Gulfstream Advisory

Subscription terms and disclosures

This page explains the terms and disclosures so you can read them first. It is not the agreement. The final agreement and documents are delivered to you to read before you sign anything, and they control.

At a glance

The Subscription Fee is $99 per month, billed monthly in advance until you cancel. It is not a twelve-month commitment; twelve monthly payments total $1,188.
The Service is not investment management. Gulfstream has no trading authority under it and does not monitor your accounts continuously. Under the Service Gulfstream does not hold your assets or trade for you.
You can cancel online at any time. Cancelling ends the Service immediately and turns off renewal. After the Initial Termination Window you may instead choose to keep access until the end of the period you paid for.
The Service includes only the features described in your agreement.
The free Portfolio Snapshot is separate. Requesting one does not enroll you in the $99 monthly service, authorize a payment, or subscribe you to marketing email.

Defined terms

These capitalized terms mean the same thing everywhere on this page and in the documents you receive.

Gulfstream, we, us: Gulfstream Capital LLC.
you: The person who signs the agreement and subscribes.
Service: Gulfstream Advisory, the subscription described in the agreement. The Service consists only of the features described in the agreement.
Snapshot: The free Portfolio Snapshot: a short summary prepared from a statement you upload to the free portfolio review. It is separate from the Service and does not enroll you in it.
Assessed Component Score: The score the Service reports for the categories your statement supports, shown with how many of the possible methodology points were assessed. It is not a prediction, a guarantee or a finding of suitability.
Subscription Fee: The fee for the Service: $99 for each Service Period.
Service Period: Each monthly period for which a Subscription Fee is paid.
Contract Entry Time: The time Gulfstream records its acceptance of the agreement, after the required documents were delivered to you in a readable form, every required client signature was received and Gulfstream completed its onboarding review.
Initial Termination Window: The period during which you may terminate without penalty and receive a refund of every Subscription Fee you paid. It ends at 11:59:59 PM in your Tennessee local time zone on the fifth Business Day after the later of delivery of all required documents to you and the Contract Entry Time.
Business Day: A day that is not a Saturday, a Sunday, a federal holiday observed by the federal government, or a full-day Tennessee state-office closure.

What is included today

Feature
Analyze brokerage statements
Direct-holding concentration analysis
Assessed component score
Investment intelligence without transferring assets

The agreement terms

These terms appear in the agreement you will be asked to sign. The agreement you receive controls.

Services: Gulfstream provides the Service: non-discretionary written portfolio analysis based only on the information you supply, an Assessed Component Score and a direct-holding concentration analysis, limited to the features described in this agreement. Features not described in this agreement are not part of the Service. The Service does not include discretionary management, trade execution, continuous account monitoring, individualized tax or legal advice, or comprehensive financial planning. The limited scope of the Service does not waive any fiduciary duty that applies to advice Gulfstream gives.
Term: This agreement begins at the Contract Entry Time. The paid Service begins when your first Subscription Fee payment succeeds and your access is enabled. No fee is earned for any time before that. The agreement renews each Service Period until it is terminated.
Fee: The Subscription Fee is $99 per Service Period, collected monthly in advance. Twelve monthly payments total $1,188; this is not an annual prepayment or a twelve-month commitment. Gulfstream does not add sales tax to the Subscription Fee. Custody charges and investment product expenses charged by others are separate and are not part of the Subscription Fee.
How the fee works: The Subscription Fee is a fixed $99 per month. It is not a percentage of assets and does not change with portfolio value or investment performance. Service Periods run between the monthly renewal dates shown in your account. If a Subscription Fee is refunded on termination, the amount is calculated under the refund terms below.
Discretion: Under this agreement Gulfstream receives no discretionary trading authority, no custody of your assets and no authority to withdraw funds, and it does not ask for your brokerage login credentials. You decide whether to act on the analysis and place any trades yourself with your own custodian. Gulfstream has no authority to vote your securities under this agreement.
Assignment: Gulfstream will not assign this agreement without your consent where applicable law requires it. A transaction that applicable law treats as an assignment is handled the same way. Questions: info@gulfstreamcapital.net or 865-874-6248.

Cancelling and refunds

Your Initial Termination Window is the first five business days after the later of delivery of all required documents to you and the Contract Entry Time. During it you may terminate without penalty and receive a refund of every Subscription Fee you paid. After it, if you cancel, we refund the unearned part of the Subscription Fee you prepaid, counted by the day, with no exit charge. Your exact deadline is shown with your agreement.

Initial Termination Window. You may terminate without penalty through 11:59:59 PM in your Tennessee local time zone on the fifth Business Day after the later of (a) delivery to you of all required documents in a readable form and (b) the Contract Entry Time. The following day is day one. If we are unsure whether a day is a holiday, we do not count it as a Business Day. Until your Tennessee time zone is verified, we use Eastern Time. Your exact deadline and the version of the holiday calendar used are shown with your agreement and do not change after we accept it. If you terminate within the Initial Termination Window, we refund every Subscription Fee you paid.

Cancellation after the Initial Termination Window. Cancelling ends the Service immediately and turns off renewal, unless you expressly choose to keep access until the end of the period you paid for. That choice is separate from cancelling, and no refund is due for that period. When you cancel, we refund the unearned part of the prepaid Subscription Fee. Let P be the Subscription Fee paid for the current Service Period. Let D be the number of calendar days from the first day of the Service Period, counting that day, up to but not including the next renewal date. Let U be the number of whole days from the first day of the Service Period, counting that day, up to but not including the day you cancel, and not less than zero or more than D. The refund is P × (D − U) ÷ D, rounded up to the next cent and never more than P. The day you cancel is not counted as earned. We charge no exit fee.

When cancellation takes effect. Cancellation is effective when we receive it through the online cancellation control or at info@gulfstreamcapital.net, not when staff later read it. A failure of the payment processor or of a refund never reverses your cancellation.

Refund timing. We initiate a refund that is owed within two business days after we record your cancellation. The system starts the refund automatically when the cancellation is recorded. If an automatic attempt fails, a task is opened for our team with a 24-hour due time. Your bank decides when the refund posts.

Other cases. If Gulfstream fails to supply or lawfully continue the Service, it refunds the unearned part of the Subscription Fee under the same formula and any further amount the law requires. If a Service Period is invalid or has no length, a staff member decides the refund by hand, in your favor, and does not keep the fee by default.

Example (illustration only, not an actual refund). A $99 Service Period begins October 26, 2026 and renews November 26, so D = 31. If you cancel on November 5, U = 10, and the refund is $99 × 21 ÷ 31, rounded up, which is $67.07. Within the Initial Termination Window the refund is instead the whole Subscription Fee.

What you will be asked to authorize

At checkout, after Gulfstream accepts your agreement, you will see this authorization with an unchecked box. Nothing is charged unless you tick it and complete checkout.

I authorize Gulfstream Capital LLC to charge the Subscription Fee of $99 each month to the payment method I enter on Stripe’s secure checkout page for Gulfstream Advisory. The first charge occurs when I complete that checkout, and charges continue each month until I cancel. This is a monthly subscription, not a twelve-month commitment; twelve monthly payments total $1,188. I can cancel online using the cancellation control in my account or by email to info@gulfstreamcapital.net. The agreement explains my Initial Termination Window, with a refund of every Subscription Fee I paid, and the refund of the unearned part of a prepaid Subscription Fee after that window. My free Portfolio Snapshot does not enroll me in this subscription.

Documents you receive before you sign

Non-Discretionary Investment Advisory Subscription Agreement
Form ADV Part 2A brochure (and Part 2B where it applies)
Privacy notice
Consent to electronic delivery
Recurring payment authorization
Digital service limitations
Conflicts of interest disclosure
Technology and AI use disclosure

You acknowledge each one separately. Signing the agreement and authorizing payment are separate steps.

Conflicts of interest

Gulfstream receives the Subscription Fee of $99 for each Service Period while your subscription is active. This gives Gulfstream a financial incentive for you to start and keep your subscription.

Gulfstream Private Wealth is a separate full-management service under a separate advisory agreement and fee schedule. If you choose it, Gulfstream receives the compensation stated in that agreement. This gives Gulfstream an incentive to suggest its own service rather than another provider or your existing arrangement. You do not need Private Wealth to receive the Service.

The Conflicts of interest disclosure delivered with your agreement describes every other conflict Gulfstream has identified, and it controls.

Gulfstream Advisory: technology and AI

Gulfstream Advisory is a service of Gulfstream Capital LLC, which remains responsible for its advisory services. Gulfstream software extracts and organizes information from the statement you provide, calculates the figures and builds the written report from them. An outside artificial intelligence (AI) service, OpenAI, receives only a redacted text version of your statement and is used to identify the holdings listed in it. Gulfstream processes the statement through its own OpenAI services under Gulfstream’s account terms with OpenAI (a business or API account). How OpenAI retains and uses what it receives is governed by those terms and the account settings Gulfstream has in effect; Gulfstream’s own deletion times for its own copies are stated separately in the Security and Retention Schedule. The AI service does not write the report. The Provider and Data Schedule lists each provider, what it receives and why.

AI output can be incomplete or incorrect. Extraction from a statement can misread amounts or holdings, and a calculation is wrong when its inputs are wrong. The Assessed Component Score uses the methodology and coverage limits shown with it. It is not a guarantee, a return forecast or a finding of suitability.

We describe a report or observation as reviewed by a person only where a person recorded that review. Review does not guarantee accuracy.

The Service gives Gulfstream no authority to trade, rebalance or withdraw from your brokerage account, and it does not monitor your accounts continuously. The Service consists only of the features described on the Gulfstream Advisory page and in the agreement. Report suspected errors to info@gulfstreamcapital.net or 865-874-6248. This disclosure does not waive any right or duty that cannot be waived.

Provider and Data Schedule

These are the outside providers that the Gulfstream code sends information to, what each one receives and why. How a provider retains or uses information is governed by that provider’s terms and the settings Gulfstream has in effect, and Gulfstream makes no statement here about those beyond what is written in this table.

Provider	What it does	What it receives	Use
OpenAI (AI service)	Identifies the holdings listed in a redacted text version of an uploaded statement (free portfolio review and Snapshot). It does not write the report.	Redacted statement text and page references only. It does not receive the original file, images, your name or your contact details.	Used only to list holdings. Gulfstream sends this text through its own OpenAI services (a business or API account) under Gulfstream’s account terms with OpenAI. How long OpenAI keeps the text, and whether it uses it for any purpose, is governed by OpenAI’s terms for that account and the account settings Gulfstream has in effect. This schedule makes no statement about those terms or settings. Gulfstream’s own deletion times for its own copies are in the Security and Retention Schedule and do not change what OpenAI does.
Netlify (hosting and storage)	Hosts the website and server functions, and stores uploads, review files, Snapshots, subscriber records and compliance records in Netlify Blobs.	Everything you submit to the site: uploads while they are held, your email address, Snapshot content and compliance records.	Storage and delivery of the service. Gulfstream deletes files from its Netlify storage on the schedule in the Security and Retention Schedule.
Stripe (payment)	Takes the monthly payment on a Stripe-hosted checkout page, manages the subscription and issues refunds. Nothing is charged until you complete checkout.	Your email address, an internal subscriber identifier and the payment details you enter on Stripe’s page. Gulfstream receives billing status and transaction references back.	Payment, subscription and refund administration.
Google (email delivery)	Sends Gulfstream Advisory sign-in links and service notices from info@gulfstreamcapital.net through Google Workspace SMTP. Real sending stays off unless the firm turns it on.	The recipient’s email address and the subject and text of each message.	Email delivery only.
Resend (email delivery)	Sends the free portfolio review report email and related messages from review@notify.gulfstream.one.	The recipient’s email address and the content of the message sent.	Email delivery only.
Slack (internal notice)	Posts a private internal notice to Gulfstream staff when a free review is received or ready.	Your name, your email address and a summary of allocation and largest-holding figures with a protected link. No account identifiers or statement text.	Internal staff notification only.

Security and Retention Schedule

This describes what the Gulfstream systems do today. It is not an independent security assessment, and it does not promise that information cannot be lost or accessed without permission.

Security controls

Subscriber sign-in	A sign-in link is emailed to the address on file. It works once and expires in 15 minutes. No more than 5 links are sent to one address per hour. A session lasts 12 hours (HttpOnly, Secure, SameSite=Lax).
Snapshot and report links	A Snapshot link is signed and valid for 30 days. A paid-report link is signed, valid for 10 minutes and works only for the signed-in subscriber with current paid access. Expiry of a link controls access only; it does not delete the Snapshot.
Email address handling in logs	The outbound mail log keeps a short hash and the domain of each recipient, not the address.
Payments	Payment is taken on a Stripe-hosted page. Stripe webhook messages are accepted only with a valid signature and are applied once per event.
Website analytics	Analytics store a count per day, event and headline variant, with no visitor identifier, IP address, email address or portfolio information. Browsers that send Global Privacy Control or Do Not Track are not counted. The headline variant is kept in the browser’s local storage. The “upload completed” count is browser-reported and may include repeat visits.

How long information is kept

Original upload, upload chunks, extracted statement text and raw AI output (free portfolio review)	Deleted by an hourly job 72 hours after upload, and never later than 7 days. Each deletion is read back and logged in a receipt that holds no statement content.
Copies held by OpenAI (the redacted statement text sent to identify holdings)	The 72-hour and 7-day deletion times above apply to Gulfstream’s own copies only. How long OpenAI keeps the redacted text, and whether it uses it for any purpose, is governed by OpenAI’s terms for Gulfstream’s account and the account settings in effect. Gulfstream makes no statement about those terms or settings.
Holdings table and unsent report from a review that was never sent	Deleted 30 days after upload.
Viewable copy of a report that was sent	The viewing link stays open 60 days; then the viewable copy is deleted.
The report and email that were sent, with delivery records	Kept as a required business record, for at least five years. The scheduled job never deletes it; deleting it needs a separate decision by the firm.
Portfolio Snapshot, the subscriber record behind it and the source note	No automatic deletion exists. The Snapshot link stops working after 30 days, but the stored Snapshot and the email-address record remain until they are deleted at your request (the delete link from the free review, which removes them on a best-effort basis, or a deletion request to info@gulfstreamcapital.net) or under the firm’s current records schedule.
Deletion request on a Gulfstream Advisory account	Opening the request revokes access to the Snapshot link at once. Nothing is deleted until staff record what was deleted and what is retained and why. No required record is deleted while a legal hold applies.
Gulfstream Advisory compliance records (agreement, consents, billing, refunds, complaints and others)	No automatic disposal exists. The 18-category schedule (five years after fiscal year end for most; seven years for the executed package) is the firm’s current policy. No automatic disposal exists, so nothing is deleted on that schedule.

A link that expires stops working but does not by itself delete the record behind it.

Your information

We use the statement you upload to prepare your Snapshot or analysis. Gulfstream software and the outside providers named in the Provider and Data Schedule process it. You may ask us to delete your information at any time. We then tell you what was deleted and which records we must keep, why, and until when. A link expiring does not by itself delete a record.

Gulfstream software processes your statement. An outside AI service (OpenAI), used through Gulfstream’s own OpenAI account, receives redacted statement text only, and is used only to identify the holdings listed in it. OpenAI’s retention and use of that text follow OpenAI’s terms and Gulfstream’s account settings. Review how your information is processed and kept before you upload.

Questions, corrections or deletion requests: info@gulfstreamcapital.net or 865-874-6248. See also the Disclosures page.

Questions, corrections and complaints

Send a question, a correction request or a complaint to info@gulfstreamcapital.net or call 865-874-6248. For a complaint, we record the date and time we received it, open a review task for our compliance function, and close the task only with a written note.

Gulfstream Capital LLC · Gulfstream Investment Team · info@gulfstreamcapital.net · 865-874-6248. Gulfstream Advisory provides limited-scope portfolio analysis based on the holdings information you provide. It does not include a recommendation to buy, sell or hold any security, and it is not investment management. Under the Service Gulfstream does not take custody of your assets or trade for you. The Assessed Component Score describes measurable characteristics of the holdings on a statement; it does not indicate suitability or predict results.