XCelerate AK — Client Acceptance Policy v1.2 Version 1.2 | Governing Law: Republic of Ghana | For each Client, this version replaces version 1.1 or 1.0 from the date the Client accepts it, or from the effective date of a notice given under section 17. 1. Acceptance of Terms By completing onboarding, the Client enters a binding agreement with XCelerate AK LLC, a company registered in the United States and Ghana and operating as XCelerate AK from Accra, Ghana, for use of the AI Concierge Platform. This agreement is governed by Ghanaian law and constitutes an electronic contract under the Electronic Transactions Act 2008 (Act 772). 2. Services Provided XCelerate AK provides an AI-powered customer service platform including automated messaging, human agent handoff, analytics, multi-channel integrations, subscription billing management, learning from the Client's own conversations (Learn Mode) and, at the Client's choice, importing the Client's recent WhatsApp chat history to learn from. 3. Eligibility and Authorisation The Client confirms that the signer is at least 18 years old, duly authorised to bind the organisation, that the business operates lawfully, and that the platform will be used only for lawful business communications. 4. Subscription and Billing Fees are as agreed in the service proposal. Billing is processed monthly through supported payment providers. Subscriptions auto-renew; written cancellation must be provided 30 days before the next renewal date. No refunds are issued for partial billing periods unless required by law. 5. Acceptable Use The Client must not send spam, distribute illegal or harmful content, violate intellectual-property or messaging-platform rights and policies, circumvent platform safeguards, or engage in deceptive, fraudulent, or unlawful activity. 6. Roles under Data Protection Law The Client is the data controller of the personal data of its customers and contacts that the platform processes for it, including messages, imported chat history, names, phone numbers and media. XCelerate AK processes that personal data as the Client's data processor, only on the Client's documented instructions, which include the settings the Client chooses in the platform, in accordance with Ghana's Data Protection Act, 2012 (Act 843). XCelerate AK is a data controller only for its own account, billing and security records. Both parties will maintain appropriate technical and organisational safeguards. 7. Data Processing Agreement XCelerate AK will: process personal data only on documented instructions; ensure that its personnel are bound by confidentiality; apply appropriate encryption and access controls; engage sub-processors only as set out in section 8; help the Client answer its customers' requests to access, correct or delete their personal data; notify the Client of a confirmed personal data breach without undue delay; and securely delete or return Client data within 30 days after the contract ends, subject to legal retention duties. 8. AI Service Providers and Processing Outside Ghana To read and answer messages, transcribe voice notes, describe images and learn from conversations, XCelerate AK sends the relevant message content to AI service providers that act as its sub-processors: MiniMax (language models); Anthropic PBC (Claude language models); OpenRouter, Inc. (a routing service that passes a request to the underlying model provider selected for it, which may be a different company, for example to use a lower-cost model); Groq, Inc. (voice-note transcription); and Microsoft (spoken replies). OpenRouter passes a request only to an endpoint that keeps neither the request nor the answer after serving it (zero data retention) and does not use them to train models, run by one of these model providers: Microsoft Azure (OpenAI models), OpenAI, Anthropic, Google (Vertex AI and AI Studio), Amazon Web Services (Bedrock), Mistral AI, xAI, DeepSeek, Moonshot AI, Z.ai, Alibaba Cloud, MiniMax, Groq, Cerebras, DeepInfra, Together AI, Fireworks AI, Baseten, Nebius and Parasail. No Client data goes to OpenRouter, or through it to any of these model providers, before version 1.1 of this policy or a later version applies to the Client, by the Client's acceptance or under section 17. Hosting, storage and delivery providers include Hetzner Online GmbH, Cloudflare, Inc., Meta Platforms (WhatsApp, Instagram and Messenger) and Resend (email). These providers process data in the United States, the European Union, Singapore, China and other countries, so the Client's data is processed outside Ghana. XCelerate AK applies the safeguards Act 843 requires for such transfers, sets each AI provider, where the provider offers the option, not to use the Client's data to train its models, and keeps the current list of sub-processors in its Privacy Policy. XCelerate AK will give notice before a new sub-processor processes the Client's data; the Client may object and end the service. 9. Learn Mode and Chat-History Import (a) Learn Mode. While the Client's AI is learning, the platform reads new conversations on the channels the Client connects, to learn how the business answers its customers. While learning, the AI does not reply to customers and does not mark their messages as read. (b) Chat-history import. When the Client links a WhatsApp number while setting up the service or while learning, before its AI first goes live, or when the Client asks the platform to import its chats, the platform imports the Client's recent one-to-one chats from that phone: at most the last 60 days, and a limited number of messages per chat. Group chats, broadcast lists, status updates and channels are never imported. Text is imported with a description of any media, such as its type and file name; the photos, videos, voice notes and documents themselves are not copied by the import. (c) Choice. Import is on by default when the Client links a number while setting up or learning. After the Client's AI has gone live, a number is imported only when the Client asks. The Client can switch import off before linking, stop it at any time, and delete imported chats at any time in the platform. (d) Exclusions. The Client can list contacts, such as family and friends, whose chats must not be imported or learned from. Their chats are skipped before they are read, and adding an exclusion deletes anything already imported from that contact. Contacts on the Client's list of contacts the AI must not reply to are excluded as well. (e) Use. Imported chats are used only to prepare the Client's own AI setup, such as its brain, knowledge and products, for the Client to review. The AI never answers customers from imported chats directly, imported chats are never used for another business, and nothing learned goes live until the Client approves it. (f) Retention. Imported chats are deleted automatically 90 days after import. Knowledge the Client approves from them becomes part of the Client's AI setup and is kept like any other knowledge the Client enters. An AI setup prepared from imported chats that the Client has not approved is deleted when the chats it was prepared from are deleted, whether by the Client, by an exclusion, by the 90-day rule or with the Client's account. Deleting the Client's account deletes imported chats with the rest of the Client's data. 10. Customer Notice and Lawful Basis The Client is responsible for having a lawful basis under Act 843 for XCelerate AK to process its customers' messages, including past chats, for these purposes, and for informing its customers. The Client will display or send a notice such as: "We use an AI assistant, provided by XCelerate AK, to help answer messages. Our conversations with you may be processed by it and by its AI providers, including outside Ghana. Ask us if you would like your chats excluded or deleted." When a customer asks, the Client will exclude or delete that customer's chats, and XCelerate AK will help it do so. 11. Intellectual Property XCelerate AK retains rights in the platform and underlying technology. The Client retains ownership of its business content and customer data. Each party grants the other a limited licence solely to deliver the contracted service. 12. Third-Party Integrations Third-party services may include Meta platforms, TikTok, Google Workspace, Cloudflare, hosting providers, payment processors and the AI service providers named in section 8. Their own terms apply. XCelerate AK is not liable for their policy changes, outages, or enforcement actions. Linking a WhatsApp number by QR code or pairing code uses a linked-device connection that WhatsApp does not officially support for businesses; WhatsApp may restrict or ban a number, and XCelerate AK is not liable for such action. 13. Service Levels and AI Quality XCelerate AK targets 99% monthly platform uptime excluding scheduled maintenance. AI response quality depends on the accuracy and completeness of the Client's approved knowledge and configuration. The Client must review and supervise automated outputs appropriate to its business. 14. Limitation of Liability XCelerate AK's aggregate liability is limited to fees paid in the three months before the event giving rise to a claim, to the extent permitted by law. XCelerate AK is not liable for indirect or consequential loss, third-party platform failure, or force majeure. The platform is provided as is without a warranty of fitness for a particular purpose. 15. Confidentiality Both parties will protect non-public information received under this agreement and disclose it only with consent or when required by law. 16. Termination Either party may terminate with 30 days' written notice. XCelerate AK may terminate immediately for material breach, non-payment, or unlawful use. Access ends on termination and data is handled under the Data Processing Agreement. 17. Changes to this Policy XCelerate AK may change this policy. Before a significant change takes effect, XCelerate AK will email the Client at least 30 days ahead, at the Client's email address on file, saying what changes, when it takes effect and where to read the new version. The new version takes effect at the start of the stated date (Accra time). Within that period the Client may object in writing (an email to support@xcelerateak.com, or the "I don't agree" button on the notice in the Client's Portal) or end this agreement under section 16; a termination notice given within that period counts as an objection. If the Client objects, the version the Client last accepted continues to apply to the Client, and anything the new version introduces stays off for the Client until the Client accepts it. If the Client does not object, the Client's continued use of the service after the effective date counts as acceptance of the new version, and no fresh acceptance in the platform is needed. Corrections and clarifications that do not reduce the Client's rights, and updates to the provider list under section 8, are notified by email and take effect as that email says. Section 8's own notice rule for a new sub-processor is unchanged. 18. Disputes Disputes first proceed to good-faith negotiation, then mediation under the ADR Act 2010 (Act 798), and thereafter may be referred to the courts of Ghana with jurisdiction in Accra. 19. Contact XCelerate AK LLC, House No. 34, 4th Street West, Near Camp Elim, North Legon, Accra, Ghana. Ghana registration BN 363591025; TIN P0023573066; VAT GHA-004746754-1. Contact and Data Protection Officer: info@xcelerateak.com.