5. User Responsibilities

Users agree to:

  • Use the Platform only for lawful and authorized purposes

  • Review and validate all outputs prior to use or distribution

  • Maintain appropriate internal controls, approvals, and review processes

  • Ensure compliance with applicable laws, regulations, and fund governing documents

  • Safeguard login credentials and access rights

Users may not:

  • Misuse the Platform

  • Attempt to reverse engineer, decompile, or exploit Platform systems

  • Access systems or data without authorization

  • Use the Platform to generate unlawful, misleading, or harmful content

6. Data Ownership & Usage

Users retain ownership of all data, documents, reports, and content they upload to or generate through the Platform, subject to applicable agreements and legal obligations.

CLARVS™ may process data solely for the purposes of:

  • Operating and maintaining the Platform

  • Providing contracted services

  • Supporting reporting workflows

  • Maintaining security, reliability, and auditability

  • Improving system performance (in aggregate or anonymized form)

CLARVS™ does not sell user data.

7. Privacy Policy

7.1 Information Collected

The Platform may collect:

  • Account and contact information

  • Uploaded documents and user-provided content

  • Investor and fund-related reporting data

  • Usage metadata and system logs

  • Technical and diagnostic information

7.2 Use of Information

Information is used only to:

  • Provide and maintain the Platform

  • Support customer reporting and communications

  • Ensure security, integrity, and performance

  • Meet legal, contractual, and regulatory obligations

7.3 Data Sharing

Data may be shared with authorized service providers solely to support Platform functionality, infrastructure, hosting, and security. Such providers are contractually obligated to protect data and use it only for permitted purposes.

7.4 Data Security

Reasonable administrative, technical, and organizational safeguards are implemented to protect data against unauthorized access, disclosure, alteration, or loss. However, no system can guarantee absolute security.

8. Confidentiality

CLARVS™ treats customer data, fund information, and investor materials as confidential and uses commercially reasonable efforts to protect confidentiality, subject to legal requirements and authorized disclosures.

9. Intellectual Property

The Platform, including its software, architecture, workflows, models, reporting structures, branding, and documentation, is the intellectual property of CLARVS™ or its licensors.

Nothing in these terms grants users ownership of Platform intellectual property beyond the limited right to use the Platform in accordance with these terms.

10. Limited Partner (LP)–Specific Disclosures

CLARVS™ is designed to support fund managers and administrators in preparing, organizing, and distributing information to Limited Partners (“LPs”). The Platform does not act on behalf of LPs and does not owe fiduciary duties to LPs.

  • CLARVS™ does not verify, audit, certify, or opine on the accuracy or completeness of fund data

  • All information made available to LPs originates from the fund manager, administrator, or authorized third parties

  • CLARVS™ does not provide investment recommendations, suitability assessments, or performance guarantees

  • LPs remain responsible for independent review and due diligence

Any access provided to LPs is read-only unless expressly authorized, and all LP communications remain the responsibility of the fund manager or administrator.

11. Reliance on Fund Manager & Administrator Data

CLARVS™ relies entirely on data, documents, calculations, and representations supplied by fund managers, General Partners, administrators, auditors, and authorized third-party systems.

CLARVS™ does not independently validate capital accounts, NAVs, valuations, waterfalls, or allocations unless expressly agreed in writing. Users remain responsible for final approval and release of all investor-facing materials.

12. Open-End Fund Disclosure Rider

For open-end funds, evergreen vehicles, interval funds, or similar structures:

  • NAVs and investor balances may be preliminary, estimated, or subject to adjustment

  • Period-over-period changes may reflect subscriptions, redemptions, fees, expenses, or valuation updates

  • Data may be updated retroactively

CLARVS™ presents information as provided and does not guarantee finality or immutability of reported figures.

13. Closed-End Fund Disclosure Rider

For closed-end or drawdown funds:

  • Capital calls, distributions, IRRs, multiples, and waterfalls are based on user-provided inputs

  • Metrics may be unaudited or provisional

  • Final allocations are governed by fund governing documents

CLARVS™ does not interpret partnership agreements or side letters.

14. Reporting Status & Audit Disclosure

Unless explicitly stated otherwise:

  • Reports generated through CLARVS™ are unaudited

  • Audit opinions and certifications are not provided by CLARVS™

LPs should rely on official audited financial statements where required.

15. Forward-Looking Statements

Certain information may include projections or estimates. Such statements are inherently uncertain and subject to change. CLARVS™ does not guarantee outcomes or performance.

16. LP Access & Permissions

LP access is governed by permissions set by the fund manager or administrator. CLARVS™ does not determine disclosure scope, timing, or eligibility.

17. No Fiduciary Relationship

Use of the Platform does not create a fiduciary, advisory, or agency relationship between CLARVS™ and any LP, fund, or investor.

18. Disclaimers

The Platform is provided “as is” and “as available.”
CLARVS™ disclaims all warranties to the maximum extent permitted by law.

19. Limitation of Liability

Total liability, if any, is limited to amounts paid to CLARVS™ during the preceding twelve (12) months.

20. Changes to This Page

CLARVS™ may update this page from time to time. Continued use constitutes acceptance.

21. Governing Law

These terms are governed by the laws specified in applicable customer agreements.

22. Applicability Across Products

This Legal & Governance page applies to all CLARVS™ products, modules, and future offerings.

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