Consumer Terms

Primer Consumer Terms

Last updated: 28 May 2026

Agreement to These Terms

These Consumer Terms (the "Terms") form a legally binding agreement between Kernel AI Ltd, trading as Primer ("Primer", "we", "us", or "our"), and the individual who accesses or uses Primer for personal, non-business purposes ("you" or "your").

Kernel AI Ltd is a company registered in England and Wales under company number 15117085. Our registered office is 128 City Road, London EC1V 2NX, England. You can contact us at hello@primerapp.com.

These Terms govern your access to and use of Primer's websites, applications, software, tools, artificial intelligence features, content, subscriptions, and related services that link to these Terms (together, the "Services").

By creating an account, clicking to accept these Terms, purchasing a subscription, or otherwise using the Services, you agree to these Terms. If you do not agree, you must not use the Services.

These Terms apply only where you are acting wholly or mainly outside your trade, business, craft, or profession. If you use Primer on behalf of a business, organisation, employer, fund, firm, investment club, investment syndicate, client, customer, or other legal entity, or for professional research, commercial investing, advisory, portfolio-management, regulated, or employment-related purposes, our Business Terms or a separate written agreement apply instead.

The following documents are incorporated into these Terms:

• our Privacy Policy, which explains how we handle personal data;
• our Cookies Policy, which explains how we use cookies and similar technologies;
• our Acceptable Use Policy, which explains prohibited uses of the Services;
• our Cancellation and Refunds Policy, which explains cancellation, refunds, and cooling-off rights; and
• any plan terms, checkout terms, trial terms, or feature-specific terms shown to you when you sign up for or use a particular Service.

If there is a conflict between these Terms and any plan-specific terms shown at checkout, the checkout terms will apply to the relevant purchase. Nothing in these Terms limits any mandatory consumer rights that apply to you under the laws of your country of residence.

Key Consumer Information

This section summarises important information. It is not a substitute for the full Terms.

• Trader identity: Kernel AI Ltd, trading as Primer, company number 15117085, 128 City Road, London EC1V 2NX, England, hello@primerapp.com.
• Main characteristics: Primer is an AI-powered research and financial-analysis workspace. It helps organise, analyse, summarise, model, and draft research materials. It does not provide investment advice, personal recommendations, brokerage, execution, custody, or professional advice.
• Eligibility: you must be at least 18 and using Primer wholly or mainly for personal, non-business purposes under these Terms.
• Price and taxes: paid plan price, billing period, renewal date, trial period, cancellation terms, and applicable taxes or tax calculation method will be shown before you confirm payment.
• Contract duration: subscriptions renew automatically until cancelled. You can cancel through account settings, the billing portal, or by contacting us.
• Cooling-off: if statutory cancellation rights apply, you may have a 14-day right to cancel. If you request immediate access during that period, your refund rights may be reduced or, for digital content, may be lost where the legal requirements are met.
• Complaints and support: contact hello@primerapp.com.
• Version archive: current and previous legal terms should be available from our legal pages once published.

International Consumer Rights

Primer is operated by a UK company, but the Services may be accessed from different countries. Consumer protection laws vary by country, state, province, and territory. These Terms are intended to apply globally to the extent permitted by law, but they do not override mandatory consumer rights that apply where you live.

If any provision of these Terms is inconsistent with a mandatory consumer protection law that applies to you, that law will apply to the extent of the inconsistency and the relevant provision will be interpreted or limited so that it is lawful. You will continue to have any non-waivable rights and remedies available under your local law.

Without limiting that general rule:

• United Kingdom consumers may have rights under laws including the Consumer Rights Act 2015 and the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, including rights relating to digital content, services, pre-contract information, cancellation, and unfair terms.
• European Union and European Economic Area consumers may have rights under national laws implementing EU consumer legislation, including rules on pre-contract information, unfair terms, legal conformity of digital content and digital services, and the 14-day right of withdrawal for distance contracts. Where required, we will provide cancellation information, withdrawal information, and other mandatory information before you are bound.
• United States consumers may have federal and state rights relating to automatic renewal, negative option subscriptions, trial conversion, cancellation, price changes, disclosures, unfair or deceptive practices, and state-specific notices. Where required, renewal terms must be presented clearly, your affirmative consent must be obtained, and cancellation must be available through a simple method appropriate to how you signed up.
• California and other US state consumers may have additional automatic-renewal and online-cancellation rights. If you sign up online and a law requires online cancellation, we will provide an online cancellation mechanism and will not require you to use a more burdensome method.
• Australian consumers have rights under the Australian Consumer Law, including consumer guarantees that cannot be excluded. Nothing in these Terms excludes, restricts, or modifies any non-excludable Australian consumer guarantee, right, or remedy.
• New Zealand consumers may have rights under the Consumer Guarantees Act 1993 and Fair Trading Act 1986, including rights relating to online trading, digital products, services, misleading conduct, and consumer guarantees. Nothing in these Terms excludes rights that cannot be excluded under New Zealand law.
• Canadian consumers may have federal and provincial rights relating to online contracts, subscription renewals, cancellation, pricing, taxes, deceptive marketing, and consumer remedies. Quebec consumers may have additional language, online-contract, cancellation, and disclosure rights. Where mandatory local law requires French-language terms or notices, the required local-language materials will control for those consumers.
• Consumers in other countries, states, provinces, and territories may have similar or additional rights. These Terms are not intended to exclude them.

We may restrict, suspend, or decline access in a country or region where we reasonably believe that offering the Services would be unlawful, require licensing or registration we do not hold, create material regulatory risk, or prevent us from complying with sanctions, export controls, consumer law, tax law, or payment processor requirements.

Some local rights must be implemented in the product experience, not only in these Terms. For example, applicable law may require specific checkout disclosures, tax-inclusive pricing, renewal reminders, easy online cancellation, local-language notices, withdrawal forms, or refund mechanics. Where those requirements apply, the relevant checkout, billing, cancellation, email, or account-settings flow should be read together with these Terms.

1. Who May Use Primer

You must be at least 18 years old to use the Services.

You must provide accurate, current, and complete information when creating an account or purchasing a subscription. You must keep your account credentials confidential and must not share your account with anyone else. You are responsible for all activity under your account unless the activity results from our failure to use reasonable care.

You must not create or use an account if you are barred from using the Services under applicable law, sanctions, export controls, payment processor rules, or the laws of the country where you are located or ordinarily resident.

You must tell us promptly at hello@primerapp.com if you believe your account has been compromised or used without permission.

We may refuse, suspend, or terminate access where we reasonably believe that:

• you do not meet the eligibility requirements;
• your account information is inaccurate or misleading;
• your account has been compromised;
• your use breaches these Terms or our Acceptable Use Policy;
• your use could cause harm, liability, legal risk, security risk, or regulatory risk to us, our users, or others; or
• we are required to do so by law, regulation, court order, payment processor rules, sanctions, export controls, or a competent authority.

Where reasonably practicable and legally permitted, we will give you notice and an opportunity to appeal or remedy the issue before or shortly after suspension or termination.

2. What Primer Does

Primer is an AI-powered research and financial-analysis workspace. Depending on the plan and features available to you, the Services may help you retrieve, organise, summarise, compare, model, draft, and analyse information from company disclosures, filings, earnings materials, transcripts, presentations, market information, news, user-provided materials, and other sources.

The Services may generate summaries, analyses, comparisons, tables, models, calculations, charts, alerts, draft written materials, research notes, and other outputs (together, "Outputs") based on your prompts, files, instructions, configurations, watchlists, notes, datasets, and other materials (together, "Inputs"), third-party information, and artificial intelligence systems.

Primer is designed to support your own research workflow. It is not designed to replace your judgment, independent verification, or professional advice.

Primer does not connect to brokerage accounts, does not place or route orders, does not hold money or assets, does not custody securities or cryptoassets, and does not execute, clear, settle, or arrange transactions. If a third-party integration or workflow ever allows external actions, you remain responsible for reviewing and authorising those actions before they are taken unless we expressly state otherwise in separate terms.

3. Important AI Limitations

Artificial intelligence systems are probabilistic and may produce Outputs that appear confident, detailed, or precise even when they are wrong. You acknowledge and agree that:

• Outputs may be inaccurate, incomplete, outdated, misleading, biased, non-unique, or unsuitable for your purpose;
• Outputs may omit important context, cite sources incorrectly, misread documents, make calculation errors, or draw unsupported conclusions;
• the Services may not identify every relevant risk, assumption, disclosure, event, conflict, inconsistency, or source limitation;
• automated workflows, alerts, and recurring research tasks may fail, run late, miss events, or produce irrelevant or incorrect results;
• third-party data, market data, filings, transcripts, websites, and other sources may be delayed, incomplete, unavailable, inaccurate, or subject to third-party rights and terms;
• Outputs may contain numerical, spreadsheet, formula, currency, unit, date, valuation, citation, source-matching, or classification errors;
• Outputs may be affected by prompt injection, malicious third-party content, formatting defects, inaccessible source material, or model/provider limitations;
• actions suggested by the Services may be inappropriate, unlawful, financially harmful, or unsuitable for you if followed without independent review;
• Outputs may not reflect our views; and
• similar or identical Outputs may be generated for other users.

You must independently review and verify Outputs before relying on them, sharing them, publishing them, trading on them, or using them to make any decision. You must not rely on the Services or Outputs as your sole source of truth or as a substitute for professional advice.

You must apply human review before using any Output in connection with financial decisions, legal rights, tax positions, health or safety, employment, housing, credit, education, insurance, eligibility, access to services, or any other decision that could have a legal, financial, or similarly significant effect on a person.

4. Finance, Investment, and Regulated Activity Disclaimer

Primer provides research-support, information-management, modelling, and productivity tools. Primer does not provide financial, investment, legal, tax, accounting, pension, insurance, mortgage, credit, or other regulated advice.

Unless we expressly agree otherwise in a signed written agreement, Primer is not:

• an investment adviser, financial adviser, financial planner, broker-dealer, introducing broker, investment manager, portfolio manager, asset manager, research analyst, securities dealer, trading venue, exchange, clearing house, custodian, bank, lender, insurer, tax adviser, accounting firm, law firm, or fiduciary;
• authorised, registered, licensed, or regulated by the UK Financial Conduct Authority, US Securities and Exchange Commission, FINRA, CFTC, NFA, or any other financial-services regulator to provide investment advice, personal recommendations, brokerage, execution, order routing, dealing, custody, asset management, portfolio management, investment research as a regulated service, tax advice, legal advice, or accounting advice; or
• responsible for determining whether any investment, security, financial instrument, strategy, portfolio, transaction, tax position, filing position, accounting treatment, or legal position is suitable, appropriate, lawful, or advisable for you.

The Services and Outputs are for general informational, educational, research, and productivity purposes only. They do not constitute and must not be treated as:

• investment advice, financial advice, trading advice, personal recommendations, portfolio recommendations, or regulated investment research;
• an offer, invitation, recommendation, inducement, solicitation, or instruction to buy, sell, hold, subscribe for, underwrite, redeem, short, lend, borrow, or otherwise transact in any security, commodity, derivative, cryptoasset, currency, fund interest, loan, deposit, insurance product, or other financial product;
• an assessment of suitability, appropriateness, risk tolerance, investment objectives, financial circumstances, tax status, legal obligations, or regulatory obligations;
• brokerage, execution, order routing, custody, settlement, clearing, payment, valuation, pricing, rating, audit, assurance, tax, legal, or accounting services; or
• a promise or guarantee of performance, returns, outcomes, accuracy, availability, or risk reduction.

The Services may cover or refer to issuers, instruments, asset classes, sectors, exchanges, trading venues, indices, benchmarks, currencies, commodities, cryptoassets, funds, private-market assets, public-market assets, macroeconomic indicators, geographies, and jurisdictions around the world. Any reference to a market, jurisdiction, asset class, security, issuer, product, benchmark, index, strategy, or transaction is market-agnostic research-support content only. It does not mean that Primer is authorised, licensed, approved, passported, registered, or otherwise permitted to provide regulated services in that market or jurisdiction, and it does not mean that the relevant instrument, market, strategy, or transaction is lawful, available, appropriate, or suitable for you.

The disclaimers and restrictions in these Terms apply across all markets, jurisdictions, venues, and asset classes, including listed securities, unlisted securities, equities, bonds, loans, funds, ETFs, derivatives, options, futures, swaps, contracts for difference, commodities, foreign exchange, rates, indices, benchmarks, cryptoassets, tokenised assets, private funds, private credit, venture capital, real estate, structured products, insurance products, pensions, deposits, and any other financial or investment product. You are responsible for understanding and complying with any local laws, regulator rules, exchange rules, market-data terms, sanctions, tax obligations, disclosure obligations, account restrictions, investor-qualification rules, and dealing restrictions that apply to your own use of information or to any investment or trading activity.

No Output should be understood as saying that any financial instrument, issuer, company, market, sector, portfolio, strategy, risk, price, valuation, forecast, event, or transaction is suitable for you or for any other person. References to "buy", "sell", "hold", "long", "short", "overweight", "underweight", "target", "fair value", "upside", "downside", "risk", "opportunity", "signal", "thesis", "view", "rating", "screen", or similar finance language are generated as research-support language only and are not personal recommendations or investment advice.

The Services may process information about publicly traded companies and markets. You must not use the Services to misuse inside information, material non-public information, confidential information, trade secrets, embargoed information, restricted research, restricted-list information, or other information that you are not lawfully permitted to use. You are responsible for complying with all laws and rules that apply to your own investing or trading activity, including market abuse, insider dealing, securities, commodities, sanctions, tax, disclosure, and reporting rules.

You must not present Primer or any Output as being approved, endorsed, reviewed, authorised, or regulated by any financial regulator, exchange, issuer, broker, investment adviser, or other third party unless that is true and you have permission to do so.

You are solely responsible for your financial, investment, legal, tax, accounting, and business decisions. You should obtain advice from an appropriately qualified and regulated professional before making decisions that could affect your finances, investments, tax position, legal rights, regulatory obligations, or other important interests.

You must not use the Services to provide financial advice, investment advice, personal recommendations, financial promotions, regulated research, brokerage, execution, custody, portfolio management, tax advice, legal advice, accounting advice, or any other regulated service to another person unless you are properly authorised to do so and your use of Primer is lawful and consistent with these Terms. Consumer accounts are not intended for that use.

5. Your Inputs and Rights in Outputs

You retain any rights you already have in your Inputs. You are responsible for your Inputs, including making sure that you have all rights, licences, permissions, and lawful bases needed to submit them to the Services and for us and our service providers to process them.

You must not submit third-party data, market data, documents, transcripts, filings, broker research, analyst research, ratings, estimates, expert-network materials, proprietary datasets, paid newsletters, or other content if your licence, subscription, employment obligations, platform terms, or applicable law does not permit that use. You are responsible for complying with any terms that apply to data or content you upload, paste, import, connect, or ask the Services to process.

You grant us, our affiliates, subprocessors, and service providers a worldwide, non-exclusive, royalty-free licence to host, copy, transmit, store, modify, process, analyse, display, and otherwise use your Inputs and Outputs to:

• provide, operate, maintain, secure, troubleshoot, and improve the Services;
• generate and deliver Outputs and related features;
• prevent abuse, fraud, security incidents, and policy violations;
• comply with law, regulation, court orders, and lawful requests; and
• otherwise act as described in our Privacy Policy and any settings or plan terms made available to you.

As between you and Primer, and to the extent permitted by law and subject to third-party rights, we assign to you any right, title, and interest we may have in Outputs generated specifically for you by the Services. This assignment does not transfer rights in our Services, software, models, systems, prompts, tools, templates, workflows, brand, or other technology. It also does not transfer third-party rights in source materials, market data, licensed data, or content that may be reflected in an Output.

We do not guarantee that Outputs are protectable by intellectual property rights, unique to you, non-infringing, confidential, accurate, or suitable for commercial publication. You are responsible for reviewing Outputs before using or sharing them.

Unless we clearly tell you otherwise or you separately consent, we will not use your uploaded files, prompts, or Outputs to train third-party foundation models. We may use your Inputs, Outputs, usage data, and feedback to provide, secure, debug, analyse, evaluate, and improve the Services as described in our Privacy Policy, including through human or automated review where needed for safety, quality, support, abuse prevention, or legal compliance. We may also create aggregated or de-identified information from use of the Services, provided it does not identify you.

6. Privacy and Personal Data

Our Privacy Policy explains how we collect, use, disclose, retain, and protect personal data. You must read it before using the Services.

You must not upload or submit personal data, confidential information, inside information, non-public market-sensitive information, special category data, health data, biometric data, children's data, government identifiers, payment card data, passwords, authentication secrets, or other highly sensitive information unless:

• you have all rights and lawful bases needed to do so;
• your use is lawful and consistent with these Terms and our Acceptable Use Policy; and
• the relevant plan or feature is appropriate for that type of information.

If you ask the Services to process information about another person, you are responsible for ensuring that your use is lawful and fair to that person.

The Services are not intended for children and must not be used to process children's personal data. If you believe a child has provided personal data to us, contact hello@primerapp.com.

7. Acceptable Use

You must use the Services only for lawful purposes and in accordance with these Terms and our Acceptable Use Policy.

You must not, and must not help anyone else to:

• use the Services in a way that violates any applicable law, regulation, sanctions, export controls, court order, third-party right, or contractual obligation;
• use the Services to make, support, or automate decisions that have legal or similarly significant effects on a person without appropriate human review and a lawful basis;
• use the Services to provide regulated financial, investment, legal, tax, accounting, credit, insurance, employment, housing, education, healthcare, or other regulated services without proper authorisation;
• use the Services to trade, place orders, route orders, execute transactions, hold assets, manage portfolios, or provide custody;
• use the Services for market manipulation, insider dealing, unlawful disclosure, pump-and-dump schemes, spoofing, wash trading, misleading financial promotions, fraudulent fundraising, sanctions evasion, tax evasion, money laundering, or other financial crime;
• use the Services to identify, target, exploit, or mislead vulnerable people or to make eligibility, credit, insurance, employment, housing, education, healthcare, or similar high-impact decisions about a person;
• use the Services to generate, distribute, or rely on misleading, deceptive, fraudulent, defamatory, infringing, harmful, or illegal content;
• upload content that you do not have the right to use or that infringes another person's rights;
• reverse engineer, decompile, disassemble, copy, resell, rent, lease, sublicense, scrape, crawl, harvest, benchmark, or build a competing service from the Services except where this restriction is prohibited by law;
• use automated or non-human means to access the Services unless we expressly permit it;
• use Outputs to train, distil, evaluate, or improve a model or service that competes with Primer or our model providers, except where we expressly permit it or the restriction is prohibited by law;
• bypass rate limits, usage limits, access controls, security controls, safety systems, filters, or other protective measures;
• interfere with, disrupt, overload, damage, or impair the Services or any third-party system;
• introduce malware, harmful code, prompt injections intended to exfiltrate data, or other malicious content;
• use prompts, files, websites, or tool outputs to extract system prompts, secrets, credentials, customer data, proprietary data, model weights, or non-public information;
• misrepresent the source, accuracy, or human authorship of Outputs;
• share your account credentials or make your account available to another person; or
• use the Services in any way that could expose us, our users, our providers, or others to harm, liability, security risk, legal risk, regulatory risk, or reputational harm.

We may monitor for misuse and may remove content, restrict features, block prompts or Outputs, suspend access, terminate accounts, report unlawful activity, or preserve and disclose information where reasonably necessary to protect the Services, users, third parties, legal compliance, or our rights.

8. Plans, Subscriptions, Trials, Credits, and Limits

Some Services are free, and some require payment. The plan, price, billing period, included credits, feature limits, trial period, renewal date, taxes, cancellation terms, and any other material checkout terms will be shown to you before you confirm payment.

If you purchase a paid subscription, you must provide accurate billing information and a valid payment method. You confirm that you are authorised to use the payment method you provide.

Subscriptions renew automatically at the end of each billing period unless you cancel before renewal. By purchasing a subscription, you authorise us and our payment processors to charge your payment method for subscription fees, applicable taxes, and any accepted add-ons or usage-based charges on a recurring basis until cancellation.

Before you confirm payment, the checkout flow should clearly show the plan you are buying, whether the plan is monthly or annual, the total recurring charge or how it is calculated, any trial end date or first charge date, the renewal frequency, cancellation route, refund terms, and the legal documents you are accepting. After purchase, we will provide a confirmation in a durable form, such as email, containing the key contract information required by applicable law.

If we offer a trial, the trial length, trial features, trial limits, payment requirements, conversion date, renewal date, and cancellation requirements will be shown during sign-up or checkout. If a trial converts into a paid subscription, we will tell you before you confirm the trial and will send reminders where required by law.

Plans may include credits, usage allowances, active-run limits, feature limits, fair-use limits, rate limits, storage limits, or other technical limits. Credits and usage allowances:

• are not cash, stored value, e-money, gift cards, or deposit accounts;
• have no monetary value outside the Services;
• may expire at the end of the relevant billing period or trial period unless we state otherwise;
• are not transferable, exchangeable, or refundable except where required by law or expressly stated by us; and
• may be adjusted, withheld, or revoked where there is fraud, abuse, error, chargeback, refund, or breach of these Terms.

We may change plan features, model availability, limits, and credit consumption rules from time to time. If a change materially reduces the core paid functionality of your current subscription, we will give reasonable notice where practicable and legally required. If the change materially disadvantages you during a paid subscription period, your mandatory consumer rights, including any right to cancel or receive a proportionate refund, are not affected.

9. Prices, Taxes, and Payment Processing

Prices are shown on our website, in the Services, or during checkout. Consumer-facing prices will be displayed in a way intended to comply with applicable consumer pricing laws. In some jurisdictions, taxes must be included in the advertised consumer price where they can be calculated in advance. In other jurisdictions, taxes may be calculated and added during checkout. Where taxes apply, we or our payment processor will calculate and show applicable taxes, or the method for calculating them, before you confirm payment where required by law.

You are responsible for all taxes, duties, levies, and similar charges that apply to your purchase, except taxes based on our net income. The amount of tax may depend on your billing address, tax status, location, and other information you provide.

Payments are processed by third-party payment processors such as Stripe. Payment processor terms and privacy notices may apply. We are not responsible for payment processor errors, delays, outages, card issuer decisions, bank fees, currency conversion charges, or unauthorised payment method use, except where caused by our failure to use reasonable care or where the law says otherwise.

If payment fails, we may retry payment, ask you to update your payment method, downgrade your plan, restrict paid features, suspend access, or cancel your subscription.

We may change subscription prices. If we increase the recurring price of your subscription, we will give you at least 30 days' notice where required by law, and the increase will apply no earlier than your next renewal. You can cancel before the increase takes effect if you do not agree. If applicable law requires express consent for a price increase or material subscription change, we will seek that consent.

10. Cancellation, Cooling-Off, and Refunds

You may cancel your subscription at any time through your account settings, the billing portal, or any other cancellation method we make available. You can also contact us at hello@primerapp.com.

Cancellation stops future renewals. Unless we tell you otherwise, you will continue to have access to paid features until the end of the billing period you have already paid for.

Except where required by law or expressly stated by us, payments are non-refundable and we do not provide refunds or credits for partial billing periods, unused credits, unused features, downgrades, account inactivity, or failure to cancel before renewal.

If you are a consumer in the United Kingdom, European Economic Area, or another jurisdiction with statutory cancellation rights, you may have a legal right to change your mind and cancel your subscription within 14 days after the contract is formed, without giving a reason. Your local law may give you additional or different rights.

When you purchase a subscription, we may ask you to tick a separate box requesting immediate access to the Services during the 14-day cooling-off period and acknowledging the cancellation consequences. If you do not request immediate access, we may delay access to paid digital content or paid Services until the cooling-off period expires where legally necessary to preserve cancellation rights. If you request immediate access:

• we may begin supplying the digital service immediately;
• for services, if you cancel during the cooling-off period after supply has begun, we may deduct or retain an amount that is proportionate to the Services supplied before you cancelled, including usage, credits consumed, and any non-recoverable third-party costs, where permitted by law;
• for services that have been fully performed during the cooling-off period, you may lose the right to cancel once performance is complete if you expressly requested early performance and acknowledged the cancellation consequences where required by law; and
• for digital content not supplied on a tangible medium, you may lose the right to cancel once supply has begun if you expressly consented to immediate supply and acknowledged that you would lose the right to cancel, where required by law.

If you cancel during a statutory cooling-off period and are entitled to a refund, we will make any refund due without undue delay and no later than 14 days after the day we are informed of your decision to cancel, unless a different period is required by law. We will normally refund using the same payment method you used for the original transaction unless you agree otherwise.

You may use the model cancellation form in the Appendix, but you do not have to. A clear statement that you wish to cancel is enough.

These Terms do not limit your statutory rights where the Services are not as described, not of satisfactory quality, not fit for purpose, defective, or otherwise fail to meet consumer law requirements that apply to you.

11. Third-Party Services and Content

The Services may use, display, link to, or integrate with third-party content, websites, data sources, model providers, infrastructure providers, analytics providers, payment processors, authentication providers, and other third-party services.

Third-party services and content are not controlled by us. They may be inaccurate, delayed, incomplete, unavailable, insecure, or subject to separate terms, privacy notices, fees, and restrictions. We are not responsible for third-party services or content except where required by law.

You are responsible for complying with third-party terms that apply to your use of third-party services or content.

Market data, company data, filings, transcripts, news, estimates, and other financial information may be delayed, limited, corrected, restated, withdrawn, subject to licence restrictions, or unsuitable for your intended use. You must verify source documents and applicable data-provider terms before relying on or redistributing any Output.

12. Service Availability and Changes

We will use reasonable care and skill in providing the Services. However, the Services may be unavailable, degraded, changed, suspended, limited, or discontinued from time to time due to maintenance, updates, security issues, abuse prevention, legal requirements, third-party outages, model provider changes, data provider changes, capacity limits, or events beyond our reasonable control.

We may add, remove, update, replace, restrict, or modify features, models, tools, workflows, content sources, data providers, limits, and user interfaces. We do not guarantee that any particular feature, model, provider, source, or Output format will always be available.

We may apply usage limits, queueing, throttling, content filters, safety filters, abuse controls, and security checks. These controls may block, delay, modify, or refuse Inputs or Outputs, including where they are lawful, if we reasonably consider that doing so protects the Services, users, us, third parties, or legal compliance.

If we discontinue a paid Service during a period you have already paid for, and you are not in breach of these Terms, we will give reasonable notice where practicable and provide a refund or credit for the unused prepaid period where required by law or where we consider it fair to do so.

13. Our Intellectual Property

We and our licensors own all rights, title, and interest in and to the Services, including software, models, systems, workflows, prompts, templates, interfaces, designs, databases, documentation, trademarks, logos, trade names, and other technology and content.

Subject to your compliance with these Terms, we grant you a personal, limited, revocable, non-exclusive, non-transferable right to access and use the Services for your own personal, non-business purposes.

You must not copy, modify, distribute, sell, lease, sublicense, make available, or create derivative works from the Services except as expressly permitted by these Terms or by law.

14. Feedback

If you provide feedback, ideas, suggestions, bug reports, ratings, comments, or other information about the Services ("Feedback"), you grant us a worldwide, perpetual, irrevocable, royalty-free licence to use, copy, modify, publish, distribute, and otherwise exploit that Feedback for any purpose without compensation to you. This does not affect your rights in personal data under the Privacy Policy.

15. Liability

Nothing in these Terms excludes or limits liability where it would be unlawful to do so. This includes liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, and your mandatory consumer rights.

We are responsible for foreseeable loss and damage caused by our breach of these Terms or our failure to use reasonable care and skill. Loss or damage is foreseeable if it was obvious that it would happen or if, at the time the contract was made, both you and we knew it might happen.

The Services are supplied for domestic and private use under these Consumer Terms. If you use the Services for commercial, business, professional, regulated, or investment-management purposes under a consumer account, we will not be responsible for business losses or regulated-use losses that would not have arisen from permitted personal use.

We are not responsible for:

• loss or damage that is not foreseeable;
• loss or damage caused by your breach of these Terms, misuse of the Services, or failure to follow our reasonable instructions;
• loss or damage caused by third-party services, third-party content, data providers, model providers, payment processors, telecommunications providers, internet providers, device failures, or events outside our reasonable control, except where the law says otherwise;
• decisions you make based on Outputs without independent review or professional advice;
• business losses, including loss of profit, loss of revenue, loss of business, business interruption, loss of opportunity, loss of goodwill, or loss of anticipated savings, because the Services under these Terms are for personal, non-business use only; or
• loss of data or content where you failed to keep your own backup or export and it was reasonable for you to do so.

Except for liability that cannot lawfully be limited, our total liability to you arising out of or relating to these Terms or the Services will be limited to the greater of: (a) the amount you paid us for the Services in the 12 months before the event giving rise to the claim; and (b) GBP 100. This limit does not reduce any remedy that mandatory consumer law says must be available to you.

16. Your Responsibility to Us

You are responsible for losses we suffer that arise from your breach of these Terms, misuse of the Services, unlawful Inputs, infringement of third-party rights, unauthorised use of another person's payment method, or use of the Services in a way that creates legal, regulatory, security, or financial risk for us, except to the extent the loss was caused by our breach of these Terms or failure to use reasonable care.

Nothing in this section requires you to compensate us for our own negligence, wilful misconduct, or breach of these Terms.

17. Account Closure and Termination

You may stop using the Services at any time. You may close your account by using any account closure feature we make available or by contacting hello@primerapp.com.

We may suspend or terminate your account or access to the Services if:

• you breach these Terms or our Acceptable Use Policy;
• you do not pay amounts due;
• your account is inactive for a prolonged period and you do not have an active paid subscription;
• we reasonably believe your use creates legal, regulatory, security, safety, financial, or reputational risk;
• we need to protect the Services, users, us, or others;
• we are required to do so by law, regulation, sanctions, export controls, court order, payment processor rules, or a competent authority; or
• we discontinue the Services.

Where reasonably practicable and legally permitted, we will give you notice before termination. You may contact us at hello@primerapp.com if you believe your account has been suspended or terminated in error.

When your account closes or these Terms terminate, your right to use the Services ends. Where reasonably practicable and legally required, we will give you a reasonable opportunity to export your Inputs and Outputs before account closure, except where access is suspended or terminated for security, legal, non-payment, rights-infringement, or abuse reasons. Sections that by their nature should survive will continue to apply, including sections on AI limitations, finance disclaimers, payment obligations, intellectual property, privacy, liability, disputes, and interpretation.

18. Changes to These Terms

We may update these Terms from time to time. If we make material changes, we will give reasonable notice, such as by posting the updated Terms, sending an email, or showing an in-product notice.

Unless we say otherwise, updated Terms will apply from the effective date stated in the updated version. If you continue to use the Services after the updated Terms take effect, you agree to the updated Terms.

If a change materially affects your rights or obligations and you do not agree, you may stop using the Services and cancel any subscription before the change takes effect. Where required by law, we will ask for your consent to material changes.

We will not use changes to these Terms to remove rights or remedies that have already accrued to you, or to avoid responsibility for our past breach of these Terms.

Previous versions of these Terms will be available in our legal archive.

19. Notices and Communications

We may contact you about the Services, your account, legal notices, billing, subscriptions, security, support, and changes to these Terms using the email address or contact details you provide, by in-product notice, or by posting on the Services.

Legal notices sent electronically will satisfy any legal requirement that they be in writing, to the extent permitted by law.

You are responsible for keeping your contact details up to date. We are not responsible if you do not receive a notice because your account email is incorrect, inactive, blocked, full, or controlled by someone else.

20. Complaints, Governing Law, and Disputes

If you have a complaint, contact hello@primerapp.com with enough information for us to understand and investigate the issue. We will try to respond within a reasonable time.

These Terms are governed by the laws of England and Wales, except that this choice of law does not deprive you of mandatory consumer protections that apply in your country of residence.

If you live in the United Kingdom, you may bring legal proceedings in the courts of England and Wales, Scotland, or Northern Ireland, depending on where you live.

If you live in the European Union, European Economic Area, Switzerland, or another country outside the United Kingdom, you may have the right to bring proceedings in your local courts under mandatory consumer protection laws. Nothing in these Terms limits those rights.

We encourage you to contact us first at hello@primerapp.com so we can try to resolve any issue informally.

21. General Terms

These Terms, together with the documents incorporated into them, form the entire agreement between you and us for your consumer use of the Services.

If any part of these Terms is found to be invalid or unenforceable, the rest will continue to apply.

Our failure to enforce any part of these Terms is not a waiver of our right to do so later.

You may not transfer your account or rights under these Terms to another person without our consent. We may transfer our rights and obligations under these Terms to another organisation, for example in connection with a merger, acquisition, reorganisation, or sale of assets. If we do so and the transfer materially affects your rights, we will notify you where required by law.

No person other than you and us has rights to enforce these Terms, except our affiliates, licensors, distributors, payment processors, subprocessors, service providers, and other providers may enforce provisions that protect them where applicable.

Appendix: Model Cancellation Form

You may use this form to cancel during a statutory cooling-off period, but you do not have to. You can also cancel through your account, the billing portal, or by emailing hello@primerapp.com with a clear statement that you wish to cancel.

To: Kernel AI Ltd, trading as Primer, 128 City Road, London EC1V 2NX, England, hello@primerapp.com

I hereby give notice that I cancel my contract for the following service:

• Service or subscription:
• Ordered on:
• Account email:
• Name:
• Address:
• Signature (only if this form is printed):
• Date: