Subscription terms and disclosures

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. The Service is available only to eligible Tennessee residents.
• 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 marked Available Now in your agreement. Features marked Coming Soon are not part of the Service and have no guaranteed release date.
• 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 Digital Intelligence, the subscription described in the agreement, limited to the features marked Available Now.

Available Now; Coming Soon

Available Now means a feature that works today and is included in the Service. Coming Soon means a feature that is planned, is not part of the Service and has no guaranteed release date.

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 available now and what is planned

Features marked Coming Soon are not part of the Service and have no guaranteed release date.

The proposed agreement terms

These terms are proposed for the agreement you will be asked to sign. They are shown for review and remain subject to final review before the subscription opens.

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 marked Available Now in the service schedule. Features marked Coming Soon are not part of the Service and have no guaranteed release date. 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 Central 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 Digital Intelligence. 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.

Gulfstream has not finished reviewing every other type of conflict. The Conflicts of interest disclosure delivered with your agreement controls.

Gulfstream Digital Intelligence: technology and AI

Gulfstream Digital Intelligence 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. 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. Features marked Coming Soon are not part of the Service. 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

Draft for review. These are the outside providers that the Gulfstream code sends information to, what each one receives and why. Gulfstream makes no statement here about any provider’s own retention or use of data beyond what is written in this table.

Security and Retention Schedule

Draft for review. 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

How long information is kept

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) receives redacted statement text only, and is used only to identify the holdings listed in it. 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.