● End-User Terms & CFPB Section 1033 Disclosures (v2.4)

Terms of Service & Open Banking Consumer Authorization

Effective Date: October 2026 | Provider: HeldAway / Black Dog Strategy (support@blackdogstrategy.ai)

1. Read-Only Financial Data Aggregation

By authenticating via multi-factor authentication (MFA) and linking a financial institution through Plaid Link on HeldAway, you authorize HeldAway to retrieve read-only account balances and up to 24 months (730 days) of transaction history solely on behalf of your designated Registered Investment Advisor (RIA).

2. No Custody or Money Movement

HeldAway is a read-only technology middleware platform. HeldAway does not hold custody of client assets, cannot initiate withdrawals or transfers, and never sells, rents, or monetizes consumer financial data to third-party marketers.

3. 90-Day Consent Lifecycle & Instant Revocation

In accordance with CFPB Section 1033 Open Banking standards, each institutional connection consent is valid for 90 days unless renewed or revoked earlier. You may revoke consent and permanently purge all stored data at any time via the Client Security Portal.