Effective June 1, 2026

Terms of Service

These Terms govern your use of the Initio Treasury website and platform (the "Service") provided by Initio Capital, Inc. ("Initio"). Banking services are governed separately by the Deposit Account Agreement with Column N.A.

1. Eligibility

You must be at least 18 years old, a U.S. citizen or resident, and authorized to act on behalf of any business entity you represent.

2. Acceptable use

You agree not to use the Service for any unlawful purpose, including money laundering, terrorist financing, sanctions evasion, or any activity prohibited by our Acceptable Use Policy.

3. Subscription fees

Scale subscription fees ($250/month) are billed monthly in advance and are non-refundable. You may cancel at any time; cancellation takes effect at the end of the current billing period.

4. Intellectual property

The Service, including all content, software, and trademarks, is owned by Initio or its licensors. You receive a limited, non-transferable license to use the Service for its intended purpose.

5. Limitation of liability

To the maximum extent permitted by law, Initio's aggregate liability for any claim arising from the Service is limited to the fees you paid to Initio in the 12 months preceding the claim.

6. Termination

Either party may terminate these Terms at any time. We may suspend or terminate access for breach, suspected fraud, or as required by law.

7. Arbitration

Disputes are resolved by binding individual arbitration in San Francisco, California, with a 30-day opt-out right (see Deposit Agreement §8).

Questions? Email compliance@initiotreasury.com or write to Initio Capital, Inc., Compliance Dept., 548 Market St #95421, San Francisco, CA 94104.