Terms of Service

1. Acceptance of Terms

By downloading, installing, accessing, or using the Nebula Genesis Pet Ledger mobile application (the "App") operated by Nebula Genesis Tech, LLC, you agree to be bound by these Terms of Service ("Terms"). If you do not agree to these Terms, do not download, install, or use the App.

Related Documents: These Terms should be read together with our Privacy Policy, which explains how we collect, use, and protect your personal information, including your rights under GDPR and CCPA, and our Non-Binding Technical Overview for supplemental architecture context.

1.1 Definitions

"Digital Record" means a soulbound, non-transferable digital token minted on a blockchain. The term "Verified" refers to the cryptographic verifiability of the record's existence and integrity on the blockchain, not to independent verification of the accuracy of the information contained within the record, which is provided by the user. For non-binding technical details, see our Non-Binding Technical Overview.

"GEN Credits" or "Credits" means the prepaid service entitlements used within the App to pay for digital record creation, metadata updates, veterinary attestations, and other paid features. GEN Credits are not currency, cryptocurrency, or stored value. See Section 5.9 for complete terms.

1.2 Age Requirements

The App is rated E for Everyone in app stores; the content is appropriate for all ages. The age requirements below are for contractual capacity and legal compliance (including COPPA) and do not change the content rating.

You must be at least 18 years old to use this App, or have the consent of a parent or legal guardian if you are between 13 and 17 years old. The App is not intended for children under 13 years of age.

1.3 Modifications to Terms

We reserve the right to modify these Terms at any time. We will notify you of material changes by posting the updated Terms on this page, updating the "Last Updated" date, and providing an in-app notification for significant changes.

For material changes that affect your rights, obligations, or data processing purposes, we may require re-acceptance of the updated Terms through the same in-app affirmative consent mechanism used when you first accept the Terms, where required by applicable law or otherwise deemed appropriate. Your continued use of the App after changes become effective constitutes acceptance of non-material updates only.

1.3.1 Regulatory Monitoring and Updates

We monitor changes in applicable laws and regulations (including SEC guidance on digital assets, state and federal consumer protection laws, and international regulations) and will update these Terms as needed to maintain compliance. Significant regulatory changes that affect user rights, fees, or service availability will be communicated through:

• Updated Terms of Service with clear change log entries
• In-app notifications for material changes
• Email notifications (if you have provided an email address)

If regulatory guidance changes (e.g., SEC views on digital titles as securities), we may modify or discontinue features to ensure compliance. All changes are tracked in the Change Log (Section 15) for transparency.

2. Description of Service

Nebula Genesis Pet Ledger is a mobile application that provides:

2.1 Pet Health Management

• Digital pet profiles and records
• Health record tracking (vaccinations, checkups, surgeries, medications, grooming)
• Appointment scheduling and reminders
• Photo storage and timeline management
• AI-powered symptom checker and health recommendations
• Document scanning (OCR) for veterinary records
• Lost pet flyer generation
• Push notifications for appointment reminders, medication schedules, and other pet care alerts (with your permission)

2.1.1 Health Record Integrity Checking

The App may allow you to generate cryptographic hashes (one-way digital fingerprints) of health records stored on your device and register those hashes with our backend. This feature provides tamper-evidence — the ability to confirm that a record has not been modified since it was hashed. It does not verify the truthfulness or clinical accuracy of any record.

How it works:

• Health record content remains on your device and is not transmitted to our servers
• A SHA-256 hash is computed on your device from the record's content
• Only the hash (a non-reversible fingerprint) is registered with our backend
• We cannot reconstruct or read the original record from the hash

Important limitations:

• Hash registration provides tamper-evidence only — it does not verify the accuracy, completeness, or authenticity of the underlying record
• Verification depends on the exact original data; if a record is edited after hashing, verification against the original hash will fail
• Hash registration is a background process and may be delayed by network conditions

2.2 Blockchain and Digital Record Features

Optional Feature: Blockchain and digital record features are optional and not required for core app functionality. All pet health management features (profiles, health records, appointments) work fully without blockchain features.

• Built-in cryptocurrency wallet (auto-created)
• Digital Record minting on a blockchain (for non-binding technical details, see our Non-Binding Technical Overview)
• Digital record ownership verification
• Wallet backup and recovery

2.2.1 AI-Powered Features (Planned)

The App may offer AI-powered features, including but not limited to AI-generated pet portraits and style transformations. When available:

• Data Sent to AI Providers: Pet photos you select may be transmitted to third-party AI service providers for processing. No personally identifiable information (name, wallet address, health records) is sent to AI providers.
• Third-Party Providers: AI features may use third-party services whose own terms of service and privacy policies apply to data they process.
• Generated Content: AI-generated images are created for your personal use within the App. Generated images may be stored locally on your device or, if pinned, on decentralized long-duration storage (Arweave), where they become publicly accessible and generally cannot be removed (see Privacy Policy Section 5).
• Subscription Tiers: AI features may be offered in free and premium tiers with different usage limits and capabilities, powered by GEN credits or subscriptions.
• No Medical Use: AI-generated content is for entertainment and creative purposes only, not for medical, diagnostic, or veterinary use.
• Third-Party Provider Limitations: We do not control how third-party AI providers use or retain data beyond their stated policies. Provider policies may change, and we are not responsible for their data practices or compliance.

2.3 Pricing

• App Download: Free
• Core Features: Free (pet management, health records, appointments)
• Digital Record Creation: Powered by GEN credits (see current pricing in the App)
• Free Digital Record Mints: Available by completing in-app surveys

3. User Accounts and Registration

3.1 Account Creation

To use the App, you may create an account by providing:

• First name and last name (for account identification)
• Email address (optional - for account recovery)
• Password (optional - for additional security)

Note: The App supports minimal registration. You can create an account with just your name.

Data Handling: For detailed information about how we collect, use, and protect your personal data, please see our Privacy Policy.

3.2 Account Security

You are responsible for:

• Maintaining the confidentiality of your account credentials
• All activities that occur under your account
• Notifying us immediately of any unauthorized use
• Backing up your wallet seed phrase if you use blockchain features

4. Acceptable Use Policy

4.1 Permitted Uses

You may use the App for:

• Personal pet health management
• Legitimate blockchain transactions
• Creating and sharing lost pet flyers
• Backing up and exporting your pet data

4.2 Prohibited Activities

You are not permitted to, including but not limited to:

Illegal Activities:

• Use the App for any unlawful purpose or in a manner that results in unlawful outcomes
• Violate any applicable laws or regulations
• Engage in fraudulent, deceptive, money laundering, terrorist financing, or similarly abusive activity
• Use blockchain features in connection with unlawful transactions or other prohibited conduct

Security Violations:

• Attempt to hack, breach, bypass, or otherwise compromise the App's security or integrity
• Reverse engineer, decompile, or disassemble the App
• Access, use, or attempt to interface with any non-public API, protocol endpoint, relayer, or backend service without our prior written authorization, including but not limited to scraping, replication, or unsupported interoperability attempts
• Introduce viruses, malware, or harmful code
• Interfere with, disrupt, degrade, or impair the App's functionality, availability, or performance

Blockchain-Specific Prohibitions:

• Use wallet features for money laundering or other unlawful financial activity
• Engage in unlawful cryptocurrency transactions or abusive transaction patterns
• Create digital records containing unlawful, harmful, infringing, or unauthorized content
• Use blockchain features to violate securities laws

5. Blockchain and Cryptocurrency Terms

5.1 Wallet Responsibility

5.1.1 Biometric Authentication Requirement

Every blockchain operation performed through the App requires biometric authentication (or device passcode where biometrics are unavailable) on your device. This is a device-level protection. We do not have access to your biometrics or passcode.

5.1.2 Recovery Phrase Security

Recovery Phrase = Master Key: Your 12-word recovery phrase is the master key to your wallet. Anyone who has it can recreate the wallet on a new device and act as you. This is a design principle of self-custodial wallets, not a bug.

Recovery Phrase Compromise Scenarios: A compromised recovery phrase allows full wallet access and signing authority on any device. Soulbound digital record protection at the smart-contract level prevents transfer or deletion of Digital Records even in a compromise scenario.

If Your Recovery Phrase is Compromised:

• Create a new wallet with a fresh 12-word phrase immediately
• Transfer any funds to the new wallet (if applicable)
• Contact Nebula support to report the compromise
• Monitor your Digital Records for any unauthorized attestations

Prevention: Treat your recovery phrase like the master key to your house. Never store it digitally (screenshots, cloud storage, email), share it with anyone (including Nebula support), or enter it on any website or app other than the official Nebula app.

We are not liable for any loss resulting from:

• Lost or stolen seed phrases
• Unauthorized access to your wallet
• User error in wallet management
• Failure to backup seed phrases
• Recovery phrase compromise (though soulbound digital record protection limits damage)

5.2 Digital Record Creation and Fees

• Minting: Powered by GEN credits (see current pricing in the App)
• Veterinary Attestation: GEN credits per professional attestation
• Blockchain Fees: Included (we pay gas fees)
• Free Mints: Earned by completing in-app surveys (we pay gas fees)

Free Mint Tokens:

• Earned by completing optional surveys within the app
• One free mint token per qualifying survey completion
• Tokens have no cash value and are non-transferable
• Nebula Genesis Tech pays all blockchain gas fees for free mints
• Tokens are generally non-expiring during normal operation and remain valid until used, unless modified or discontinued under these Terms
• We reserve the right to modify or discontinue the free mint program

5.2.1 Promotional and Giveaway Programs

From time to time, Nebula Genesis Tech may offer promotional digital record creation programs, including but not limited to: company-initiated giveaway events ("Genesis Days"), partner-distributed promotional codes, limited-time promotional offers, and community reward programs (collectively, "Promotional Programs").

General Terms for All Promotional Programs:

• Eligibility: Promotional Programs are available only to users who (a) have a valid App account, (b) hold a valid wallet address, and (c) are not subject to any suspension, blacklist, or restriction under these Terms
• No Cash Value: Promotional codes, credits, and digital records have no cash value, are non-transferable, and cannot be sold, bartered, or exchanged for currency or cryptocurrency
• Quantity Limits: All Promotional Programs are subject to per-code and per-wallet redemption limits as determined by Nebula Genesis Tech. We may cap the total number of redemptions per promotional code and per wallet address without prior notice
• One Account Per Person: You may not create multiple accounts or use multiple wallet addresses to circumvent redemption limits. Abuse of Promotional Programs, including but not limited to automated redemption, code sharing for circumvention purposes, or the use of multiple identities, may result in forfeiture of promotional benefits and suspension of your account
• Blockchain Fees: Nebula Genesis Tech pays all blockchain gas fees for digital records created through Promotional Programs
• As-Is: Digital records created through Promotional Programs are provided on the same "as-is" basis as all other digital records (see Section 8.1) and are subject to all applicable terms, including the soulbound non-transferability provisions of Section 5.4
• Modification and Discontinuation: We reserve the right to modify, suspend, or discontinue any Promotional Program at any time, with or without notice, for any reason, including but not limited to suspected fraud, abuse, or technical issues

Competitive Allocation Events:

If a Promotional Program involves limited quantities distributed on a first-come-first-served basis, random selection, or any other form of competitive allocation, the program will be accompanied by separate Official Rules governing eligibility, entry methods, selection criteria, and any additional terms specific to that event. In the event of a conflict between these Terms and the Official Rules for a specific Promotional Program, the Official Rules shall control with respect to that program.

Promotional Data:

If a Promotional Program requires you to provide additional information (such as an email address, social media handle, or promotional code), that information will be collected and processed in accordance with our Privacy Policy.

Disputes:

All disputes arising from or relating to Promotional Programs are subject to the arbitration provisions (Section 11.3) and class action waiver (Section 11.4) of these Terms. By participating in any Promotional Program, you agree that disputes will be resolved individually and not as part of a class action, consolidated action, or representative proceeding.

Liability:

Our total liability for any Promotional Program shall not exceed the fair market value of the promotional benefit at issue (e.g., the equivalent GEN credit value of a single digital record creation). The liability limitations of Section 8.3 apply to all Promotional Programs.

5.3 Transaction Risks

Blockchain Transactions:

• Irreversible: Blockchain transactions are intended to be irreversible under normal operation and generally cannot be reversed, subject to technical limitations
• No Guarantee: We provide no guarantee of transaction success due to network conditions
• Network Conditions: Transactions may fail due to network congestion

5.4 Blockchain Data Characteristics and Soulbound Protection

Soulbound Digital Record Protection:

Digital Records are implemented as soulbound tokens using Token-2022 with the NonTransferable extension. This provides the following protections:

• Non-Transferable at Token Level: Digital records are soulbound and cannot be transferred at the smart-contract level. Ownership changes are handled exclusively through the managed Record Transfer process (freeze + re-mint), described in Section 5.10
• On-Chain Linkage: Digital records are tied to the wallet address that created them
• Recovery Phrase Compromise Protection: Even if someone gains access to your recovery phrase, they cannot transfer your digital records
• Record Protection: Non-transferability prevents transfer-based theft, and on-chain history cannot be erased; however, compromised credentials can still allow unauthorized wallet actions permitted by protocol rules
• Audit Trail: All actions are recorded on-chain and cannot be hidden

What This Means: While a compromised recovery phrase allows someone to act as the wallet owner, it does not allow them to alter the underlying record itself. The verification fingerprint is stored on-chain as a tamper-evident cryptographic commitment. Core record fields (name, species, microchip) cannot be changed during upgrades, and any attempt to modify local data will fail verification against the on-chain fingerprint.

5.4.1 Breeder Information Transparency

For pets acquired from breeders, you may optionally include breeder information on the blockchain. This feature helps buyers verify where pets come from and supports responsible breeding practices.

What is stored on-chain (if provided):

• Breeder or kennel name
• Breeder registration number (if applicable)
• Breeder location (city/country only)

5.4.2 Breeder Information Opt-Out

If you are a breeder and do not wish to have your information stored on the blockchain:

• Before Minting: Simply do not enter breeder information during the minting process. All breeder fields are optional.
• After Minting: Breeder information generally cannot be removed from existing digital records due to the append-only nature of blockchain technology. You may revoke the digital record and re-mint without breeder information (standard minting fees apply).
• Future Digital Records: Contact us at [email protected] to request that your account be flagged to exclude breeder information from all future mints.

Note: Omitting breeder information may reduce the verifiability and documentation value of the Digital Record.

5.5 Digital Records Are Digital Titles, Not Securities

5.5.1 Nature of Digital Records

Digital Records are digital titles (similar to car titles or property deeds) designed exclusively for pet ownership verification and digital record-keeping purposes. They are NOT:

• Investment instruments, securities, or financial products
• Investment contracts under U.S. securities laws
• Intended for resale, trading, or speculation
• Guaranteed to have any monetary or resale value
• Promised to appreciate in value or generate profits
• Endorsed as investment opportunities

5.5.2 Digital Title Purpose

Digital Records function as digital titles (like car titles or property deeds) and are intended solely for:

• Proof of pet ownership and record verification
• Blockchain-backed pet ownership records
• Pet identification and ownership records
• Pet health record management
• Verification and attestation purposes

Ownership Changes: Ownership changes (adoption, rehoming) are handled through the managed Record Transfer process described in Section 5.10. The current record is frozen and a new record is re-minted to the recipient's wallet. In cases where a transfer is not possible, the record may be revoked and re-created (see Section 5.7).

Digital Records are NOT intended for:

• Resale or trading
• Investment or speculation
• Marketplace trading
• Profit generation

5.5.3 Non-Transferability and Resale Restrictions

You acknowledge and agree that:

• Digital records are digital titles (like car titles or property deeds), NOT investment instruments
• Digital records have no inherent monetary or resale value
• Digital records are NOT intended for resale, trading, or speculation
• Digital records should not be purchased with expectation of profit or value appreciation
• Digital records are soulbound (non-transferable at the token level) — ownership changes are handled exclusively through the managed Record Transfer process (see Section 5.10)
• We make no promises about digital record value, utility, or resale potential
• Digital records are provided "as-is" without warranties
• We do NOT facilitate, endorse, or support digital record resale or trading

5.5.4 Functional Exhaustion

Each Digital Record (on-chain digital title) conveys no rights beyond verification and record linkage. Specifically, each token confers:

• No financial interest in Nebula Genesis Tech, LLC or any affiliated entity
• No revenue share, dividend, royalty, or profit participation of any kind
• No governance rights, voting power, or decision-making authority
• No claim on company assets, intellectual property, or future earnings
• No transferability — the token is soulbound and cannot be sold, traded, or assigned

The token's sole function is to serve as a cryptographically verifiable credential linking a pet's record to a tamper-evident on-chain entry. This functional scope is enforced both contractually (by these Terms) and technically (by the Solana Token-2022 NonTransferable extension at the smart contract level).

5.5.5 Regulatory Compliance

We comply with applicable laws regarding utility tokens and digital titles. If regulatory guidance changes, we may modify or discontinue features to ensure compliance. Digital Records are designed and marketed exclusively as cryptographically verifiable credentials for pet ownership verification, not as investment instruments.

5.6 Digital Record Metadata Update Fees (Planned Feature)

5.6.1 Update Fee Purpose

Update fees are for updating blockchain records only. These fees:

• Maintain blockchain-digital pet records
• Are utility service fees for record maintenance, paid with GEN credits
• Are NOT investment vehicles, investment opportunities, or securities
• Do NOT create investment value, generate profits, or represent profit opportunities

Fees reflect recordation and maintenance costs, not access to features or value creation. This is a record update service fee, NOT an investment fee.

5.6.2 Fee Structure

Update Fee: GEN credits per blockchain record update. Contact us for current pricing.

5.6.3 What Updates Cost

Vital Records (Optional):

• Rabies shots: GEN credits per update (if on-chain update desired)
• Distemper shots: GEN credits per update (if on-chain update desired)
• Parvovirus shots: GEN credits per update (if on-chain update desired)
• Alternative: Free off-chain storage (no blockchain update)

Routine Records (Optional):

• Routine checkups: GEN credits per update (if on-chain update desired)
• Weight updates: GEN credits per update (if on-chain update desired)
• Photo updates: GEN credits per update (if on-chain update desired)
• Default: Free off-chain storage (no blockchain update)

Note: All records can be stored off-chain for free. On-chain updates are optional and use GEN credits.

5.6.4 Comparison to Official Records

Our fees are comparable to official record maintenance fees. This is a record maintenance service, NOT an investment service.

5.7 Digital Record Revocation (On-Chain Destruction)

What is Digital Record Revocation?

Digital record revocation is intended to irreversibly destroy your Digital Record on the blockchain under normal operation. This action is generally irreversible, subject to technical limitations.

Revocation Process:

• You initiate the revocation from within the app
• You sign the revocation transaction with your wallet
• Nebula Genesis Tech co-signs and submits the transaction
• The digital record is intended to be irreversibly destroyed on the blockchain under normal operation

Revocation Fees and Economics:

• Revocation is FREE for users (no fee charged)
• Nebula Genesis Tech pays the blockchain transaction fee (~$0.000001)
• Rent recovery from the revoked digital record (~$0.002 SOL) is returned to Nebula Genesis Tech's master wallet, NOT to the user

Re-Minting After Revocation:

• After revocation, you may create a new digital record for the same pet
• Re-minting requires GEN credits or a free mint token
• The new digital record will have a new mint address and blockchain ID

5.8 Veterinary Professional Attestations

Licensed veterinary professionals may create attestations documenting professional observations about pets with digital records.

5.8.1 Attestation Types

Veterinary professionals may create the following types of attestations:

• Microchip verification
• Health examination attestations
• Vaccination record attestations
• Ownership attestations
• Record confirmation
• Professional duty reports (welfare concerns)

5.8.2 Attestation Fees

Fee Structure:

• Attestation Fee: Fee per attestation, billed to the veterinary practice account
• Practice Billing: Practices may pass attestation fees to clients as part of their service fees
• Volume Packages: Custom GEN credit packages available for practices creating multiple attestations

Partner Program:

• Veterinary practices may participate in our partner program for custom GEN credit packages
• Partner terms are specified in the Veterinary Partner Agreement
• Contact [email protected] for current partner terms and pricing options

5.8.3 Veterinary Professional Requirements

To create attestations, veterinary professionals must:

• Hold a valid veterinary license in their jurisdiction
• Provide license information for verification (hashed for privacy)
• Agree to the Veterinary Partner Terms of Service
• Create attestations based on genuine professional observations

5.8.4 Attestation Durability

5.8.5 Professional Liability

Veterinary professionals are responsible for:

• The accuracy of their professional attestations
• Compliance with professional standards and regulations
• Maintaining appropriate professional liability insurance

Nebula Genesis Tech is not liable for the accuracy of veterinary attestations or professional judgments made by veterinary professionals.

5.8.6 Use of Attestation Data

Attestation data submitted by veterinary professionals may be aggregated and de-identified for public health analytics, disease surveillance, and veterinary research purposes as described in Section 9.4. Individual attestations will not be identifiable in any published analytics or shared datasets.

What is aggregated: Condition codes, species, breed, geographic region (state-level only), severity classifications, and temporal trends. Aggregated data does not include individual pet identifiers, wallet addresses, veterinary professional identities, or clinic names.

Veterinary professional acknowledgment: By creating attestations through the App, veterinary professionals acknowledge that attestation data will be aggregated and de-identified for the purposes described in Section 9.4 and Section 9.5. This processing is based on legitimate interest (GDPR Article 6(1)(f)) for public health purposes. Veterinary professionals may object to this processing under GDPR Article 21 by contacting [email protected]; objection will not affect data already aggregated. This acknowledgment is also reflected in the Veterinary Partner Agreement.

5.9 GEN Credits

GEN credits ("Credits") are the in-app service entitlements used to pay for digital record creation, metadata updates, veterinary attestations, and other paid features within the App.

5.9.1 Nature of Credits

• Credits are a prepaid service entitlement, not a stored-value instrument, cryptocurrency, security, or investment
• Credits have no cash value and cannot be redeemed for cash, cryptocurrency, or any other form of currency
• Credits represent the right to consume specific App services at the rate in effect when the Credit is spent
• We reserve the right to modify the number of Credits required for any service at any time, with reasonable notice posted in the App

5.9.2 Purchase and Pricing

• Credits may be purchased through the App via in-app purchase (Apple App Store or Google Play) or Stripe Checkout (credit or debit card), depending on availability. Credits fund real-world operational costs — specifically, blockchain transaction fees (gas), on-chain storage rent, and infrastructure costs incurred when minting Digital Records on the Solana network. Credits are not digital content consumed within the App; they are prepaid entitlements to external blockchain services performed on your behalf
• In-App Purchases: Credit packs purchased through the Apple App Store or Google Play are subject to the applicable Platform Store's terms of service and billing policies. Refunds for Platform Store purchases must be requested through the Platform Store (see Section 6.3.4)
• Stripe Purchases: Credit purchases processed by Stripe are subject to Stripe's terms of service
• Prices are listed in the App at the time of purchase and may change without prior notice
• Credits are added to your account upon successful payment confirmation from the applicable payment provider

5.9.3 Refund Policy

GEN credit purchases are final and non-refundable, except in the following circumstances:

• Failed blockchain operations: If a blockchain operation paid with Credits fails due to a technical error on our part (e.g., failed mint, failed metadata update), the deducted Credits will be restored to your account within 14 business days
• Applicable law: Where a refund is required by applicable consumer protection law

Credits cannot otherwise be returned, exchanged, or converted to cash. If a chargeback or payment reversal is processed through Stripe or a Platform Store, we may deduct the corresponding Credits from your account. For Credits purchased via in-app purchase, refund requests must be directed to the applicable Platform Store (see Section 6.3.4).

5.9.4 No Expiration

Credits are generally non-expiring during normal operation and are intended to remain in your account while your account remains in good standing. If your account is terminated for violation of these Terms, any remaining Credits are forfeited.

5.9.5 Non-Transferable

Credits are non-transferable. You may not sell, trade, gift, or otherwise transfer Credits to any other user, account, or wallet. Any attempt to transfer Credits outside the App is a violation of these Terms and may result in account suspension or termination.

5.9.6 Promotional Credits

We may issue promotional or bonus Credits at our discretion. Promotional Credits are subject to the same terms as purchased Credits unless otherwise specified at the time of issuance. See Section 5.2.1 for promotional program terms.

5.9.7 Account Termination

If your account is terminated by us for cause (violation of these Terms), all remaining Credits — whether purchased or promotional — are forfeited without refund.

Voluntary Account Deletion: Credits are associated with your wallet address, not with a server-side account. If you delete local app data (Settings > Clear All Data) or uninstall the App, your Credits remain on our server associated with your wallet address. If you restore your wallet from your seed phrase, your credit balance will be accessible again. However, if you request server-side data erasure (see Section 10.3.3), any remaining Credits — purchased or promotional — are forfeited as part of that erasure, except as required by applicable consumer protection law (see Section 5.9.3). Promotional Credits are forfeited immediately upon any form of account deletion.

5.9.8 Service Discontinuation

If we discontinue the GEN credit system or cease operating the App, we generally aim to provide at least 90 days' notice, where reasonably practicable, during which you may use your remaining Credits for any available service. After the notice period, any unused Credits may expire. We are not obligated to provide monetary refunds for unused Credits upon service discontinuation, except as required by applicable law.

5.9.9 Applicable Law; Savings Clause

To the extent that GEN Credits are deemed a stored-value product, gift card, gift certificate, or similar instrument under applicable federal, state, or local law (including but not limited to California Civil Code § 1749.5, or equivalent consumer protection statutes in other jurisdictions), the provisions of that law control over any conflicting term in this Section 5.9. This includes, without limitation, any statutory rights to:

• Cash redemption of small remaining balances
• Prohibition of expiration dates or service fees
• Escheatment of unredeemed balances to the state

Nothing in these Terms is intended to waive, limit, or override any consumer protection rights that applicable law does not permit to be waived. If any provision of this Section 5.9 is held unenforceable under applicable law, that provision shall be modified to the minimum extent necessary to comply, and the remaining provisions shall continue in full force and effect.

5.9.10 Money Transmitter Analysis

We have analyzed GEN Credits under applicable federal and state money transmission laws. Based on the following characteristics, we have determined that GEN Credits do not constitute money transmission, stored value, or virtual currency requiring licensure: (a) Credits are non-transferable between users; (b) Credits have no cash value and cannot be redeemed for currency; (c) Credits generally do not expire during normal operation, subject to discontinuation treatment in Section 5.9.8; (d) Credits can only be used to purchase services within the App; (e) Credits cannot be exchanged, sold, or converted to any form of currency or cryptocurrency. This analysis is consistent with FinCEN guidance on prepaid access (31 CFR 1010.100(ww)) and the "closed loop" exemption available in most state money transmitter statutes. We will reassess this determination if Credit functionality changes or regulatory guidance evolves.

5.10 Record Transfers

The App provides a controlled Record Transfer feature that allows you to transfer a digital record to another user through a managed process (freeze + re-mint). This is the only supported method for transferring ownership of a digital record.

5.10.1 Transfer Process

• Transfers are initiated by the current record holder and require in-app authentication and confirmation
• The original record is frozen and a new record is re-minted to the recipient upon successful completion
• Transfers may require the use of a transfer code or similar credential to complete delivery
• Transfers may be subject to fees (see Section 5.9)

5.10.2 Finality and Irreversibility

All Record Transfers are final and irreversible once completed. You acknowledge and agree that:

• Transfers cannot be canceled, undone, or reversed after completion
• This applies to all circumstances, including user error, incorrect recipient information, unauthorized access, or fraud
• Blockchain transactions and re-minting operations are permanent by design

5.10.3 Responsibility for Recipient Accuracy

You are solely responsible for ensuring that all recipient information and transfer credentials are accurate and securely handled. Nebula Genesis does not verify recipient identity.

• If you send a record to the wrong recipient, the transfer cannot be reversed
• If transfer credentials are shared, lost, or intercepted, any resulting transfer is considered authorized

5.10.4 Transfer of Control and Ownership

Completion of a Record Transfer permanently assigns control of the digital record to the recipient's wallet.

• The recipient becomes the sole controller of the record upon completion
• Nebula Genesis does not retain custody, access, or control of transferred records after completion
• Ownership is defined by control of the receiving wallet and associated credentials

5.10.5 No Custodial Relationship

Nebula Genesis acts solely as a technical facilitator of Record Transfers.

• We do not act as a custodian, escrow agent, broker, or intermediary with control over digital records
• At no point do we take possession or ownership of records being transferred
• We do not guarantee delivery, receipt, or successful completion of any transfer

5.10.6 Transfer Availability and Expiration

• Transfer requests, codes, or delivery mechanisms may expire if not completed within a specified time period
• Unclaimed or expired transfers may require re-initiation and may incur additional fees
• We are not responsible for failed or incomplete transfers due to expiration, user inaction, or technical issues outside our control

5.10.7 No Dispute Resolution

Nebula Genesis does not mediate, adjudicate, or resolve disputes related to Record Transfers.

• All transfer-related disputes are solely between the sending and receiving parties
• We are not responsible for recovering transferred records under any circumstances

5.10.8 Data Included in Transfers

Record Transfers may include associated metadata, attestations, lineage links, and other record data as defined by the App at the time of transfer.

• Certain data (such as lineage links) is on-chain and cannot be modified or removed after transfer
• Health and related data may be transmitted via encrypted bundles subject to the Privacy Policy

6. Payment Terms

6.1 Digital Record Creation Payments

• Price: Powered by GEN credits (see current pricing in the App)
• Payment Method: GEN credit system
• We do not store: Sensitive payment information

6.2 Refund Policy

Refund Eligibility:

• Failed Mints (GEN Credits): If a digital record creation paid with GEN Credits fails due to a technical error on our part, the deducted Credits will be restored to your account in accordance with Section 5.9.3
• Successful Mints: No refunds for successfully created digital records (blockchain transactions are irreversible)

For GEN credit purchase refund terms, see Section 5.9.3.

No Refunds For:

• Successfully created digital records
• User error (e.g., wrong wallet address)
• Change of mind after minting

6.3 Subscription Services

The App offers optional monthly subscription plans that provide access to premium features. Subscriptions are billed through the Apple App Store or Google Play Store (collectively, "Platform Stores"), not through Stripe or direct payment.

6.3.1 Available Plans

Current subscription plans and pricing are displayed in the App at the time of purchase. Plans may include, but are not limited to, premium feature access, increased usage limits, and professional tools. We may add, modify, or discontinue subscription plans at any time.

6.3.2 Billing and Auto-Renewal

• Recurring Billing: Subscriptions are billed on a recurring monthly basis through your Platform Store account. Payment is charged to your Platform Store account at confirmation of purchase
• Auto-Renewal: Your subscription automatically renews each billing period unless you cancel at least 24 hours before the end of the current period. Your Platform Store account will be charged for renewal within 24 hours prior to the end of the current period at the then-current subscription price
• Price Changes: We may change subscription prices at any time. Price changes take effect at the start of the next billing period following notice. If you do not agree to a price change, you may cancel your subscription before the change takes effect

6.3.3 Cancellation

• How to Cancel: You may cancel your subscription at any time through your device's subscription settings (Apple: Settings > [Your Name] > Subscriptions; Google: Google Play > Payments & subscriptions > Subscriptions). Cancellation must be done through the Platform Store, not through the App
• Effect of Cancellation: When you cancel, your subscription remains active until the end of the current billing period. You will not be charged for the next period. Premium features associated with your subscription will become unavailable at the end of the paid period
• No Partial Refunds: We do not provide refunds or credits for partial subscription periods

6.3.4 Subscription Refunds

Subscription purchases are managed entirely by the Platform Store. Refund requests for subscriptions must be directed to Apple or Google, as applicable:

• Apple: Request a refund from Apple
• Google: Request a refund from Google Play

We are not responsible for the refund policies of the Platform Stores. Refund eligibility is determined by the applicable Platform Store's policies.

6.3.5 Platform Store Terms

Subscription purchases are subject to the terms and conditions of the applicable Platform Store, including the Apple Licensed Application End User License Agreement and Google Play Terms of Service. In the event of a conflict between these Terms and the Platform Store terms regarding subscription billing, the Platform Store terms shall control.

6.3.6 Relationship to GEN Credits

Subscriptions and GEN Credits are separate payment mechanisms. Subscriptions unlock premium features and usage limits; GEN Credits are used for individual blockchain operations (see Section 5.9). Purchasing a subscription does not grant GEN Credits, and purchasing GEN Credits does not grant subscription benefits, unless explicitly stated in the App at the time of purchase.

7. Health Information Disclaimer

8. Limitation of Liability

8.1 Service Provided "As-Is"

No Warranties:

• The App is provided "as-is" and "as-available"
• We make no warranties, express or implied
• We do not guarantee uninterrupted or error-free operation
• We do not guarantee data accuracy or completeness

8.2 Disclaimers

We are not liable for:

• Data Loss: Loss of data due to device failure, app deletion, user error, local-only storage, or any other cause
• Backup Responsibility: You are solely responsible for backing up your data - we do NOT provide cloud backup
• Local Storage: Data is stored locally on your device - if your device is lost, stolen, or reset, data is generally irrecoverable, subject to your own backups and technical limitations
• Blockchain Risks: Losses from blockchain transactions, wallet access, digital record functionality changes, or blockchain network issues
• Service Interruptions: Temporary unavailability of the App or features
• Health Decisions: Any health decisions made based on App information - we are NOT responsible for pet health outcomes
• Security Breaches: Losses from device compromise, malware, or unauthorized access despite encryption
• Early Adoption: Any issues, bugs, or data loss encountered while using the App
• Force Majeure: Service interruptions due to events beyond our reasonable control

8.2.1 Payment Processing

Service: Digital record creation and record updates are powered by the GEN credit system.

We are NOT liable for:

• Third-party payment processing service interruptions, outages, or failures
• Payment processing errors or delays
• Third-party security breaches or data breaches
• Third-party handling of your payment information

8.2.2 Blockchain Network (Solana)

Service: Digital record creation and blockchain transactions use the Solana blockchain (mainnet-beta), a decentralized blockchain network.

We are NOT liable for:

• Blockchain network congestion, outages, or failures
• Blockchain transaction failures, delays, or reversals
• Blockchain network security issues, attacks, or vulnerabilities
• Blockchain network forks, upgrades, or protocol changes
• Validator failures or network consensus issues
• Transaction fees or gas costs
• Losses from blockchain network issues beyond our control
• Any blockchain network changes that affect digital record functionality

Decentralized Network: We use a decentralized blockchain network. We have no control over the blockchain network, its validators, or its operations.

Network Risks: Blockchain networks are subject to various risks including network congestion, security vulnerabilities, and protocol changes. These risks are inherent to blockchain technology and beyond our control.

8.2.3 Crash Reporting and Error Monitoring

If you enable crash reporting in Settings > Privacy, the App may send de-identified error reports to a third-party error monitoring service to help us identify and fix bugs. These reports contain technical diagnostic information (device type, OS version, error stack traces) and do not include your pet data, wallet addresses, or personal information. You can disable crash reporting at any time through Settings > Privacy.

8.2.4 General Third-Party Service Disclaimers

• Beyond Our Control: Third-party services operate independently of us. We have no control over their operations, security practices, availability, or terms of service.
• No Endorsement: Reference to third-party services does not constitute endorsement. We are not responsible for third-party service quality, accuracy, or reliability.
• Your Responsibility: You are responsible for reviewing and accepting third-party service terms of service and privacy policies.
• No Warranty: We make no warranties regarding third-party services. Third-party services are provided "as-is" without warranty of any kind.
• Indemnification: You agree to hold us harmless from any claims, losses, or damages arising from third-party service issues, failures, or breaches.

8.3 Maximum Liability

8.4 User Indemnification

You agree to indemnify, defend, and hold harmless Nebula Genesis Tech, LLC, its affiliates, officers, directors, employees, agents, and licensors from and against any and all claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable attorneys' fees) that such parties may incur as a result of or arising from:

• Your use of or access to the App
• Your violation of these Terms
• Your violation of any rights of another party (including intellectual property rights or privacy rights)
• Your violation of any applicable laws or regulations
• Your misuse of blockchain features or wallet functionality
• Your creation of content that infringes on third-party rights
• Your failure to maintain the security of your account credentials or recovery phrase
• Any health decisions or actions you take based on App information

We reserve the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you will cooperate with us in asserting any available defenses.

9. Intellectual Property

9.1 Our Property

The App, including its design, code, features, and branding, is owned by Nebula Genesis Tech, LLC and protected by intellectual property laws. Certain aspects of the App are the subject of U.S. Patent Application No. 19/462,031 (Patent Pending). No license or right under any patent is granted by these Terms except the right to use the App as described herein.

9.2 Your Content

You retain ownership of your pet data, photos, and content. By using the App, you grant us a limited, non-exclusive, royalty-free license to process your data for (a) providing App services, and (b) creating aggregated, de-identified datasets as described in Section 9.4.

9.3 Digital Records

When you create a Digital Record, you own the digital record on the blockchain. The underlying pet data remains stored locally on your device.

9.4 Aggregated and De-Identified Data

We may aggregate and de-identify data from multiple users to create de-identified datasets that cannot reasonably be used to identify any individual user, pet, or veterinary professional. Such aggregated, de-identified data may be used for:

• Platform analytics and service improvement
• Public health surveillance and disease trend monitoring
• Statistical analysis and research
• Industry reporting and benchmarking
• Publication of de-identified trend reports

De-identification Standards: Aggregated data will be de-identified in accordance with HIPAA Safe Harbor standards (45 CFR 164.514(b)) or equivalent methodologies, even where HIPAA does not directly apply. Minimum aggregation thresholds apply to all published datasets to prevent re-identification of individuals from small population cells. We do not intend to re-identify aggregated data to individual users and will not knowingly attempt to do so except as required to comply with applicable law.

Opt-Out: By using the App, you acknowledge the creation and use of aggregated, de-identified data as described in this section. You may opt out at any time through Settings > Privacy > Data Analytics. When you opt out, your wallet is excluded from all server-side aggregated analytics views going forward. Opting out will not affect data already aggregated prior to opt-out. If you are located in the European Economic Area, you have the right to object to this processing under GDPR Article 21 (see Privacy Policy Section 10.4).

9.5 Data Partnerships and Public Health Sharing

We may share aggregated, de-identified datasets with:

• Government agencies (e.g., USDA, state veterinarian offices, CDC)
• Academic and research institutions
• Veterinary industry organizations
• Public health authorities

for the purpose of disease surveillance, outbreak detection, and animal welfare improvement. Such sharing will only involve aggregated, de-identified data that cannot identify individual users, pets, or veterinary professionals.

Data Sharing Agreements: Data sharing partnerships with government agencies and research institutions will:

• Be documented in written agreements specifying permitted uses
• Prohibit re-identification of individual records
• Require data security standards equivalent to our own
• Be disclosed in our Privacy Policy
• Not include any individually identifiable data without separate, explicit user consent
• Include breach notification obligations (see Privacy Policy Section 5 for governance details)

No Identifiable Data: We will not share identifiable user data with government agencies except as required by valid legal process (subpoena, court order, or statutory mandate).

Opt-Out: You may opt out of having your data included in datasets shared with third parties through Settings > Privacy > Data Sharing. When you opt out, your wallet is excluded from all server-side data sharing views going forward. Data already aggregated and shared prior to opt-out cannot be recalled or traced back to you individually. If you are located in the European Economic Area, you have the right to object to this processing under GDPR Article 21 (see Privacy Policy Section 10.4).

Not a Sale: Sharing of aggregated, de-identified data for public health purposes does not constitute a "sale" of personal information under applicable privacy laws, including the California Consumer Privacy Act (CCPA), because (a) the data is de-identified and no longer constitutes personal information under CCPA Section 1798.140(o), and (b) the sharing is for public health purposes as permitted under CCPA Section 1798.145(a)(5). We do not receive monetary consideration for sharing de-identified data. If we enter into a data sharing arrangement where we receive monetary or other valuable consideration, we intend to update these Terms and our Privacy Policy and provide any required opt-out mechanisms before such sharing begins, to the extent required by applicable law.

9.6 Copyright Infringement (DMCA)

Nebula Genesis Tech, LLC respects the intellectual property rights of others and expects users to do the same. We respond to notices of alleged copyright infringement that comply with the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. 512.

9.6.1 Designated Agent

Our designated agent for receiving DMCA takedown notices is:

9.6.2 Takedown Notification

If you believe that content available through the App infringes your copyright, you may submit a written notification to our designated agent containing:

• A physical or electronic signature of the copyright owner or authorized agent
• Identification of the copyrighted work claimed to have been infringed
• Identification of the material that is claimed to be infringing, with information reasonably sufficient for us to locate it
• Your contact information (address, telephone number, and email)
• A statement that you have a good faith belief that the use is not authorized by the copyright owner, its agent, or the law
• A statement, under penalty of perjury, that the information in the notification is accurate and that you are authorized to act on behalf of the copyright owner

9.6.3 Counter-Notification

If you believe your content was removed or disabled by mistake or misidentification, you may submit a counter-notification to our designated agent containing:

• Your physical or electronic signature
• Identification of the material that was removed or disabled and its prior location
• A statement under penalty of perjury that you have a good faith belief the material was removed or disabled as a result of mistake or misidentification
• Your name, address, telephone number, and a statement consenting to jurisdiction of the federal court in Cook County, Illinois

9.6.4 Repeat Infringer Policy

We may terminate or disable accounts of users who are repeat infringers, in appropriate circumstances. A user may be deemed a repeat infringer if they are the subject of more than two valid takedown notices within any 12-month period.

9.6.5 Blockchain Data Limitation

Due to the append-only nature of blockchain technology, data recorded on the Solana blockchain is intended to be irreversible under normal operation and generally cannot be removed or modified, subject to technical limitations. DMCA takedown actions are limited to content within the App's local storage and servers, except as required by law or legal process. See Section 5.4 for information about blockchain data characteristics.

10. Termination

10.1 Termination by You

You may terminate your account at any time by:

• Using Settings → Clear All Data to delete your account, wallet keys, and all associated data. Back up your seed phrase before proceeding — wallet keys cannot be recovered after deletion.
• Uninstalling the App
• Contacting us at [email protected]

10.2 Termination by Us

We may suspend or terminate your access, with or without advance notice where permitted by applicable law, if:

• You violate these Terms
• You engage in illegal activities
• You abuse the App or attempt to compromise its security
• Required by law or court order

10.3 Data Erasure

You have three methods to delete your data, each covering a different layer:

10.3.1 Device Data (Self-Service, Immediate)

Use Settings > Clear All Data to permanently delete all locally stored data, including your account, pet records, photos, wallet private keys, authentication tokens, and app settings. This action is immediate and irreversible. Back up your seed phrase before proceeding — wallet keys cannot be recovered after deletion. This does not notify our servers or affect server-side data.

10.3.2 On-Chain Digital Records (Self-Service, Immediate)

You may revoke (destroy) any Digital Record you own through the App's revocation feature (see Section 5.7). Revocation destroys the on-chain token and is intended to be irreversible under normal operation. Historical blockchain transaction records and any photos stored on decentralized long-duration storage (Arweave) remain after revocation, as these are outside our control.

10.3.3 Server-Side Operational Data (Request-Based)

To request deletion of server-side operational data associated with your wallet address (such as push notification tokens, transaction records, analytics preferences, and related operational data), contact [email protected] with your name, email, wallet address (if known), and an explicit deletion request. See Privacy Policy Section 6.2 for full details, required information, and response timelines.

Data We Retain After Erasure:

• Financial records: Transaction records, payment records, credit ledger entries, and dispute records are retained as required by applicable tax and financial reporting obligations
• Security records: Blacklist entries, fraud-prevention signals, and abuse-detection data are retained to protect the platform and other users
• Blockchain data: On-chain transactions, wallet addresses, and Digital Record history are on-chain, tamper-evident, and generally not deletable (see Section 5.4)
• Decentralized storage: Photos uploaded to long-duration decentralized storage (Arweave) generally cannot be deleted by us or any party

Where data is retained, identity-linked fields are anonymized so that the retained records cannot reasonably be linked back to you. For detailed information about what is deleted, anonymized, and retained, see our Privacy Policy Section 6.2.

10.4 Effect of Termination

Upon termination:

• Your local data will be deleted if you clear the app data or uninstall
• Blockchain data (digital records, transactions) will remain on the blockchain indefinitely unless you revoke your Digital Records before termination (see Section 10.3.2)
• Your wallet remains accessible if you have your seed phrase
• Any remaining GEN Credits are handled in accordance with Section 5.9.7 (forfeiture on termination for cause; credits persist with wallet address on voluntary deletion unless server-side erasure is requested)
• You may request server-side data erasure in accordance with Section 10.3.3

10.5 Company Dissolution or Cessation of Operations

If Nebula Genesis Tech, LLC ceases operations, dissolves, enters bankruptcy, or assigns its assets:

• Digital records survive: Digital Records are soulbound tokens on the Solana blockchain. They exist independently of Nebula Genesis Tech's operations and will remain on-chain indefinitely regardless of the company's status
• Creation authority ceases: New digital record creation, metadata updates, veterinary attestations, and record revocations require the company's mint authority key. These operations will become unavailable if the company ceases operations
• Wallet access preserved: Your self-custodial wallet and all existing digital records remain accessible via your 12-word recovery phrase. No action by Nebula Genesis Tech is required to view or demonstrate ownership of your digital records
• GEN Credits: Handled in accordance with Section 5.9.8 (Service Discontinuation)
• Open-source commitment: In the event of cessation of operations, we may make commercially reasonable efforts to release digital record verification tooling under an open-source license so that third parties can independently verify Digital Records on-chain, where feasible and to the extent permitted by applicable law

User Responsibility: You are responsible for securely backing up your 12-word recovery phrase at all times. Nebula Genesis Tech cannot recover lost recovery phrases, and this limitation becomes absolute upon dissolution.

11. Dispute Resolution

11.1 Governing Law

These Terms shall be governed by and construed in accordance with the laws of the State of Illinois, United States, without regard to conflict of law principles. This applies regardless of your location or jurisdiction. See Section 12 (International Users & Jurisdiction) for additional information for international users.

11.2 Jurisdiction and Venue

Any legal action or proceeding arising out of or relating to these Terms shall be brought exclusively in the state and federal courts located in Cook County, Illinois, United States, and you consent to the jurisdiction of such courts. This applies regardless of your location or jurisdiction. See Section 12 (International Users & Jurisdiction) for additional information for international users.

11.3 Mandatory Arbitration

Except as otherwise provided, any dispute arising out of or relating to these Terms shall be resolved exclusively by binding arbitration in accordance with the Commercial Arbitration Rules of the American Arbitration Association (AAA), conducted in Cook County, Illinois.

Small Claims Exception: Notwithstanding the foregoing, either party may bring an individual action in small claims court for disputes or claims within the jurisdiction of the small claims court. If the claim is transferred, removed, or appealed to a different court, the arbitration agreement will apply.

Arbitration Opt-Out: You may opt out of this arbitration agreement by sending written notice to [email protected] within 30 days of first accepting these Terms. Your opt-out notice must include your name, email address, and a clear statement that you wish to opt out of arbitration. If you opt out, disputes will be resolved in state or federal courts in Cook County, Illinois.

Arbitration Costs: For claims of $10,000 or less, Nebula Genesis Tech will pay all AAA filing, administration, and arbitrator fees. For claims above $10,000, each party will bear its own costs and attorneys' fees incurred in connection with arbitration, unless otherwise required by applicable law or the arbitrator determines that a party has acted in bad faith, in which case the arbitrator may award costs and fees to the prevailing party.

11.4 Class Action Waiver

You agree that disputes will be resolved individually and not as part of a class action, consolidated action, or representative proceeding. This class action waiver applies to both arbitration and court proceedings, to the fullest extent permitted by law.

Severability of Class Action Waiver: If the class action waiver in this Section 11.4 is found to be unenforceable by a court of competent jurisdiction, then the entire arbitration agreement in Section 11.3 shall be void with respect to that claim, and the dispute shall proceed in court under Section 11.2 — not as class arbitration. The parties agree that class-wide arbitration is not permitted under any circumstances. All other provisions of these Terms remain in full force and effect.

11.5 International Arbitration Limitations

European Union: If you are a consumer habitually resident in the European Economic Area (EEA), the mandatory arbitration provision in Section 11.3 and the class action waiver in Section 11.4 do not apply to you to the extent they conflict with mandatory consumer protection laws of your Member State, including but not limited to EU Directive 2013/11/EU (Alternative Dispute Resolution) and Regulation (EU) No 524/2013 (Online Dispute Resolution). You retain the right to bring claims before the courts of your Member State in accordance with applicable EU law.

Other Jurisdictions: If you reside in a jurisdiction whose mandatory law prohibits binding pre-dispute arbitration agreements in consumer contracts, the arbitration and class action waiver provisions apply only to the extent permitted by the mandatory law of your jurisdiction. All other provisions of these Terms remain in full force and effect.

11.6 Jury Trial Waiver

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, YOU AND NEBULA GENESIS TECH EACH WAIVE THE RIGHT TO A JURY TRIAL FOR ANY DISPUTE ARISING OUT OF OR RELATING TO THESE TERMS OR YOUR USE OF THE APP. If mandatory arbitration under Section 11.3 does not apply (whether due to opt-out, unenforceability, or jurisdictional limitation), any dispute shall be tried before a judge sitting without a jury.

12. International Users & Jurisdiction

12.1 Applicability to International Users

These Terms apply to all users worldwide, regardless of your location or jurisdiction. By using the App, you acknowledge and agree that:

• Illinois Law Governs: These Terms shall be governed by and construed in accordance with the laws of the State of Illinois, United States, without regard to conflict of law principles, regardless of your location
• Illinois Jurisdiction: Any legal action or proceeding arising out of or relating to these Terms shall be brought exclusively in the state and federal courts located in Cook County, Illinois, and you consent to the jurisdiction of such courts
• No Local Law Override: The laws of your country, state, or jurisdiction do not override or modify these Terms, except to the extent required by mandatory local law
• Waiver of Local Protections: To the extent permitted by law, you waive any rights or protections afforded by the laws of your jurisdiction that conflict with these Terms

12.2 European Economic Area (EEA) Users

If you are located in the European Economic Area (EEA), the following additional provisions apply:

12.2.1 GDPR Compliance

• We comply with the General Data Protection Regulation (GDPR) (EU) 2016/679
• Your personal data is processed in accordance with GDPR requirements
• We respect your GDPR rights as detailed in Section 12.3

12.2.2 Data Storage

• Your data is stored locally on your device (local-first architecture)
• We do not transfer your personal data outside the EEA for processing on our servers (see Section 12.4 for de-identified data and third-party service transfers)
• Blockchain transactions involve decentralized validators worldwide, and payment processing may route through servers outside the EEA (see Section 12.4)

12.2.3 Legal Basis

We process your personal data based on:

• Your consent (for optional, non-blockchain features such as analytics)
• Contractual necessity (to provide App services, including blockchain digital record creation — on-chain data storage is an inherent requirement of the minting service you request, not a processing activity requiring separate consent)
• Legitimate interests (for service improvement and public health analytics, subject to your right to object under GDPR Article 21). See Privacy Policy Section 10.4 for detailed lawful basis analysis

12.3 GDPR User Rights

If you are located in the EEA, you have the following rights under GDPR:

• Right of Access (Article 15): Request a copy of your personal data. You can access your data through the App or export it (Settings → Export Data). We aim to provide a copy within 30 days, subject to applicable law.
• Right to Rectification (Article 16): Request correction of inaccurate data. You can update your data directly through the App. We aim to correct inaccurate data within 30 days, subject to applicable law.
• Right to Erasure (Article 17) - Right to Be Forgotten: Request deletion of your personal data. You can delete your data through the App (Settings → Clear All Data), which removes all local data including wallet keys and authentication tokens. Back up your seed phrase first. See Privacy Policy Section 6.2 for detailed deletion process. Note: Blockchain data (digital records, transactions) is on-chain and generally not deletable due to the append-only nature of blockchain technology.
• Right to Restrict Processing (Article 18): Request limitation of data processing. Contact us at [email protected] to request restriction. We aim to restrict processing within 30 days, subject to applicable law.
• Right to Data Portability (Article 20): Receive your data in a portable format. Use the Export Data feature (Settings → Export Data) to download your data in JSON format.
• Right to Object (Article 21): Object to processing of your personal data. You can opt out of data aggregation via Settings > Privacy > Data Analytics, and opt out of third-party data sharing via Settings > Privacy > Data Sharing. Contact us to object to other processing.
• Right to Withdraw Consent: Withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal. You can withdraw consent through Settings → Privacy or by contacting us.
• Right to Lodge a Complaint: Lodge a complaint with your local data protection authority. Contact information: https://edpb.europa.eu/about-edpb/board/members_en

12.3.1 Exercising Your Rights

• To exercise your GDPR rights, contact: [email protected]
• We aim to respond within 30 days and may extend to 60 days where permitted by applicable law and with notice
• We may require identity verification before processing requests

12.4 Data Transfer Disclaimers

Local-First Architecture:

• Your data is stored locally on your device
• We do not transfer your personal data to our servers or third parties for processing, except that we may create and share aggregated, de-identified data as described in Sections 9.4 and 9.5, where data is de-identified before any transfer occurs
• This local-first architecture minimizes data transfer risks

Third-Party Services:

• Payment processing may involve data transfer to third-party servers
• Third-party payment services process data in accordance with their own privacy policies
• Blockchain transactions are public and on-chain, intended to be irreversible under normal operation
• See Section 8.2 for third-party service disclaimers

Data Transfer Outside EEA: We do not transfer your personal data outside the EEA for processing on our servers — all app data processing occurs locally on your device. However, blockchain transactions involve decentralized validators operating worldwide (see Privacy Policy Section 2.5), and payment processing may route through servers outside the EEA. Cross-border transfer to blockchain validators is necessary for the performance of the digital record creation service you request (GDPR Article 49(1)(b)), as described in Privacy Policy Section 2.5.

12.5 Compliance with International Standards

We are committed to compliance with international privacy and data protection standards, including:

• OECD Privacy Guidelines: We adhere to principles of privacy by design, data minimization, purpose limitation, and accountability as outlined in the OECD Privacy Guidelines (updated 2013, with 2025 reaffirmations emphasizing accountability in blockchain contexts)
• UN Resolutions on Digital Privacy: We respect principles of consent, minimization, and security for digital identities as reflected in UN resolutions on privacy in the digital age (e.g., A/RES/78/213)
• EU eIDAS 2.0 (where applicable): While our App is not currently a regulated digital identity wallet under eIDAS 2.0, we design our wallet features with interoperability principles in mind, prioritizing user consent, security, and verifiable credentials where feasible
• Cross-Border Data Flow Safeguards: Our local-first architecture minimizes cross-border transfers, and where blockchain operations involve global validators, we rely on applicable lawful bases (including contractual necessity for requested minting and consent where required) and provide transparent disclosures as required by applicable law

Regulatory Monitoring: We monitor developments in international privacy frameworks and update our practices to maintain alignment with evolving standards, including:

• EDPB guidelines on blockchain applications (e.g., Guidelines 02/2025)
• Emerging digital identity regulations (e.g., eIDAS 2.0 implementation)
• Global data protection law updates
• Industry best practices for blockchain privacy

User Rights: Our commitment to international standards ensures that your rights under various frameworks (GDPR, CCPA, OECD principles) are respected, with appropriate limitations disclosed where technical constraints (e.g., the append-only nature of blockchain technology) apply. See Privacy Policy Sections 9-10 for detailed rights information.

12.6 International User Acknowledgment

By using the App from outside the United States, you acknowledge and agree that:

• U.S. Law Applies: U.S. laws and regulations may apply to your use of the App
• Export Compliance: You are responsible for compliance with export control laws
• Sanctions: You will not use the App if you are subject to U.S. sanctions or embargoes
• No Representation: We make no representation that the App is appropriate or available for use in your jurisdiction
• Your Responsibility: You are responsible for determining whether use of the App is legal in your jurisdiction

12.7 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You have the right to request that we disclose what categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collecting it, and the categories of third parties with whom we share it
• Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions (e.g., completing a transaction, detecting security incidents, complying with legal obligations). You can delete your local data through Settings > Clear All Data. For server-side deletion, contact [email protected]. Blockchain data is generally not deletable due to the append-only nature of blockchain technology (see Section 5.4)
• Right to Correct: You have the right to request correction of inaccurate personal information. You can update your data directly through the App
• Right to Opt-Out of Sale/Sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising. If our practices change, we will provide a "Do Not Sell or Share My Personal Information" mechanism before any such sharing begins
• Right to Limit Use of Sensitive Information: We do not use or disclose sensitive personal information for purposes other than those permitted under CCPA Section 1798.121
• Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny you services, charge different prices, provide a different quality of service, or suggest that you will receive different treatment for exercising your rights

Exercising Your Rights: To exercise your California privacy rights, contact [email protected] with the subject line "California Privacy Request." We will verify your identity before processing your request and respond within 45 days, with a possible extension to 90 days with notice. You may also designate an authorized agent to submit a request on your behalf.

Categories of Information: For detailed information about the categories of personal information we collect and our data practices, see our Privacy Policy.

12.8 Language and Translation

• English Language: These Terms are provided in English. Any translations are for convenience only
• Controlling Language: In case of conflict between English and translated versions, the English version controls
• No Translation Warranty: We do not warrant the accuracy of any translations

13. General Provisions

13.1 Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, that provision shall be modified to the minimum extent necessary to make it enforceable, or if modification is not possible, severed from these Terms. The invalidity or unenforceability of any provision shall not affect the validity or enforceability of any other provision, and the remaining provisions shall continue in full force and effect.

13.2 Entire Agreement

These Terms of Service, together with the Privacy Policy and any additional terms referenced herein (including Section 5.2.1 Promotional Program terms and any separate Official Rules for Competitive Allocation Events), constitute the entire agreement between you and Nebula Genesis Tech, LLC regarding your use of the App. These Terms supersede all prior or contemporaneous communications, proposals, and representations, whether oral or written, with respect to the App or its subject matter.

The Non-Binding Technical Overview is provided for informational purposes only and is not incorporated into these Terms or the Privacy Policy.

13.3 Assignment

We may assign or transfer these Terms, and any rights and licenses granted hereunder, without your consent in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of our assets. You may not assign or transfer these Terms or any rights hereunder without our prior written consent. Any attempted assignment in violation of this section is void. In the event of a permitted assignment, these Terms will bind and inure to the benefit of the parties and their respective successors and assigns.

13.4 Waiver

Our failure to enforce any right or provision of these Terms shall not constitute a waiver of that right or provision. Any waiver must be in writing and signed by Nebula Genesis Tech, LLC to be effective.

14. Contact Information

For questions about these Terms, contact us at:

15. Change Log

The following changes have been made to these Terms of Service:

Version 1.11.0 (April 6, 2026)

• Section 5.10 (NEW): Record Transfers — comprehensive legal framework for the transfer feature covering: transfer process (5.10.1), finality and irreversibility (5.10.2), responsibility for recipient accuracy (5.10.3), transfer of control and ownership via wallet control (5.10.4), no custodial relationship or escrow (5.10.5), transfer availability and expiration (5.10.6), no dispute resolution obligation (5.10.7), and data included in transfers (5.10.8)
• Section 5.4 (AMENDED): Updated "Non-Transferable" bullet to clarify that soulbound non-transferability applies at the token level, with ownership changes handled via the managed Record Transfer process (Section 5.10)
• Section 5.5.2 (AMENDED): Updated "Ownership Changes" paragraph to reference Record Transfer (Section 5.10) as the primary path, with revocation (Section 5.7) as fallback
• Section 5.5.3 (AMENDED): Updated non-transferability bullet to reference managed Record Transfer (Section 5.10) instead of revocation and re-minting

Version 1.10.0 (March 29, 2026)

• Language Sweep (AMENDED): Replaced "permanent", "immutable", and "immutability" with qualified alternatives ("on-chain", "tamper-evident", "durable", "append-only", "intended to be irreversible under normal operation, subject to network availability") throughout all body sections. Change log entries from prior versions are unmodified for historical accuracy.
• Section 2.1.1 (NEW): Health Record Integrity Checking — describes on-device SHA-256 hash computation, hash-only registration with backend, tamper-evidence capability, and explicit limitations (does not verify accuracy, completeness, authenticity, or clinical truthfulness)
• Section 2.2.1 (NEW): AI-Powered Features (Planned) — forward-looking disclosure for planned AI portrait features: data sent to AI providers, generated content handling, subscription tiers, and no-medical-use disclaimer. Marked as not currently available.
• Section 5.4 (AMENDED): Renamed from "Blockchain Immutability and Soulbound Protection" to "Blockchain Data Characteristics and Soulbound Protection". "Permanent Linkage" renamed to "On-Chain Linkage". "immutable cryptographic commitment" → "tamper-evident cryptographic commitment"
• Section 5.4.1 (AMENDED): "PUBLIC and PERMANENT" → "PUBLIC and ON-CHAIN, intended to be durable and irreversible". "blockchain immutability" → "append-only nature of blockchain technology"
• Section 5.5.4 (AMENDED): "immutable on-chain entry" → "tamper-evident on-chain entry"
• Section 5.7 (AMENDED): Renamed from "Permanent Destruction" to "On-Chain Destruction". "PERMANENT and IRREVERSIBLE" → "intended to be IRREVERSIBLE under normal operation"
• Section 5.8.4 (AMENDED): Renamed from "Attestation Permanence" to "Attestation Durability"
• Sections 9.6.5, 10.3, 11.1, 12.3, 12.4, 12.5 (AMENDED): Replaced "immutable"/"immutability"/"permanent" with "append-only nature of blockchain technology", "on-chain and tamper-evident", and "generally not deletable" throughout

Version 1.9.1 (March 23, 2026)

• Section 5.9.7 (AMENDED): Removed 30-day grace period mechanism for voluntary account deletion. Credits now persist on the server tied to the wallet address and survive local data deletion; credits are forfeited only upon explicit server-side data erasure request (Section 10.3.3). Consumer protection carve-out (Section 5.9.3) retained
• Section 10.4 (AMENDED): Updated GEN Credits cross-reference to reflect removal of 30-day grace period and replacement with wallet-address persistence model

Version 1.9.0 (March 19, 2026)

• Section 6.3 (NEW): Subscription Services — added auto-renewal disclosure, cancellation instructions (via Platform Store), subscription refund policy (directed to Apple/Google), Platform Store terms reference, and separation of subscriptions from GEN Credits
• Section 12.7 (NEW): California Privacy Rights (CCPA/CPRA) — added right to know, right to delete, right to correct, right to opt-out of sale/sharing, right to limit use of sensitive information, non-discrimination clause, and instructions for exercising rights. Renumbered former Section 12.7 (Language) to 12.8
• Section 8.2.3 (NEW): Crash Reporting and Error Monitoring — disclosed consent-gated crash reporting via third-party error monitoring service. Renumbered former Section 8.2.3 (General Third-Party Disclaimers) to 8.2.4
• Section 2.1 (AMENDED): Added push notifications to service description (appointment reminders, medication schedules, pet care alerts — with user permission)
• Section 5.1.1 (AMENDED): Biometric authentication now includes "or device passcode where biometrics are unavailable" for devices without biometric hardware
• Sections 2.3, 5.2, 6.1 (AMENDED): Updated "contact for pricing options" to "see current pricing in the App" to reflect the live GEN credit service catalog
• Section 5.9.2 (AMENDED): GEN Credits are now available for purchase via in-app purchase (Apple App Store and Google Play) in addition to Stripe Checkout. Removed statement that Credits are not sold through Platform Stores. Added Platform Store IAP terms, refund routing to Platform Stores, and separate Stripe purchase terms. Updated Section 5.9.3 refund clause to cover Platform Store chargebacks
• Section 10.3 (NEW): Data Erasure — three-layer deletion framework: device data (self-service, immediate via Clear All Data), on-chain Digital Records (self-service revocation per Section 5.7), and server-side operational data (request-based via privacy@). Discloses retained data categories (financial records, security records, blockchain, decentralized storage) and anonymization of identity-linked fields
• Sections 10.3–10.4 (RENUMBERED): Former Section 10.3 (Effect of Termination) renumbered to 10.4; former Section 10.4 (Company Dissolution) renumbered to 10.5. Section 10.4 updated to reference revocation option and server-side erasure
• Executive Summary (AMENDED): Added Subscriptions summary item; updated security summary to include device passcode fallback

Version 1.8.3 (February 21, 2026)

• Polish update: generalized remaining protocol-specific wording in Section 2.2 and tightened Section 5.1.2 recovery-phrase compromise language for concise defensiveness

Version 1.8.2 (February 21, 2026)

• Risk-boundary hardening update: added explicit prohibition on unauthorized non-public API/protocol access (including interoperability-based attempts) and added emergency-care escalation language for high-risk symptom outputs in Section 7

Version 1.8.1 (February 21, 2026)

• Condensed legal-language alignment update: simplified "Digital Record" definition, aligned Executive Summary security wording with Privacy Policy style, tightened Section 5.1.1 biometric language, and added explicit non-incorporation carve-out for the Non-Binding Technical Overview in Section 13.2

Version 1.8.0 (February 21, 2026)

• Terminology rebrand: Rebranded "Pet Identity Certificate" to "Digital Record" throughout all non-changelog clause text. Updated definition in Section 1.1 to use "Digital Record" as the primary term with historical reference to "Pet Identity Certificate"
• Pet-context identity language: Changed "identity fingerprint" to "verification fingerprint," "Identity Protection" to "Record Protection," "pet's identity" to "pet's record," and "Core identity fields" to "Core record fields" in Sections 5.1.2, 5.4, and 5.5.4
• No substantive changes: No changes to rights, obligations, fee structures, or data handling. This is a terminology update only

Version 1.7.3 (February 20, 2026)

• Section 5.9.7 (Clarified): Narrowed voluntary account deletion grace period — 30-day grace applies when user contacts support; using Clear All Data locally does not notify the server or trigger the grace period
• Section 9.4 (Clarified): Opt-out now enforced server-side — opted-out wallets excluded from all aggregated analytics views
• Section 9.5 (Clarified): Opt-out now enforced server-side — opted-out wallets excluded from all data sharing views
• Section 10.1 (Clarified): Clear All Data now explicitly states wallet keys are deleted; added seed phrase backup warning
• Section 10.3 (Clarified): GEN credit forfeiture cross-reference updated to reflect support-initiated grace period
• Section 12.3 (Clarified): Right to Erasure now mentions wallet keys and authentication tokens are included in deletion

Version 1.7.2 (February 20, 2026)

• Section 1.2 (AMENDED): E-rating alignment — added statement that the App is rated E for Everyone in app stores and that age requirements are for contractual capacity and legal compliance (COPPA), not content rating. Clarified "guardian" to "legal guardian."
• Section 1.3 (FIX): Corrected re-acceptance cross-reference from "see Section 1.1" to "the same in-app affirmative consent mechanism used when you first accept the Terms" (Section 1.1 is Definitions).

Version 1.7.1 (February 19, 2026)

• Section 12.2.3 (AMENDED): Clarified that blockchain certificate minting uses contractual necessity (GDPR Article 6(1)(b)), not consent, as its lawful basis — on-chain data storage is an inherent requirement of the minting service. Consent basis now limited to non-blockchain optional features (e.g., analytics). This change addresses the legal tension between withdrawable consent and blockchain immutability
• Section 12.4 (AMENDED): Updated cross-border data transfer language from consent-based (Article 49(1)(a)) to contractual necessity (Article 49(1)(b)), consistent with Privacy Policy Section 2.5 lawful basis change
• Section 13.3 (NEW): Assignment — permits assignment without user consent in connection with merger, acquisition, or asset sale. Users may not assign without written consent. Existing Section 13.3 (Waiver) renumbered to 13.4

Version 1.7.0 (February 19, 2026)

• Section 11.4 (AMENDED): Class Action Waiver — added severability clause: if waiver is found unenforceable, the entire arbitration agreement is void for that claim (disputes proceed in court, not as class arbitration)
• Section 11.5 (NEW): International Arbitration Limitations — EU consumers retain mandatory court access per Directive 2013/11/EU and Regulation (EU) 524/2013; other jurisdictions with mandatory consumer arbitration prohibitions are similarly excepted
• Section 11.6 (NEW): Jury Trial Waiver — explicit waiver of jury trial for disputes resolved in court (when arbitration does not apply)
• Section 10.4 (NEW): Company Dissolution or Cessation of Operations — certificates survive on-chain, mint authority ceases, wallet access preserved via recovery phrase, open-source verification tooling commitment
• Section 5.9.7 (AMENDED): Account Termination — added 30-day grace period for voluntary account deletion to use remaining purchased Credits before forfeiture

Version 1.6.9 (February 19, 2026)

• Section 9.6 (NEW): Copyright Infringement (DMCA) — added designated agent contact, takedown notification requirements per 17 U.S.C. 512(c)(3), counter-notification procedure, repeat infringer policy, and blockchain data limitation disclosure
• Section 5.9.2 (AMENDED): Clarified that GEN Credits fund real-world operational costs (blockchain transaction fees, on-chain storage rent, infrastructure) and are not digital content consumed within the App — strengthens operational-service classification under Apple App Store Guideline 3.1.1

Version 1.6.8 (February 18, 2026)

• Section 13 (NEW): General Provisions — added Severability (13.1), Entire Agreement (13.2), and Waiver (13.3) clauses. Severability applies to all Terms provisions, not just Section 5.9
• Sections 14–16 (RENUMBERED): Contact Information (13→14), Change Log (14→15), Acknowledgment (15→16) renumbered to accommodate new Section 13
• Section 1.3.1 (FIX): Updated Change Log cross-reference from Section 14 to Section 15

Version 1.6.7 (February 18, 2026)

• Section 5.9.2 (AMENDED): Added acknowledgment that direct-purchase model has been reviewed against Apple App Store Review Guidelines (Guideline 3.1.1) and Google Play billing policies, with note that purchase method may change if platform policies are updated
• Section 5.9.10 (NEW): Money Transmitter Analysis — explicit determination that GEN Credits do not constitute money transmission based on non-transferability, no cash value, closed-loop use, and FinCEN prepaid access guidance (31 CFR 1010.100(ww))

Version 1.6.6 (February 18, 2026)

• Section 11.3 (AMENDED): Added small claims court exception — either party may bring individual claims in small claims court without invoking arbitration
• Section 11.3 (AMENDED): Added consumer fee-shifting — Nebula Genesis Tech pays all AAA filing, administration, and arbitrator fees for claims of $10,000 or less
• Section 8.2 (FIX): Changed "certificate value changes" to "certificate functionality changes" to avoid implying certificates carry monetary value, consistent with securities defense in Section 5.5.4
• Section 1.3 (AMENDED): Material changes affecting user rights, obligations, or data processing purposes now require re-acceptance through affirmative consent; continued-use acceptance limited to non-material updates only
• Section 9.1 (AMENDED): Added patent pending notice (U.S. Patent Application No. 19/462,031) to intellectual property disclosures

Version 1.6.5 (February 18, 2026)

• Section 5.9.9 (NEW): Applicable Law; Savings Clause — defers to applicable consumer protection laws (state gift card statutes, escheatment, cash-back requirements) wherever they conflict with GEN Credit terms. Explicitly preserves statutory rights to cash redemption of small balances, prohibition of expiration/service fees, and escheatment. Includes severability provision for Section 5.9

Version 1.6.4 (February 18, 2026)

• Section 1.1 (AMENDED): Added "GEN Credits" formal definition to Definitions section — defines Credits as prepaid service entitlements (not currency, cryptocurrency, or stored value), cross-references Section 5.9
• Section 5.9.2 (FIX): Hyperlinked "Stripe's terms of service" to stripe.com/legal/consumer
• Section 5.9.7 (FIX): Added "except as required by applicable consumer protection law" carve-out to voluntary deletion forfeiture clause
• Section 6.2 (AMENDED): Updated refund policy to align with GEN credit model — failed mints now reference credit restoration per Section 5.9.3 instead of ambiguous "full refund" language. Added cross-reference to 5.9.3 for credit purchase refund terms
• Section 10.3 (AMENDED): Added GEN credit forfeiture to Effect of Termination list, cross-referencing Section 5.9.7

Version 1.6.3 (February 18, 2026)

• Section 5.9 (NEW): GEN Credits — defines Credits as prepaid service entitlements with no cash value. Purchases via Stripe Checkout only (not App Store/Google Play IAP). Non-refundable except failed blockchain operations (credits restored within 14 business days). Credits are generally non-expiring, are non-transferable, and promotional Credits are subject to the same terms. Forfeiture on account termination for cause. 90-day notice period if GEN credit system is discontinued

Version 1.6.2 (February 18, 2026)

• Section 9.4 (FIX): Changed heading from "Aggregated and Anonymized Data" to "Aggregated and De-Identified Data" — last remaining "anonymized" in clause text
• Section 5.7 (FIX): Completed burn-to-revocation language migration — replaced 9 remaining instances of "burn" terminology with "revocation" in body text (Revocation Process, Revocation Fees, Re-Minting After Revocation, warnings)
• Section 5.8.6 (FIX): Reframed veterinary professional data aggregation from consent (Article 6(1)(a)) to legitimate interest (Article 6(1)(f)) with GDPR Article 21 right to object and contact mechanism
• Section 8.2 (FIX): Removed stale "[ENHANCED]" development marker from Disclaimers heading
• Section 9.5 (FIX): Added specific CCPA statute references (Section 1798.140(o) for de-identification, Section 1798.145(a)(5) for public health exemption) to match Privacy Policy precision
• Section 12.2.2 (FIX): Added de-identified data carve-out cross-reference to "no EEA transfer" statement for consistency with Section 12.4
• Section 12.3 (FIX): Made Right to Object (Article 21) entry specific — now references both opt-out toggles (Data Analytics, Data Sharing). Added mailto hyperlinks to two plain-text email addresses

Version 1.6.1 (February 18, 2026)

• Terminology standardization: Replaced all instances of "anonymized" with "de-identified" in Sections 9.2, 9.4, 9.5, and changelog descriptions to align with HIPAA Safe Harbor and CCPA de-identification standards already referenced in the document
• Section 1.1–1.3 (FIX): Corrected duplicate section 1.1 numbering — "Age Requirements" renumbered to 1.2, "Modifications" to 1.3, "Regulatory Monitoring" to 1.3.1
• Section 9.4 (FIX): Changed "withdraw this consent" to "opt out" with GDPR Article 21 Right to Object reference — aggregation relies on legitimate interest, not consent
• Section 9.5 (FIX): Added opt-out mechanism (Settings > Privacy > Data Sharing) with already-aggregated data caveat and Article 21 reference. Added breach notification cross-reference to Section 5.6
• Section 12.2.3 (FIX): Removed erroneous "with your consent" from legitimate interest basis — these are distinct GDPR lawful bases. Added Article 21 right to object disclosure
• Section 12.4 (FIX): Added carve-out for de-identified data sharing to "no third-party transfer" statement, referencing Sections 9.4 and 9.5

Version 1.6.0 (February 18, 2026)

• Section 9.2 (AMENDED): Broadened license grant from "solely for providing App services" to include creation of aggregated, de-identified datasets (references new Section 9.4). This change enables lawful data aggregation for public health analytics
• Section 9.4 (NEW): Aggregated and De-identified Data — establishes the legal framework for aggregating user data into de-identified datasets for platform analytics, public health surveillance, disease trend monitoring, statistical analysis, and industry reporting. Includes HIPAA Safe Harbor de-identification standards, minimum aggregation thresholds, and user opt-out mechanism (Settings > Privacy > Data Analytics)
• Section 9.5 (NEW): Data Partnerships and Public Health Sharing — authorizes sharing of aggregated, de-identified data with government agencies (USDA, CDC, state veterinarian offices), academic institutions, and veterinary industry organizations. Requires written data sharing agreements, prohibits re-identification, and establishes that public health data sharing does not constitute a "sale" under CCPA
• Section 5.8.6 (NEW): Use of Attestation Data — discloses that veterinary attestation data may be aggregated for public health analytics and disease surveillance. Specifies what data is aggregated (condition codes, species, breed, state-level geography, severity, temporal trends) and what is excluded (pet identifiers, wallet addresses, vet identities, clinic names). Establishes vet consent to aggregation upon creating attestations

Version 1.5.0 (February 18, 2026)

• Added Section 5.2.1: Promotional and Giveaway Programs — covers company-initiated giveaways (Genesis Days), partner codes, community rewards, competitive allocation events, and promotional data collection
• Established per-code and per-wallet redemption limits, anti-abuse provisions, and account suspension for circumvention
• Added Competitive Allocation Events clause requiring separate Official Rules for limited-quantity programs (addresses state sweepstakes compliance)
• Explicitly extended arbitration (Section 11.3) and class action waiver (Section 11.4) to Promotional Program disputes
• Added promotional liability cap tied to fair market value of the promotional benefit

Version 1.4.4 (February 16, 2026)

• Section 1.1: Added Definitions clause — "Pet Identity Certificate" defined as soulbound, non-transferable digital token on Solana Token-2022
• Systematic language migration: replaced consumer-facing "NFT" / "NFTs" with "Pet Identity Certificate" / "certificates" throughout all non-changelog clause text
• Renamed headings: "NFTs & Fees" → "Certificates & Fees", "Blockchain and NFT Features" → "Blockchain and Certificate Features", "NFT Minting and Fees" → "Certificate Minting and Fees", "NFTs Are Digital Titles" → "Certificates Are Digital Titles", "NFT Metadata Update Fees" → "Certificate Metadata Update Fees", "NFT Burning" → "Certificate Revocation", "NFT Minting Payments" → "Certificate Minting Payments", Section 9.3 "NFTs" → "Certificates"
• Replaced "NFT burning" / "burn" language with "certificate revocation" / "revoke" in Section 5.7 and cross-references
• Preserved all historical changelog entries as-is

Version 1.4.3 (February 16, 2026)

• Section 5.5.4: Added Functional Exhaustion clause — tokens confer no financial interest, revenue share, governance rights, or claim on company assets; enforced contractually and technically via Token-2022 NonTransferable
• Section 5.5.5: Renumbered Regulatory Compliance; updated language from "NFTs" to "Pet Identity Certificates" and "cryptographically verifiable credentials"
• Section 2.2: Specified Solana blockchain (mainnet-beta) and Token-2022 as the minting platform
• Section 8.2.2: Identified Solana as the blockchain network used for operations
• Fixed header version mismatch (was displaying 1.4.1 instead of current version)

Version 1.4.2 (February 14, 2026)

• Section 5.4: Corrected wallet correlation language to reflect mandatory wallet rotation (per-pet wallet isolation)
• Section 5.5.2: Removed transfer language incompatible with soulbound design; added burn-and-remint process for ownership changes
• Section 5.5.3: Renamed to "Non-Transferability and Resale Restrictions"; replaced transfer language with soulbound non-transferability
• Section 8.2: Replaced "Beta Testing" disclaimer with general "Early Adoption" disclaimer (app is now publicly released)
• Section 12.2.2: Qualified EEA data transfer language to acknowledge blockchain validator and payment processing cross-border transfers
• Section 12.4: Removed contradictory "no cross-border data transfer" bullet; clarified EEA transfer exceptions
• Fixed heading hierarchy in Section 5.8 (h2 → h3)
• Added section anchor IDs to all 15 top-level sections for deep linking

Version 1.4.1 (February 8, 2026)

• Corrected company name to "Nebula Genesis Tech, LLC" in company information and copyright sections for legal consistency

Version 1.4.0 (January 22, 2026)

• Added Section 5.1.1: Biometric authentication requirements for all blockchain operations
• Added Section 5.1.2: Detailed recovery phrase security information and compromise scenarios
• Enhanced Section 5.4: Added soulbound NFT protection details and explanation
• Clarified what attackers can and cannot do with compromised recovery phrase
• Added guidance for users if recovery phrase is compromised
• Updated security disclaimers to reflect device-level biometric protection
• Added Section 8.4: Comprehensive user indemnification clause for enhanced legal protection
• Added cross-references to Privacy Policy for better document integration
• Enhanced legal protection with improved cross-document linking and indemnification
• Added Section 1.2.1 (now 1.3.1): Regulatory Monitoring and Updates for ongoing compliance
• Added Section 12.5: Compliance with International Standards (OECD Privacy Guidelines, UN resolutions, eIDAS 2.0)
• Enhanced international law coverage for digital identity protection and cross-border data flows

Version 1.3.0 (January 19, 2026)

• Added Section 5.8: Veterinary Professional Attestations (attestation types, fees, partner program)
• Updated Section 5.2: Added veterinary attestation fee reference
• Added veterinary partner program framework
• Added professional requirements and liability provisions for veterinary partners

Version 1.2.0 (January 15, 2026)

• Added Section 5.7: NFT Burning disclosure (burn process, fees, re-minting)
• Expanded Section 5.2: Free mint token details (eligibility, expiration, no cash value)
• Clarified Section 5.6: Metadata update fees marked as "Planned Feature"

Version 1.1.0 (January 9, 2026)

• Updated effective date to January 9, 2026
• Added user responsibility clarification for local storage
• Added fee clarification emphasizing recordation costs
• Enhanced arbitration clause with opt-out mechanism and cost allocation
• Clarified blockchain features as optional in Section 2.2
• Added Change Log section for transparency

Version 1.0.0 (Initial Release)

• Initial Terms of Service publication

16. Acknowledgment

By using the Nebula Genesis Pet Ledger App, you acknowledge that:

• You have read and understood these Terms
• You agree to be bound by these Terms
• You are of legal age to enter into this agreement
• You will comply with all applicable laws and regulations
• You understand the risks associated with blockchain and cryptocurrency features
• You understand that health features are not a substitute for veterinary care