Natural Services Agreement

Last updated: March 9, 2026

These Terms of Service ("ToS"), the Financial Services Terms, and the Data Processing Agreement ("DPA") collectively form the Natural Services Agreement ("Agreement") between you or the entity you represent ("You") and Natural that governs Your use of the Services. The Agreement is effective when You first access or use the Services (the "Effective Date") and continues in effect until terminated (the "Term"). Capitalized terms not defined inline are defined in the ToS Appendix 1 (Definitions), below.

Natural may update the Agreement at any time by notifying You of the update and publishing the new version on Natural's website. Your continued use of the Services means You accept the updated Agreement.

Terms of Service

1. Services

1.1. Acceptance of Agreement

By submitting Your Natural onboarding application or otherwise accessing or using the Services, You agree to the terms of the Agreement.

1.2. Services

Your use of the Services is subject to Natural's approval. If Your onboarding application is approved, Natural will make the Services available to You and grant You access to a Natural Dashboard. You must use the Services solely for the Authorized Purposes and in compliance with Law, the Agreement, the Documentation, and the AUP.

1.3. Support

Natural will provide You with basic business and technical support for issues relating to Your Natural onboarding, Account, and use of the Services.

1.4. Preview Services

Natural may make a Preview Service available to You. Preview Services may be feature-incomplete, unstable, or contain bugs, and Your use of the Preview Services is at Your own risk and discretion. You should not use Preview Services in a production environment unless You understand all limitations.

2. Authority and Representation

2.1. General

You represent that You have full power, capacity, and legal authority to bind the entity or individual specified in Your Natural onboarding application to the Agreement.

2.2. Adult Representative

If You have an Adult Representative, both You and Your Adult Representative must comply with Law, the Agreement, the Documentation, and the AUP.

2.3. Entity Representative

You are responsible for each Entity Representative's actions and Transactions in connection with Your Natural Account. If You are a sole proprietor, the Agreement binds You individually and as an Entity Representative of the sole proprietorship.

3. Restrictions

3.1. Age Restrictions

You must be at least 18 years old to independently use the Services. If You are a minor in Your jurisdiction, You may only use the Services if a parent or legal guardian acts as Your Adult Representative and supervises Your use of the Services. References to "You" throughout the Agreement mean jointly You and Your Adult Representative.

3.2. Conduct Restrictions

You must not (and must not attempt to):

(a) engage in any illegal, unauthorized, fraudulent, or deceptive activity;

(b) harass, abuse, or harm others;

(c) conduct a Prohibited or Restricted Business, Transact with any Prohibited or Restricted Business, or enable any individual or entity to operate or benefit from a Prohibited or Restricted Business, except for a Restricted Business that Natural has pre-approved in writing; or

(d) build a product that competes with Natural or the Natural Technology.

3.3. Product Restrictions

You must not (and must not attempt to):

(a) perform any action that interferes with the operation of the Services or affects other Natural users' use of the Natural services;

(b) reverse engineer any part of the Natural Technology;

(d) circumvent any technical or security limitation of the Natural Technology or use Natural Technology that is disabled or prohibited;

(e) create a Natural account on behalf or for the benefit of an individual or entity Natural previously suspended or terminated from using the Natural services; or

(f) in any way copy, reproduce, republish, upload, post, transmit, resell, or distribute any part of the Services, Natural Technology, or Documentation without Natural's prior written authorization.

4. Identity Verification

4.1. KYB/KYC Authorization

You authorize Natural to, directly or through a third-party service provider, take all actions Natural considers necessary to verify Your identity and validate Your Financial Instrument(s). This may include requesting Your contact details (including Personal Data), business information (if applicable), and other substantiating documents and information. Natural may require You to take steps to confirm ownership of Your email address, phone number, and Financial Instrument(s).

4.2. Unsuccessful Verification

Your failure to verify Your identity may result in delayed or blocked setup of Your Natural Account, suspended funds settlement, additional due diligence measures, and/or suspension or termination of Your Natural Account.

4.3. Affiliate Verification

If Your Affiliate entity seeks to use Natural's services or access the Natural Technology, that Affiliate entity must submit an onboarding application to Natural, complete the identity verification process, and set up its own account with Natural.

5. Roles; Agent Protocols; Background Technology

5.1. Role of Your Contributor(s)

You are responsible for a Contributor's actions and Transactions in connection with Your Natural Account. You are liable for any Losses or Third-Party Losses Your Contributor causes. For purposes of this Section 5, all references to "You" mean both You and Your Contributor(s), if any, jointly and severally.

5.2. Role of Your Agent(s)

You, and not Natural, are responsible for ensuring that Your Agents lawfully and correctly Transact. You are liable for any Losses or Third-Party Losses an Agent causes, including if Your Agent Transacts in an unintended, grossly negligent, or malicious manner.

5.3. Agent Protocol(s)

You, and not Natural, are responsible for lawfully and correctly implementing Your Agent Protocol(s). You are liable for any Losses or Third-Party Losses an Agent Protocol causes, including if Your Agent Protocol causes Your Agent to Transact in an unintended, grossly negligent, or malicious manner.

5.4. Background Technology

You, and not Natural, are responsible for Your Background Technology. You are liable for any Losses or Third-Party Losses Your Background Technology causes, including if Your Background Technology, or any act or omission relating to Your Background Technology, causes Your Agent to Transact in an unintended, grossly negligent, or malicious manner.

5.5. Your Instructions

Natural is liable for financial losses caused by Natural's failure to reasonably follow Your, Your Agent's, or Your Contributor's Instructions.

6. Confidentiality

6.1. General

Each party may receive or access the other party's Confidential Information in connection with the Services. Each party must use the other party's Confidential Information solely to provide or receive the Services and protect it using the same degree of care it uses to protect its own. Each party must not disclose the other party's Confidential Information to any third party except to employees, contractors, professional advisors, or, in Natural's case, Financial Partners who need to know it for legitimate purposes and are bound by confidentiality obligations at least as protective as the Agreement.

6.2. Disclosures

A party may disclose Confidential Information if Law, a subpoena, or a court order requires the disclosure, but only if that party gives prompt, advance notice to the other party (where legally permitted) and reasonably cooperates with any efforts to contest the disclosure (at the other party's option and expense). Natural may identify You as a user of the Services in its financial disclosures and tax documents.

6.3. Exclusions

Confidential Information excludes information that the receiving party can prove:

(a) is or becomes publicly available without breach of this provision;

(b) the receiving party lawfully knew or possessed prior to receiving it in connection with the Services;

(d) the receiving party lawfully obtains from a third party without restriction.

6.4. Return of Confidential Information

If the Services terminate, each party will promptly return or securely delete the other party's tangible and electronic Confidential Information, unless Law or a legitimate compliance obligation requires further retention.

7. Data Security and Privacy

7.1. Account Registration

To access the Services, You must request a Natural Account using current, accurate, and complete information. You must keep Your login credentials confidential and secure.

7.2. Unauthorized Access

You are responsible for unauthorized access to Your Natural Account. Natural is not liable for Losses or Third-Party Losses caused by Your failure to protect Your login credentials or otherwise secure Your Natural Account. You must notify Natural immediately of any unauthorized access to Your Natural Account.

7.3. Controls

You and Natural will maintain commercially reasonable administrative, technical, and physical safeguards designed to protect the data in each party's respective possession or control against unauthorized access, modification, loss, and disclosure. Natural will comply with the data security measures stated in Appendix 2 (Data Security Measures) of the DPA.

7.4. DPA

The DPA states Your and Natural's obligations regarding the processing of Personal Data in connection with the Services. Each party will comply with the DPA.

8. Data Usage

8.1. Natural Data

You must use Natural Data only as permitted by the Agreement.

8.2. Model-Training

You must not use any Natural Data or Natural Confidential Information to create, improve, train, or enhance Your or any third party's machine learning or artificial intelligence models, agents, tools, technology, systems, or algorithms.

8.3. Data Retention

Natural is not obligated to retain data it receives from or through You, except as required by Law and to provide the Services.

9. Intellectual Property

9.1. Natural's IP Rights

Natural and its third-party licensors hold all IP Rights to the Natural Technology and the Documentation. Your use of the Natural Technology and the Documentation must not violate or infringe Natural's IP Rights.

9.2. License Grant (Natural Technology)

Subject to the Agreement, Natural grants You a limited, worldwide, royalty-free, non-exclusive, non-transferable, non-sublicensable, revocable license during the Term to use the Natural Technology solely:

(a) as necessary to use the Services;

(b) for the Authorized Purposes; and

9.3. License Exclusions (Natural Technology)

Your License to the Natural Technology does not allow You to, and You must not (and must not enable others to):

(a) use or run the Natural Technology in any way other than according to the Agreement and the Documentation;

(b) modify, adapt, translate, reverse engineer, decompile, disassemble, or otherwise create derivative works based on the Natural Technology or any part of it; or

(c) rent, lease, lend, sell, share, redistribute, or sublicense any part of the Natural Technology unless Natural otherwise authorizes in writing.

9.4. Natural's Third-Party Materials

The Services and the Natural Technology may utilize Third-Party Materials. Natural's Third-Party Materials may include open source software, in which case the terms of the relevant open source license supersede any conflicting provision in the Agreement regarding open source code.

9.5. Your IP Rights

You and Your third-party licensors hold all IP Rights in the Background Technology and Content.

9.6. License Grant (Content)

You grant to Natural a perpetual, worldwide, royalty-free, non-exclusive, irrevocable license to use the Content as necessary for Natural to provide, develop, and improve the Services and the Natural Technology and for Natural's internal business purposes.

9.7. Your Third-party Materials

If You include Third-Party Materials in the Content, You must obtain all necessary rights, licenses, and consents sufficient to enable Natural to use the Content.

9.8. Reservation of IP Rights

Nothing in the Agreement assigns or transfers any IP Rights to the other party. IP Rights not expressly granted in the Agreement are reserved.

9.9. Joint Development

Nothing in the Agreement contemplates a joint development of intellectual property by You and Natural.

10. Publicity

10.1. License Grant (Natural's Services)

Subject to the Agreement, each party grants to the other party a worldwide, non-exclusive, non-transferable (except as the Agreement allows), non-sublicensable, royalty-free license during the Term to use the granting party's Marks:

(a) to provide or receive the Services; and

(b) to identify Natural as the provider of the Services to You.

All goodwill generated from the use of the grantor party's Marks will inure to the sole benefit of the grantor party.

10.2. Natural's Permitted Uses of Your Marks

Natural may use Your Marks:

(a) on any digital or physical surface that identifies Natural users;

(b) for sales and marketing purposes in Natural's materials, assets, communications, and presentations at events and otherwise; and

10.3. Your Permitted Uses of Natural's Marks

If You use Natural's Marks, You must comply with Natural's brand guidelines and any take-down request Natural provides to You.

11. Disclaimers

11.1. Disclaimer of Warranties

Natural provides the Services and Natural Technology to You "as is" and "as available". Natural does not warrant that Your use of the Services and Natural Technology will be uninterrupted or error-free. Natural is not liable for delays, failures, or outages.

11.2. Industry Regulations

The Services are not designed to ensure Your compliance with industry-specific regulations that apply directly to You. You are responsible for Your compliance with applicable industry regulations.

12. Fees; Taxes

12.1. Fees

You agree to pay Natural all applicable Fees for the Services. The Fees are listed on the Natural Pricing Page. Unless Law requires, Your obligation to pay the Fees is non-cancelable, and Fees paid are non-refundable.

12.2. Collection

Natural may collect Fees You owe or recoup Losses by deducting them from Your Natural Account balance, invoicing You, or otherwise charging Your designated payment method.

12.3. Taxes

(a) Taxes on the Services - The Fees listed on the Natural Pricing Page exclude Taxes. You agree to pay Natural all applicable Taxes relating to Your use of the Services.

(b) Your Tax Responsibilities - You are solely responsible and liable for: (i) determining which, if any, Taxes or fees apply to the sale of Your products and services, acceptance of donations, or payments You receive in connection with Your use of the Services; and (ii) assessing, collecting, reporting, and remitting Taxes for You and Your entity (if applicable) to the appropriate taxing authority.

13. Limitations on Liability

13.1. Limitation on Liability Amount

Except for a party's gross negligence, fraud, willful misconduct, or Losses or Third-Party Losses arising from Section 5 or 14 of the ToS, a party's total liability arising out of or relating to the Agreement will not exceed the total Fees paid under the Agreement during the 12-month period before the first event giving rise to liability.

13.2. Limitation on Liability Types

Neither party is liable to the other party in connection with the Services for any indirect, consequential, special, reliance, incidental, or punitive damages, whether in contract, tort, or other legal or equitable theory.

14. Indemnification

14.1. General

You will indemnify Natural, its Affiliate(s), and their directors, employees, and agents for all Third-Party Losses that arise from Your use or misuse of the Services and Natural Technology, gross negligence, fraud, willful misconduct, breach of the Agreement, or violation of Law.

14.2. IP Claims

(a) Indemnity. Each party will indemnify the other party, its Affiliate(s), and their directors, employees, and agents for all Third-Party Losses that form the basis of an IP Claim, except that this indemnification obligation does not apply if: (i) the indemnified party used the Materials in combination with other materials; (ii) that combination caused the Third-Party Losses; and (iii) the Materials the indemnifying party provided would not infringe absent the combination.

(b) Remediation. If an IP Claim arises, the indemnifying party may, at its sole discretion and expense: (i) modify the Materials it provided to be non-infringing; (ii) replace the Materials with non-infringing alternatives; or (iii) obtain a license for the indemnified party to continue using the Materials.

15. Suspension; Termination

15.1. Account Suspension (by Natural)

Natural may immediately suspend Your access to the Services and Natural Technology if Natural reasonably believes that:

(a) You breached, or Your continued access to the Services would breach, the Agreement;

(b) You violated, or Your continued access to the Services would violate, the AUP or Law;

(d) You fail to provide requested verification information;

(e) You fail to meet KYB/KYC or anti-money laundering screening requirements;

(f) Your actions threatened or continue to threaten the security, stability, or reliability of the Natural Technology; or

(g) Your actions caused or continue to cause unacceptable risk to Natural or Natural users.

15.2. Termination for Convenience (by You)

You may, at any time, terminate the Agreement by closing Your Natural Account through Your Natural Dashboard or by contacting support, subject to settlement of Your outstanding obligations under the Agreement.

15.3. Termination for Convenience (by Natural)

Natural may, at any time upon 30 days' notice to You, terminate the Agreement and close Your Natural Account.

15.4. Termination for Cause (by Natural)

Natural may immediately terminate the Agreement or revoke access to any part of the Services or Natural Technology if:

(a) Natural reasonably believes termination without notice is required by Law or necessary to prevent fraud or harm;

(b) You materially breach the Agreement and, if capable of cure, do not cure the breach within 10 days after Natural provides You a notice that specifies the breach; or

(c) Natural suspends Your account and You do not prove within 10 days that Natural's basis for suspension was in error or is cured.

15.5. Effect of Termination (general)

Upon termination, Your right to use the Services and Natural Technology immediately ends. Termination does not relieve either party of payment obligations accrued before termination.

15.6. Effect of Termination for Cause (by Natural)

Upon termination for cause, Natural may close Your Natural Account and take related actions including canceling or settling Your pending Transactions at Natural's discretion. Natural will not refund unused wallet balances if Your Natural Account is terminated for cause.

15.7. Survival

The following obligations will survive termination of the Agreement:

(a) obligations that by their nature are intended to survive termination (e.g., either party's payment obligation to the other or a third party in connection with the Services);

(b) terms that limit liability to the extent necessary to ensure that a party's potential liability for acts and omissions that occurred during the Term is unaffected by the termination; and

16. Arbitration; Governing Law; Jurisdiction and Venue

16.1. Binding Arbitration

To the extent Law permits, the parties will resolve any dispute, claim, or controversy arising out of or relating to the Agreement exclusively by final and binding arbitration. Judgment on the award may be entered in any court of competent jurisdiction.

16.2. Class Action Waiver

To the extent Law permits, any dispute arising out of or relating to the Agreement, whether in arbitration or in court, will be conducted only on an individual basis and not in a class, consolidated, or representative action. Notwithstanding any other provision of the Agreement or the AAA Rules, disputes regarding the interpretation, applicability, or enforceability of this class waiver may be resolved only by a court and not by an arbitrator. If this waiver of class or consolidated actions is deemed invalid or unenforceable, neither party is entitled to arbitration.

16.3. Arbitration Procedure

(a) American Arbitration Association - The American Arbitration Association ("AAA") will conduct the arbitration: (i) in San Francisco, California; (ii) by a single arbitrator; (iii) subject to the AAA Commercial Arbitration Rules if You are a business; (iv) subject to the AAA Consumer Arbitration Rules if You are an individual; (v) on an individual basis and not in a class, consolidated, or representative action; and (vi) subject to the substantive Law of the State of California and of the United States, excluding their conflict or choice of law rules.

(b) Notice of Disputes - Before commencing arbitration, the party asserting a claim must send a written notice of dispute to the other party. All dispute notices to Natural must be sent to notices@natural.com. All dispute notices to You will be sent to the email address associated with Your Natural Account. Your notices must: (i) provide Your name, email address, mailing address, and Natural Account ID (if any); (ii) describe the nature, factual basis, and legal basis of the dispute; and (iii) detail the specific relief You are seeking.

(c) Authorizations - If You appoint an attorney to submit Your notice, You must provide written authorization allowing Natural to discuss Your dispute and account details with Your attorney. Natural may require You (or Your attorney) to verify Your identity and confirm Your authorization to disclose information about Your Natural Account. You (or Your attorney) will cooperate with Natural's reasonable verification request(s).

(d) Attempt to Resolve - After notice of arbitration is provided, the parties will meet for the purpose of resolving the dispute. If the dispute is not resolved within 30 days of the notice, then a party may commence arbitration in accordance with this Section 16.

16.4. Confidentiality of Arbitration

The parties will keep confidential the existence of the arbitration, the details of the arbitration proceeding, the hearing, and the arbitrator's decision, except:

(a) as necessary to prepare for and conduct the arbitration hearing;

(b) in connection with a court application for a preliminary remedy, confirmation, vacatur, or modification of an arbitrator's award;

(d) as necessary to professional advisers who are subject to a strict duty of confidentiality; and

(e) as Law otherwise requires.

The parties, witnesses, and arbitrator will treat as confidential and not disclose to any third party (other than witnesses or experts) any submissions, documents, or other evidence produced in the arbitration, except as Law requires or if the evidence was obtained from the public domain or otherwise obtained independently from the arbitration.

16.5. Governing Law; Jurisdiction; Venue

California Law governs the Agreement. For IP claims, each party consents to exclusive personal jurisdiction in the United States District Court for the Northern District of California, and for all other claims that may not be subject to arbitration or to confirm an arbitrator's award, each party consents to exclusive personal jurisdiction in the federal courts for the Northern District of California and the state courts located in San Francisco County, California.

17. General Terms

17.1. Compliance with Law

Each party must comply with all applicable Law in connection with the Services.

17.2. Notices and Communications

Required Writing - Any required notice under the Agreement must be provided in written or electronic form to the other party.
Notices to Natural - Unless Natural otherwise instructs You, You must provide notices to Natural at notices@natural.co.

17.3. Assignments

You may not assign or transfer any of Your rights or obligations under the Agreement without Natural's prior consent, which will not be unreasonably withheld. However, You may assign the Agreement in its entirety to Your successor resulting from a merger, acquisition, or sale of all or substantially all of Your assets or voting securities, provided that:

(a) You promptly notify Natural of the assignment;

(b) the assignee agrees in writing to assume all of Your obligations under the Agreement; and

(c) the assignee complies with Natural's procedural and documentation requirements to give legal effect to the assignment.

Any attempt by You to transfer or assign the Agreement, except as expressly authorized above, will be void. Natural may assign and transfer its rights and obligations under the Agreement (in whole or in part) without Your consent. The Agreement will be binding on, inure to the benefit of, and be enforceable by the parties and their permitted assigns.

17.4. Legal Fees and Costs

In any dispute, arbitration, or other legal proceeding arising out of or relating to the Agreement, the arbitrator or court will award to the prevailing party, if any, the reasonable attorneys' fees and costs the prevailing party incurred in the dispute, arbitration, or legal proceeding.

17.5. Entire Agreement

The Agreement, together with any separate written agreements or terms related to Fees, constitutes the entire agreement and understanding of the parties regarding the Services and supersedes all prior and contemporaneous agreements and understandings.

17.6. Order of Precedence

If any term in these ToS conflicts with a term elsewhere in, or incorporated by reference into, the Agreement, then the order of precedence is:

(a) the DPA, but only as to terms that relate to Personal Data;

(b) the Financial Services Terms, including any terms incorporated by reference;

(d) the ToS.

17.7. Severability

If a court or Governmental Authority finds any provision of the Agreement to be invalid, illegal, or unenforceable, the parties intend for the balance of provisions to remain in full force and effect.

17.8. Waivers

A party's waiver of its rights in connection with the Agreement must be in writing signed by the waiving party to be effective. A party's failure to enforce any provision of the Agreement does not constitute a waiver of that party's right to subsequently enforce the provision.

17.9. Force Majeure

Neither party is liable for delays or failures caused by an event beyond reasonable control, including a natural disaster, labor dispute, supply chain disruption, regional or international health crisis, war, hostility, invasion, civil unrest, terrorism threat or act, Law, or a Governmental Authority's act.

17.10. No Agency

Each party to the Agreement, and each Financial Partner (if applicable), is an independent contractor. Nothing in the Agreement establishes a partnership, joint venture, general agency, trust, or fiduciary relationship between You and Natural or any Financial Partner.

17.11. Subcontractors

Natural may use subcontractors in the performance of its obligations under the Agreement. Natural remains responsible for its performance under the Agreement.

ToS Appendix 1 (Definitions)

"Adult Representative" means a Representative that is Your parent, guardian, or otherwise authorized legal agent who accepts the Agreement and submits a Natural onboarding application on Your behalf.

"Affiliate" means an entity that directly or indirectly Controls, is Controlled by, or is under common Control with another entity.

"Agent" means an automated system, model, or application that You or Your Contributor authorize(s) to Transact in connection with Your Natural Account.

"Agent Protocol(s)" means the configuration, rules, parameters, programmatic logic, and Background Technology You or Your Contributor use(s) to instruct, authorize, and direct Your Agent to Transact in connection with Your Natural Account.

"Authorized Purposes" means actions and Transactions related to the individual or business description You specify in Your Natural onboarding application, including configuring Agent Protocol(s).

"AUP" means the Authorized Use Policy that governs Your use of the Services.

"Background Technology" means the technical setup, system integrations, know-how, and Agent Protocol(s) You use to enable Your Agent(s) to Transact in connection with Your Natural Account.

"Bank Partner" means a financial institution chartered or organized under U.S. federal or state law and authorized to accept deposits and engage in banking activities, with whom Natural may interact to provide the Services.

"Claim" means any claim, demand, government investigation, or legal proceeding that a third party makes or brings against any indemnified party in connection with the Services.

"Confidential Information" means all non-public information, including personal data, that a disclosing party discloses in any form to a receiving party in connection with the Services that (a) is designated as confidential; or (b) should reasonably be understood to be confidential given the nature of the information and the circumstances of disclosure.

"Contributor" means an individual that You invite to interact with Your Natural Account according to the roles and permissions You configure.

"Control" means direct or indirect ownership of more than 50% of the voting power or equity in an entity.

"Content" means all text, images, and other data (excluding Personal Data) and information that You provide, transmit, upload, publish, or make accessible to Natural in connection with the Services and that Natural does not provide You.

"Data Controller" has the meaning stated in the DPA.

"DPA" means the Data Processing Agreement that governs Your use of the Services.

"Data Processor" has the meaning stated in the DPA.

"Documentation" means the instructions, requirements, sample code, references, canonical examples, and other concepts Natural makes available to You through the Natural Technology.

"Entity Representative" means Your employee, contractor, or other Representative who acts on Your behalf in connection with the Services.

"Fees" means the cost of Your Transactions and applicable charges based on Your use of the Services, as stated on the Natural Pricing Page.

"Financial Instrument" means any means of holding, transferring, or settling value, such as a bank account, financial services account, stored-value wallet, or digital or tokenized asset.

"Financial Partner" means an entity that provides financial services, including a Bank Partner, with whom Natural may interact to provide the Services.

"Governmental Authority" means a regulator or other governmental agency or body with legitimate authority over You, Natural, or the Services.

"Instructions" means any communication or documentation, including those provided through the Natural API(s), Natural Dashboard, any electronic communication between You and Natural, and any Transaction Instructions, through which: (a) You, Your Agent, or Your Contributor instruct(s) Natural to take an action, or a series of actions, in connection with the Services; or (b) a Data Controller instructs a Data Processor to Process Personal Data in connection with the Services.

"IP Claim" means: (a) where Natural is the indemnifying party, a Claim by a third party that the indemnified party's use of the Natural Technology, Services, Natural Marks, or any other Material that Natural provided You infringes the IP Rights of the third party; or (b) where You are the indemnifying party, a Claim by a third party that the indemnified party's use of Your Content, Marks, or Materials infringes the IP Rights of the third party.

"IP Rights" means all copyrights, patents, trademarks, service marks, trade secrets, moral rights, and other intellectual property rights recognized anywhere in the world.

"Law" means the applicable laws, rules, regulations, and legally permissible and binding requirements of every jurisdictional Governmental Authority.

"Losses" means any damages, financial harms, liabilities, judgments, settlements, penalties, fines, costs, and expenses (including reasonable attorneys' fees and legal expenses) a party incurs in connection with the Services.

"Mark" means a trademark, service mark, design mark, logo or stylized script.

"Material(s)" means any software, hardware, documents, data, Marks, inventions, or other materials provided by a party.

"Natural" means Natural AI, Inc. and its Affiliate(s), if any.

"Natural Account" means a Natural account You apply for and Natural approves that enables You and Your Contributor(s) to access and use the Services.

"Natural API" means a Natural application programming interface, including all endpoints that enable Natural users to use the Services.

"Natural Dashboard" means the user interface through which You may view information about and manage Your Natural Account.

"Natural Data" means all data and information relating to the Natural APIs, Natural Technology, and Services, including usage data, learnings, product insights, and product improvements derived from the Natural Data, all of which is considered Natural's Confidential Information.

"Natural Technology" means all software (including the Natural SDKs), application programming interfaces (including the Natural APIs), user interfaces (including the Natural Dashboard), Natural's website(s), Natural's application(s), the Natural Data, and any other technology that Natural uses to provide the Services.

"Natural user" means a verified individual or entity who has a Natural Account.

"Personal Data" has the meaning stated in the DPA.

"Prohibited Business" means an industry or product, or an entity that engages in an industry or product, that Natural cannot support for legal, regulatory, reputational, or other reasons.

"Representative" means an individual who has actual or apparent authority to act on Your behalf or whom You authorize to use the Services on Your behalf.

"Restricted Businesses" means industries or products that Natural may support after additional due diligence.

"Services" means the product and service offerings Natural provides or makes available to You, including Your access to and use of the Natural Technology.

"Taxes" means any applicable taxes and duties imposed by any Governmental Authority, including sales and use tax, excise tax, gross receipts tax, value-added tax (VAT), goods and services tax (GST) (or equivalent transaction taxes), and withholding tax.

"Third-Party Losses" means all amounts finally awarded to a third party in connection with its Claim(s).

"Third-Party Materials" means third-party software and other licensed materials a party uses in connection with the Services.

"Transact" means to perform a Transaction.

"Transaction" means a money movement request that You, Your Agent, or Your Contributor executes using the Natural Technology.

"Transaction Instructions" means the authorization and instructions You, Your Agent, or Your Contributor provide(s) to Natural stating the nature of the Transaction, Transaction Method, Transaction amount, and any other remittance information Natural requires to facilitate the Transaction.

"Transaction Method" means a money movement instrument or mechanism that Natural, along with any applicable Financial Partner, uses or facilitates as part of the Services.

Financial Services Terms

These terms (the "Financial Services Terms") are subject to and form part of the Agreement that governs Your use of the Services. Capitalized terms not defined in the Financial Services Terms have the meanings given to them elsewhere in the Agreement.

Natural may modify the Financial Services Terms as our products and partnerships evolve, or if a Financial Partner requires, by publishing the new version on Natural's website. Your continued use of the Services means You accept the updated Financial Services Terms.

Financial Partner Terms

Natural's Financial Partners facilitate money movement in connection with Natural's Services. The Financial Partner Terms apply to Your use of Natural's Services.

Financial Partner	Location	Terms
Bridge	United States	Bridge US User Terms

Transaction Method Terms

You are able to decide which Transaction Method(s) You use in connection with the Natural Services. The applicable Transaction Method Terms apply to each Transaction Method You use.

Transaction Method	Location	Terms
ACH	United States	ACH Terms
Wire Transfers	United States	Wire Transfer Terms
Real-time Payment Network (RTP)	United States	RTP Terms
FedNow	United States	FedNow Terms
Card Transaction	United States	Card Transaction Terms

General Terms

1. Compliance Audits

Upon request by Natural or a Financial Partner, You must provide all documentation necessary to demonstrate Your compliance with the Financial Services Terms. If You fail to provide sufficient documentation of Your compliance with the Financial Services Terms, Natural may suspend or terminate Your Natural Account.

2. No Nesting

Parties must not combine multiple debits or credits under a single authorization or submit Transactions on behalf of other third-party senders.

3. Instant Funds Access

Additional fees may apply if You elect to access funds instantly. Natural will disclose additional fees on Your Natural Dashboard.

4. Transaction Limits

Natural may limit or restrict Transactions at its discretion. Natural may consider factors such as Transaction size, Transaction velocity, unusual or suspicious activity, credit risk, regulatory risk, or other perceived risk related to Your Natural Account.

ACH Terms

1. ACH Network

The ACH Operator operates the ACH Network. The NACHA Operating Rules govern ACH Transactions on the ACH Network.

2. Natural's Compliance

Natural and its Financial Partner(s) will comply with the Financial Services Terms and the NACHA Operating Rules in connection with the Services.

3. Your Compliance

By using the ACH Transaction Method, You agree to comply with the Financial Services Terms and the NACHA Operating Rules in connection with the Services.

4. Bank Account Verification

Natural may verify Natural users' bank accounts. Natural collects and processes this data according to the DPA and Privacy Policy.

5. Roles

A Natural user acts as the ACH Originator or ACH Receiver. Natural acts as a Third-Party Sender, collects Transaction Instructions from a Natural user, and formats and transmits ACH entries only according to Transaction Instructions.

6. Reversals

ACH Transactions are final unless Law requires or Natural agrees otherwise. Baseless reversals may result in suspension or termination of Your Natural Account, additional fees, or reporting to financial institutions.

7. Termination

Natural may suspend or terminate Your Natural Account access if You violate the NACHA Operating Rules, have high return or reversal rates, or a Financial Partner requires it.

8. Account Number Prevails

Natural and the RDFI must rely on the routing and account numbers You provide. If You provide an incorrect account number—even if You provide the correct ACH Beneficiary name—neither Natural nor the RDFI are liable.

RTP Terms

1. RTP Network

The RTP Operator operates the RTP Network. The RTP Network Rules govern RTP transactions on the RTP Network.

2. Natural's Compliance

Natural and its Financial Partner(s) will comply with the Financial Services Terms and the RTP Network Rules in connection with the Services.

3. Your Compliance

By using the RTP Transaction Method, You agree to comply with the Financial Services Terms and the RTP Network Rules.

4. Roles

A Natural user acts as the RTP Originator or RTP Receiver. Natural acts as the Intermediary and processes the RTP Transaction only according to Transaction Instructions.

5. Irrevocability

RTP Transactions are immediate and irrevocable once processed.

6. Termination

Natural may suspend or terminate Your Natural Account access if You violate the RTP Network Rules or a Financial Partner requires it.

FedNow Terms

1. FedNow Services

The Federal Reserve operates the FedNow Services. 12 CFR Part 210, Subpart C, governs the FedNow Transaction Method.

2. Natural's Compliance

Natural and its Financial Partner(s) will comply with all governing rules and regulations stated in 12 CFR Part 210, Subpart C (Funds Transfers Through the FedNow Service).

3. Your Compliance

By using the FedNow Transaction Method, You agree to comply with the Financial Services Terms and all governing rules and regulations stated in 12 CFR Part 210, Subpart C (Funds Transfers Through the FedNow Service).

4. Roles

A Natural user acts as the FedNow Originator or FedNow Receiver. Natural acts as the Intermediary and processes the FedNow Transaction only according to Transaction Instructions.

5. Irrevocability

FedNow Transactions are immediate and irrevocable once processed.

6. Termination

Natural may suspend or terminate Your Natural Account if You violate the governing rules and regulations stated in 12 CFR Part 210, Subpart C, or a Financial Partner requires it.

Wire Transfers Terms

1. Wire Transfers

A combination of federal laws, regulations, network rules, and bank agreements, depending on whether the transfer is domestic or international and whether it's a consumer or business transaction, govern Wire Transfers.

2. Natural's Compliance

Natural and its Financial Partner(s) will comply with the Financial Services Terms and all applicable rules and regulations that govern consumer and business Wire Transfers.

3. Your Compliance

By using the Wire Transfer Transaction Method, You agree to comply with the Financial Services Terms and all applicable rules and regulations that govern consumer and business Wire Transfers.

4. Roles

A Natural user acts as the Wire Originator or Wire Beneficiary. Natural collects Transaction Instructions from the Wire Originator and submits those to a financial services institution for processing over Fedwire, SWIFT, or another wire network. Natural processes Wire Transfers only according to Transaction Instructions.

5. Wire Instructions

For purposes of the Wire Transfer Transaction Method, "Transaction Instructions" includes "Wire Instructions".

6. Irrevocability

Wire Transfers are immediate and irrevocable once processed.

Card Transaction Terms

1. Card Transactions

The Card Network Rules govern Card Transactions.

2. Natural's Compliance

Natural and its Financial Partner(s) will comply with the Financial Services Terms and all applicable Card Network Rules.

3. Your Compliance

By using the Card Transaction Method, You agree to comply with the Financial Services Terms and all applicable Card Network Rules.

4. Roles

A Natural user initiates and authorizes a Card Transaction. Natural and its Financial Partner(s) provide the software, infrastructure, financial services, and risk controls to enable and settle the Card Transaction, subject to all applicable Card Network Rules.

Financial Services Terms Appendix 1 (Definitions)

"ACH Network" means the Automated Clearing House network, a U.S. electronic funds transfer system that facilitates the movement of credits and debits between accounts held at depository institutions according to the NACHA Operating Rules.

"ACH Operator" means the entity, such as FedACH or the Electronic Payments Network (EPN), that receives ACH entries from ODFIs and transmits them to RDFIs according to the NACHA Operating Rules.

"ACH Originator" means an individual or entity that authorizes an ACH transaction and initiates an ACH entry to debit or credit an ACH Receiver's account, either directly through an ODFI or via a Third-Party Sender.

"ACH Receiver" means the individual or entity authorized to receive an ACH credit or whose account is debited as part of an ACH transaction.

"ACH Transaction" means a U.S. electronic funds transfer of credits and debits between accounts held at depository financial institutions.

"Acquirer" (or Acquiring Bank or Merchant Acquirer) means a financial institution that: (i) enters into an agreement with a merchant to enable acceptance of payment cards; (ii) submits authorization and clearing transactions to the applicable Card Network; and (iii) receives settlement funds from Issuers, and settles those funds to the merchant, less applicable fees.

"Card" means a payment card that is issued by an Issuer and linked to a Card Account.

"Card Account" means a credit account maintained with an Issuer through which You are extended credit and may request the issuance of Cards.

"Card Network" means a payment card network, such as Visa or Mastercard, that establishes rules, standards, and technical infrastructure for processing card transactions and facilitates authorization, clearing, and settlement between Issuers and Acquirers.

"Card Network Rules" means the guidelines, bylaws, rules and regulations published by a Card Network.

"Card Transaction" means a Transaction using a Card.

"FedNow" (the FedNow Services) means the U.S. payment method operated by the Federal Reserve that enables instant, irrevocable bank-to-bank payments that settle in real time, 24 hours a day, 7 days a week, 365 days a year, allowing participating banks to send and receive funds immediately between bank accounts with confirmation to both parties within seconds.

"FedNow Originator" means the individual or entity that initiates a FedNow payment through a participating bank according to a payment instruction.

"FedNow Receiver" means the individual or entity authorized to receive funds from a FedNow payment through a participating bank.

"Intermediary" means an entity that facilitates the transmission of an RTP or FedNow transaction between the Originator's and Receiver's banks, but does not take custody of the funds.

"Issuer" means a financial institution that issues a payment card to a cardholder, authorizes card transactions, and holds the cardholder's account from which funds are debited, or to which credit is extended, in connection with a Card Transaction.

"NACHA Operating Rules" means the rules, procedures, and guidelines issued by NACHA that govern the processing of ACH transactions, including the rights, obligations, and responsibilities of ACH Originators, RDFIs, and other participants in the ACH Network.

"ODFI" (Originating Depository Financial Institution) means the depository institution that receives ACH entries from an Originator or Third-Party Sender and transmits these entries to the ACH Operator.

Originator" means the individual or entity that initiates a payment through a participating bank according to a payment instruction.

"Payment Processor" means an entity that provides transaction processing services on behalf of an Issuer or Acquirer, including transmitting authorization requests and clearing data through a Card Network.

"RDFI" (Receiving Depository Financial Institution) means the depository institution that receives an ACH entry from the ACH Operator and posts it to the ACH Receiver's account according to the NACHA Operating Rules.

"Receiver" means the individual or entity authorized to receive funds from a payment through a participating bank.

"RFP" means a Request for Payment on the RTP Network.

"RTP" (Real-Time Payments) means the U.S. payment method that enables instant, irrevocable bank-to-bank payments or requests for payment ("RFP") that settle in real time, 24 hours a day, 7 days a week, 365 days a year, allowing participating banks to send and receive funds immediately between bank accounts with confirmation to both parties within seconds.

"RTP Network" means the real-time payment network operated by The Clearing House that facilitates RTP.

"RTP Network Rules" means the rules, procedures, and technical standards that govern the real-time payment transactions transmitted on the RTP Network.

"RTP Operator" means The Clearing House, the entity that operates the RTP Network, receives payment instructions from participating banks, and facilitates the real-time settlement of funds.

"Third-Party Sender" means an intermediary that formats and transmits an ACH entry on behalf of an ACH Originator to an ODFI and assumes contractual and compliance responsibilities under the NACHA Operating Rules.

"Transaction Method Provider" means an entity that issues, operates, or maintains a Transaction Method or its enabling network.

"Transaction Method Rules" means the publicly available guidelines, bylaws, rules, regulations, and contractual terms and conditions that govern how a party may use, process, or accept a Transaction Method.

"Wire Beneficiary" means the party whose account at the receiving financial institution is to be credited with funds from a Wire Transfer.

"Wire Instructions" means the payment details provided by the Originator to the sending bank, including the Beneficiary name, account number, bank routing or SWIFT code, currency, and any reference information required to complete the transfer.

"Wire Originator" means the party that instructs a sending financial institution to initiate a Wire Transfer, providing all required payment details and authorizations for the transfer to the Wire Beneficiary in accordance with applicable network rules, regulatory requirements, and bank agreements.

"Wire Transfer" means means an electronic payment of funds initiated by a Wire Originator through a sending financial institution and transmitted via a wire network (such as Fedwire, SWIFT, or any correspondent/intermediary bank) to a receiving financial institution for credit to a Wire Beneficiary's account, according to applicable network rules, regulatory requirements, and bank agreements.

Data Processing Agreement

This Data Processing Agreement ("DPA") is subject to and forms part of the Agreement and governs Natural's handling of Personal Data in connection with the Services. Capitalized terms not defined in the DPA have the meanings stated elsewhere in the Agreement.

Natural may update the DPA at any time by notifying You of the update and publishing the new version on Natural's website. Your continued use of the Services means You accept the updated DPA.

1. Roles of the Parties

1. Natural as Data Processor

When Natural acts as Data Processor, Natural Processes Personal Data on behalf of You, the Data Controller.

2. Natural as Data Controller

When Natural acts as Data Controller, it:

has the sole and exclusive authority to determine the purposes and means of Processing Personal Data it receives from or through You; and
may engage a Natural Affiliate to act as a Joint Controller or Data Processor.

3. You as Data Controller

When You act as Data Controller, You will provide lawful DP Instructions to Natural and comply with DP Law and this DPA.

2. Purpose and Scope

1. Natural as Data Processor

The purposes of Natural acting as Data Processor are to:

provide, and provide access to, the Services; and
operate and maintain the Natural Technology.

Natural will process Personal Data only according to this DPA, the Agreement, and Your DP Instructions, unless Law otherwise requires.

2. Natural as Data Controller

The purposes of Natural acting in its capacity as a Data Controller are to:

meet requirements from banks and Transaction Method Providers;
monitor, prevent, and detect fraudulent activity on the Natural Technology;
monitor, prevent, and mitigate financial loss, security risks, and other harm;
implement, maintain, and perform internal processes that enable Natural to provide the Services, including relationship management, billing, invoicing, and financial reporting; and
comply with Law, including applicable KYB/KYC and anti-money laundering screening requirements;
Comply with Governmental Authority and Financial Partner requirements and requests; and
analyze, maintain, and improve the Natural Technology and Natural's products and services.

3. Natural's Obligations as Data Processor

1. Confidentiality

Natural grants its personnel access to Personal Data only on a need-to-know basis and requires personnel to comply with confidentiality obligations.

2. Data Security

Natural complies with its data security obligations in the Agreement, including DPA Appendix 2 (Data Security Measures).

3. Data Subject Requests

Natural will:

reasonably assist You in responding to Data Subject Requests You receive that relate to Natural's Processing of Personal Data; and
inform You of each Data Subject Request that Natural receives relating to Your use of the Services and reasonably assist You in responding to those Data Subject Requests.

4. Sub-processors

You consent to Natural's use of Sub-processors and grant Natural a general written authorization to engage Sub-processors as necessary to provide You the Services. Natural will enter into a written agreement with each Sub-processor that:

imposes data processing and security obligations on the Sub-processor that are comparable to this DPA; and
requires the Sub-processor to comply with DP Law.

Natural is liable to You for the acts and omissions of its Sub-processors related to the Services.

5. Data Incidents

Natural will notify You without undue delay after becoming aware of a Data Incident that affects Your Personal Data. To the extent possible, Natural's notification to You will describe in reasonable detail:

the type of Personal Data that was the subject of the Data Incident;
the categories and potential number of individuals or records affected; and
the status of Natural's investigation and current or planned remediation.

Following the notification, Natural will provide relevant updates to help You comply with Your obligations under DP Law (as applicable).

6. Deletion or Return

Upon termination of the Services, Natural will delete or return Personal Data according to the Agreement, unless Law or a legitimate compliance obligation requires further retention.

7. Audits

Natural will make available to You all information necessary to reasonably demonstrate its compliance with this DPA, subject to confidentiality controls.

4. Your Obligations as Data Controller

1. Instructions

The DP Instructions You provide to Natural must be lawful and comply with DP Law and this DPA.

2. Permitted Geographies

You must provide Personal Data to Natural only from the Permitted Geographies.

3. Compliance with DP Law

You must comply with and perform Your obligations under DP Law and ensure there is an appropriate legal basis for all Processing of Personal Data in connection with the Services.

4. Disclosures

You must provide all required notices (including by making available a Privacy Policy) to—and obtain all necessary rights, permissions, and consents from—Data Subjects to enable Natural to lawfully Process all Personal Data You provide in connection with the Services. You are solely responsible for the content of notices You provide to Your Data Subjects.

5. Natural's Obligations as Data Controller

1. Compliance with DP Law

Natural must comply with and perform its obligations under DP Law when acting as Data Controller.

2. Privacy Policy

Natural must maintain a Privacy Policy that explains how and for what purposes Natural collects, uses, retains, discloses, and safeguards Personal Data.

6. Disclaimers of Liability

1. Your DP Instructions

Notwithstanding anything to the contrary in the Agreement, including in this DPA, Natural is not liable for any Data Subject Claim if Natural acted according to Your DP Instructions.

2. Non-US Personal Data

Natural is not liable for any Data Subject Claim regarding Personal Data outside of the Permitted Geographies.

3. Disclosure

Natural may disclose Personal Data to Governmental Authorities when Law requires or to comply with a valid legal request, subpoena, or regulatory obligation. In these cases, Natural will notify the Data Controller promptly unless Law prohibits.********

DPA Appendix 1 (Definitions)

"Agreement" means the Natural Services Agreement between You and Natural.

"CCPA" means California Consumer Privacy Act of 2018, Cal. Civ. Code Sections 1798.100-1798.199, and its implementing regulations.

"Data Controller" means an entity that, alone or jointly with others, determines the purposes and means of Processing Personal Data, which may include, as applicable, a "Business" as defined under the CCPA.

"Data Incident" means the unauthorized or unlawful Processing, use, access, loss, disclosure, destruction or alteration of Personal Data in a party's or its Affiliate's—or a party's or its Affiliate's subcontractor's, agent's, or representative's—possession or control.

"Data Privacy Framework" means, as applicable, the EU-US, Swiss-US, or UK-US Data Privacy Framework self-certification program operated by the US Department of Commerce.

"Data Processor" means an entity that Processes Personal Data on behalf of a Data Controller, which may include, as applicable, a "Service Provider" as defined under the CCPA.

"Data Security Measures" means technical and organizational measures that appropriately secure Personal Data depending on the risks associated with the Processing.

"Data Subject" means an identified or identifiable natural person to which Personal Data relates.

"Data Subject Request" means a Data Subject's request (including "verifiable consumer requests" under the CCPA) to exercise their rights under DP Law to (i) access (e.g., "right to know" under the CCPA) their Personal Data; (ii) have their Personal Data corrected or erased; (iii) restrict or object to Natural's Processing of their Personal Data; or (iv) initiate a data portability action.

"DP Law" means Law that applies to Personal Data Processing under the Agreement and this DPA, including international, federal, state, provincial and local Law that relates to privacy, data protection, or data security.

"DP Instructions" means the documented instructions provided by a Data Controller to a Data Processor that govern how the Data Processor may Process Personal Data.

"GDPR" means General Data Protection Regulation (EU) 2016/679.

"Joint Controller" means a Data Controller that jointly determines the purposes and means of Processing Personal Data with one or more Data Controllers.

"Permitted Geographies" means the location of (a) any individual physically located in the United States who is not a citizen of a European Union member state; or (b) any Financial Instrument located, held, or stored in the United States.

"Personal Data" means any information relating to an identifiable natural person that is Processed in connection with the Services and includes "personal data" as defined in the GDPR and "personal information" as defined in the CCPA.

"Privacy Policy" means any or all of a publicly posted privacy policy, privacy notice, data policy, cookies policy, cookies notice or other similar public notice that addresses a party's Personal Data practices and commitments.

"Process" means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, transfer, alignment, restriction, erasure, or destruction. "Processed" and "Processing" have corresponding meanings.

"Sensitive Data" means, to the extent this data is treated distinctly as a special category of Personal Data under DP Law: (a) Personal Data that is genetic data, biometric data, data concerning health, a natural person's sex life or sexual orientation; (b) data about racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (c) geolocation data; or (d) sensitive personal information as defined under the CCPA.

"Sub-processor" means an entity a Data Processor engages to Process Personal Data on that Data Processor's behalf in connection with the Services.

DPA Appendix 2 (Data Security Measures)

Natural implements and maintains these technical and organizational measures in order to safeguard Your data.

1. Security

1. Encryption

Natural encrypts data in transit and at rest.

Data in Transit - TLS 1.3 for external traffic and mTLS between services; and
Data at Rest - AES-256-GCM with a qualified encryption vendor for tokenizing Restricted Data.

2. Tokenization

Natural tokenizes payment credentials through regulated third-party providers and does not store payment credentials within Natural's systems.

3. Pseudonymization

Natural assigns unique identifiers (e.g., internal tokens) instead of direct identifiers (e.g., financial or bank account numbers) wherever possible in testing and production environments.

4. Access Controls

Natural limits employee access to Your data through role-based access controls. We require multi-factor authentication and manage encryption keys through secure systems.

2. Network Security

1. Firewalls and Segmentations

Natural logically separates development and staging environments from production environments.

2. Intrusion Detection and Prevention (IDS/IPS)

Natural continuously monitors network traffic to identify and block malicious activity.

3. Monitoring and Maintenance

1. Vulnerability Management

Natural performs, or engages a qualified third-party auditor to perform, regular automated scans and annual third-party Penetration Testing of the Natural Technology.

2. Retention Minimization

Natural retains Your Personal Data only as long as necessary to fulfill the purposes described in this DPA and Natural's Privacy Policy and to comply with Law.

3. Offboarding

Natural revokes access rights (both physical and logical) immediately upon the termination of an employee or contractor.

4. Compliance

1. Purpose Limitation

Natural collects and processes Personal Data only as necessary to achieve its defined, legitimate purposes.

2. Privacy Terms

Natural complies with the Natural Services Agreement, including this DPA, and Natural's Privacy Policy.

3. Data Subject Rights

Natural supports a Data Subject's right to access, correct, delete, or object to data processing.

5. Data Retention

1. Schedule

Natural retains data according to its data retention schedule, which is based on the applicable regulatory requirements and business needs for each data class.

2. Review

Natural maintains a documented data retention schedule and reviews it at least once annually.

3. Deletion

Natural deletes data using methods that comply with Law.