Draft for review

Terms of Use

The terms for using Advolo. This is version 1.0, marked draft for review. It is not a substitute for the firm’s own client agreements.

Last updated October 4, 2026, version 1.0 · Draft for review

01 — Service

What Advolo is

Advolo is a technology platform and provides no investment advice. Advolo never holds client funds.

Advolo is workflow technology for held-away recommendations. AdvoloTech provides the platform. Advolo is not an investment adviser, a broker-dealer, or a custodian, and it does not become one because a firm uses the platform.

Advisors send allocation recommendations. Clients decide whether to act and place any trades themselves, in their own accounts. Advolo does not place trades, does not hold client assets, and does not log in to client accounts.

02 — Accounts

Accounts and authority

A firm account is created only after a person at Advolo approves the firm and the invited chief compliance officer accepts these terms and sets a password. Advisor accounts are created when a person at a live firm invites them. Do not share a password. You are responsible for activity under your account.

The chief compliance officer accepts the Platform Agreement and the Security & Data Agreement for the firm during setup. Those acceptances are firm obligations. These Terms of Use are the person’s terms for using the platform.

03 — Firms

The firm remains the adviser

The registered investment adviser is responsible for its advice, its disclosures, its client agreements, and its supervision. Advolo keeps a record of what happened on the platform. That record does not replace the firm’s own compliance program, and an approval to open an account is not a certification of the firm.

04 — Clients

Recommendations only

When client onboarding opens, a client will be asked to acknowledge that Advolo provides recommendations only, that the client places any trades, and that Advolo never trades or holds the client’s assets. Until that flow exists, clients do not have accounts on the platform.

05 — Use

Acceptable use

Use the platform for a real firm and for held-away recommendations. Do not attempt to access another firm’s data, to probe the service, or to submit information you are not authorized to provide. Vulnerability reports belong at hello@advolo.com, as described in the Security & Data Policy.

06 — Policies

Related documents

The Privacy Policy and the Security & Data Policy are part of using Advolo. If those documents and these terms conflict on a security or privacy practice, the Security & Data Policy controls that practice. The firm’s client packet controls the firm’s own client relationship. Advolo does not replace it.

07 — Changes

Changes to these terms

We may publish a new version. The page shows the version and the date. A change to the major version (the number before the decimal) will require a new acceptance. We do not edit an acceptance that was already recorded.

These terms are draft for review, version 1.0, last updated October 4, 2026. They are approved for publication by the owner so firms can read them. Counsel’s review may replace this wording.