Legal & Compliance

    Legal Agreements

    These terms govern your use of Hollis & Co services. By opening an account or using our platform, you agree to the agreements below.

    Hollis & Co., Inc.  ·  EIN: 42-1944327  ·  Delaware C-Corp, File No. 10581092

    5831 Forward Avenue, Unit 801, Pittsburgh, PA 15217  ·  legal@hollisand.co

    Effective Date: April 2026

    Section 1

    User Terms

    These User Terms are a binding agreement between the Company or User that applies for or uses the Services ("you") and Hollis & Co., Inc. ("we", "us", "our") — a Delaware C-Corporation (EIN: 42-1944327, File No. 10581092), operating under the trade name Hollis & Co — that governs your access to and use of our Services. Capitalized terms used in these User Terms are defined in our Platform Agreement and Privacy Policy.

    By using the Services, you consent to these User Terms and any applicable Service-Specific Terms for Services you use. We hereby grant to you limited permission to access and use our Services, and any use of our Services not expressly permitted in our terms is prohibited.

    You also acknowledge and agree that by using the Services, your data, including any personal information, may be collected, used, transferred and processed in accordance with our Privacy Policy.

    We may update or replace these User Terms by posting an updated version to our website. Your continued use of the Services will serve as your acknowledgment and acceptance of any changes.

    YOU AGREE TO RESOLVE DISPUTES THROUGH BINDING ARBITRATION IN THE MANNER SET FORTH UNDER THE PLATFORM AGREEMENT. PLEASE READ THAT CAREFULLY AND ONLY USE THE SERVICES IF YOU UNDERSTAND AND AGREE TO THE PROVISION.

    Access and Use of the Services

    Eligibility

    By accessing or using the Services, you represent and warrant that you have the full right, power, and authority to enter into and comply with these Terms and international laws and regulations; your use of the Services will not violate any applicable law or regulation; and you will only use the Services for lawful purposes and in accordance with these Terms.

    Prohibited Uses

    In connection with your use of the Services, you will not:

    • copy, distribute, or disclose any part of the Services in any medium, including by any automated or non-automated "scraping";
    • use any automated system, including "robots," "spiders," or "offline readers," to access the Services in a manner that sends more requests than a human can reasonably produce; (except that Hollis & Co grants public search engines revocable permission to use spiders to copy materials from hollisand.co solely to create publicly available searchable indices, but not caches or archives);
    • transmit spam, chain letters, or other unsolicited email;
    • attempt to interfere with, compromise the system integrity or security or decipher any transmissions to or from the servers running the Services;
    • take any action that imposes an unreasonable or disproportionately large load on our infrastructure;
    • upload invalid data, viruses, worms, or other software agents through the Services;
    • collect or harvest any personally identifiable information, including account names, from the Services;
    • use the Services for any commercial solicitation purposes;
    • impersonate another person or otherwise misrepresent your affiliation with a person or entity, conduct fraud, or hide your identity;
    • interfere with the proper working of the Services;
    • bypass the measures we may use to prevent or restrict access to the Services;
    • use our Services in a way that could damage our reputation or could be interpreted as slander or libel;
    • use our Services to perform or promote illegal activities of any kind;
    • use our Services in connection with any transaction involving illegal products or services; or
    • use our Services in any manner prohibited by applicable law.

    Ownership of Hollis & Co Property, Feedback

    The Services and all materials therein or transferred thereby, including software, images, text, graphics, illustrations, logos, patents, trademarks, service marks, copyrights, photographs, audio, videos, music, and User Content (the "Hollis & Co Property"), and all Intellectual Property Rights related thereto, are the exclusive property of Hollis & Co and its licensors. You agree not to sell, license, rent, modify, distribute, copy, reproduce, transmit, publicly display, publicly perform, publish, adapt, edit or create derivative works from any Hollis & Co Property.

    By submitting any Feedback, you agree that your disclosure is gratuitous, unsolicited and without restriction and will not place Hollis & Co under any fiduciary or other obligation, and that we are free to use the Feedback without any additional compensation to you.

    Content

    Definition of Content

    "User Content" means any and all information and content that a user submits to the Services. "Content" means User Content and other content or information of any type that appears or is accessible through the Services.

    Responsibility for Content

    You are solely responsible for your User Content. You assume all risks associated with use of your User Content. Hollis & Co is not obligated to backup any User Content and User Content may be deleted at any time.

    You hereby grant to Hollis & Co an irrevocable, nonexclusive, royalty-free and fully paid, worldwide license to reproduce, distribute, publicly display and perform, prepare derivative works of, incorporate into other works, and otherwise use and exploit your User Content, solely for the purposes of including your User Content in the Services.

    Acceptable Use Policy

    You agree not to use the Services to collect, upload, transmit, display, or distribute any User Content that:

    • violates any third-party right or any intellectual property or proprietary right;
    • is unlawful, harassing, abusive, tortious, threatening, harmful, invasive of another's privacy, vulgar, defamatory, false, intentionally misleading, pornographic, obscene, or promotes racism, bigotry, hatred, or physical harm of any kind;
    • is harmful to minors in any way; or
    • is in violation of any law, regulation, or obligations or restrictions imposed by any third party.

    Copyright Complaints

    Hollis & Co respects the intellectual property of others. If you believe that one of our users is unlawfully infringing the copyright(s) in a work, please provide written notification pursuant to 17 U.S.C. § 512(c) to our designated Copyright Agent at legal@hollisand.co. Pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact in a written notification subjects the complaining party to liability for damages, costs, and attorney's fees.

    Limitation of Liability

    TO THE FULLEST EXTENT ALLOWED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY SHALL HOLLIS & CO., INC. BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR (A) ANY INDIRECT, SPECIAL, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES OF ANY KIND, INCLUDING DAMAGES FOR LOST PROFITS, BUSINESS INTERRUPTION, LOSS OF DATA, OR LOSS OF GOODWILL, (B) ANY AMOUNT IN EXCESS OF THE GREATER OF (I) $100 OR (II) THE AMOUNTS PAID BY YOU TO HOLLIS & CO., INC. IN THE SIX (6) MONTH PERIOD PRECEDING THE APPLICABLE CLAIM, OR (C) ANY MATTER BEYOND OUR REASONABLE CONTROL.

    Suspension and Termination

    Hollis & Co., Inc. may suspend or terminate your account at any time and for any reason. Upon termination, we may retain data as required by law and for legitimate business purposes.


    Section 2

    Prohibited and Restricted Activities

    The following activities are prohibited when using Hollis & Co Services. You agree not to engage in any of the following:

    Illegal Activities

    • Money laundering, terrorist financing, or other illegal financial activities
    • Fraud, scams, or deceptive practices
    • Tax evasion
    • Operating unlicensed money transmission businesses

    Restricted Business Types

    • Adult content or pornography businesses
    • Cannabis and marijuana-related businesses (even where locally legal)
    • Gambling, gaming, or lottery businesses
    • Weapons, firearms, or ammunition businesses
    • Pharmaceuticals without appropriate licensing
    • Multi-level marketing or pyramid schemes

    Prohibited Transactions

    • Transactions that violate OFAC sanctions
    • Transactions involving prohibited, sanctioned, or restricted countries or entities
    • Shell company transactions intended to obscure beneficial ownership
    • International wires to OFAC-designated individuals, entities, or jurisdictions

    KYB Verification

    Hollis & Co conducts Know Your Business (KYB) verification on all business account applicants in accordance with U.S. banking regulations and Column N.A.'s program requirements. We may request formation documents, proof of address, beneficial ownership attestations, and government-issued identification before an account can be opened.

    International Wire Compliance

    International wire transfers are subject to applicable laws and regulations, including OFAC screening. Transfers to certain countries may be restricted or prohibited. Column N.A. and Hollis & Co independently screen all counterparties against OFAC and applicable sanctions lists prior to processing.


    Section 3

    Platform Agreement

    This Platform Agreement ("Agreement") is entered into by and between Hollis & Co., Inc. ("Hollis & Co," "we," "us," or "our"), a Delaware C-Corporation (EIN: 42-1944327, File No. 10581092), operating under the trade name Hollis & Co, and the entity or person ("you" or "Company") that registers for and/or uses the Services.

    3.1 Definitions

    "Authorized User" means any individual authorized by Company to access and use the Services on Company's behalf.

    "Company Data" means all data, information, and content submitted by Company or its Authorized Users through the Services.

    "Documentation" means Hollis & Co's user guides, help articles, and other materials made available to Company.

    "Intellectual Property Rights" means all patent rights, copyright rights, mask work rights, moral rights, rights of publicity, trademark, trade dress and service mark rights, goodwill, trade secret rights and other intellectual property rights.

    "Services" means Hollis & Co's financial technology platform, including all features, functionality, and applications made available to Company.

    3.2 Services

    Subject to the terms and conditions of this Agreement, Hollis & Co will provide Company with access to the Services. Hollis & Co reserves the right to modify, suspend, or discontinue any aspect of the Services at any time.

    3.3 Eligibility

    To be eligible to use the Services, Company must:

    • be a legally formed business entity;
    • have a valid Employer Identification Number (EIN) or equivalent tax identification number;
    • have a legitimate business purpose;
    • not be engaged in any Prohibited and Restricted Activities; and
    • comply with all applicable laws and regulations.

    3.4 Account Registration

    To register for an account, Company must provide accurate and complete information, including legal business name, business address, EIN or equivalent, information about beneficial owners and control persons, and bank account information. Company is responsible for maintaining the confidentiality of its account credentials.

    3.5 Fees

    Hollis & Co may charge fees for certain Services. All fees are set forth in the applicable order form or service schedule. Hollis & Co reserves the right to change its fees upon notice to Company.

    3.6 Confidentiality

    Each party agrees to keep confidential all non-public information disclosed by the other party that is designated as confidential or that reasonably should be understood to be confidential given the nature of the information and circumstances of disclosure.

    3.7 Intellectual Property

    Hollis & Co., Inc. retains all right, title, and interest in and to the Services, including all Intellectual Property Rights therein. Company retains all right, title, and interest in and to Company Data. Company hereby grants Hollis & Co a limited, non-exclusive license to use Company Data solely to provide the Services.

    3.8 Representations and Warranties

    Company represents and warrants that it has the legal authority to enter into this Agreement; all information provided to Hollis & Co is accurate and complete; it will comply with all applicable laws and regulations; and it will not use the Services for any Prohibited and Restricted Activities.

    3.9 Indemnification

    Company agrees to indemnify, defend, and hold harmless Hollis & Co., Inc. and its officers, directors, employees, and agents from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys' fees) arising out of or relating to Company's use of the Services, violation of this Agreement, or violation of any applicable law or regulation.

    3.10 Limitation of Liability

    TO THE FULLEST EXTENT PERMITTED BY LAW, IN NO EVENT WILL HOLLIS & CO., INC. BE LIABLE TO COMPANY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS OR REVENUES, WHETHER INCURRED DIRECTLY OR INDIRECTLY, OR ANY LOSS OF DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES. IN NO EVENT WILL HOLLIS & CO., INC.'S AGGREGATE LIABILITY FOR ALL CLAIMS EXCEED THE GREATER OF $100 OR THE AMOUNT PAID BY COMPANY TO HOLLIS & CO., INC. IN THE TWELVE MONTHS PRECEDING THE CLAIM.

    3.11 Dispute Resolution

    Arbitration Agreement

    PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS.

    Any dispute, controversy, or claim arising out of or relating to this Agreement shall be finally resolved by binding arbitration administered by the American Arbitration Association ("AAA") under its Commercial Arbitration Rules. The arbitration shall take place in Wilmington, Delaware. The arbitration shall be confidential. Judgment upon the award rendered by the arbitrator may be entered in any court having jurisdiction.

    Class Action Waiver

    YOU AND HOLLIS & CO., INC. AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE ACTION.

    3.12 Governing Law

    This Agreement shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of laws provisions.

    3.13 General Provisions

    Entire Agreement. This Agreement constitutes the entire agreement between the parties and supersedes all prior agreements, representations, warranties, and understandings.

    Amendment. Hollis & Co may amend this Agreement at any time by posting the amended terms on its website. Continued use constitutes acceptance.

    Severability. If any provision of this Agreement is held to be unenforceable, it shall be modified to the minimum extent necessary, and the remaining provisions shall continue in full force and effect.

    Assignment. Company may not assign this Agreement without Hollis & Co's prior written consent. Hollis & Co., Inc. may assign this Agreement without restriction.

    Notices. All notices shall be sent to legal@hollisand.co or 5831 Forward Avenue, Unit 801, Pittsburgh, PA 15217.


    Section 4

    Data Processing Addendum

    This Data Processing Addendum ("DPA") is incorporated into and forms part of the Platform Agreement between Hollis & Co., Inc. and Company.

    Definitions

    "Controller" means the entity that determines the purposes and means of processing Personal Data.

    "Data Subject" means an identified or identifiable natural person whose Personal Data is processed.

    "Personal Data" means any information relating to an identified or identifiable natural person.

    "Processing" means any operation performed on Personal Data, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, combination, restriction, erasure, or destruction.

    "Processor" means the entity that processes Personal Data on behalf of the Controller.

    "Sub-processor" means any processor engaged by Hollis & Co., Inc. to process Personal Data on behalf of Company.

    Scope and Roles

    Company is the Controller of Personal Data. Hollis & Co., Inc. is the Processor of Personal Data and processes Personal Data on behalf of Company solely for the purposes set forth in the Agreement.

    Hollis & Co's Obligations

    Hollis & Co., Inc. shall:

    • process Personal Data only on documented instructions from Company;
    • ensure that persons authorized to process Personal Data have committed themselves to confidentiality;
    • implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk;
    • assist Company in complying with its obligations under applicable data protection laws;
    • delete or return all Personal Data to Company after the end of the provision of services; and
    • allow for and contribute to audits and inspections conducted by Company or a mandated auditor.

    Sub-processors

    Company provides general authorization for Hollis & Co., Inc. to engage sub-processors, subject to: maintaining a list of sub-processors available to Company upon request; imposing equivalent data protection obligations on sub-processors; and Hollis & Co., Inc. remaining liable for sub-processor performance.

    Security

    Hollis & Co., Inc. shall implement appropriate technical and organizational measures to protect Personal Data, including encryption, ongoing confidentiality and integrity of processing systems, ability to restore availability in the event of an incident, and regular testing of technical and organizational measures.

    Personal Data Breaches

    Hollis & Co., Inc. shall notify Company without undue delay after becoming aware of a Personal Data breach, including the nature of the breach, categories and approximate number of data subjects and records concerned, likely consequences, and measures taken to address the breach.

    Data Transfers

    Hollis & Co., Inc. shall not transfer Personal Data to a third country or international organization unless the transfer is to a country providing adequate protection, is subject to appropriate safeguards, or is necessary for one of the exceptions listed in applicable data protection law.


    Section 5

    Privacy Policy

    Last Updated: April 2026

    This Privacy Policy describes how Hollis & Co., Inc. ("Hollis & Co," "we," "us," or "our") collects, uses, and shares information about you when you use our Services. For privacy inquiries, contact privacy@hollisand.co.

    Information We Collect

    Information You Provide to Us

    • account registration information (name, email address, password, company name, and other business information);
    • financial information (bank account information, transaction history, and financial statements);
    • identity verification information (government-issued ID, EIN, and date of birth);
    • communications you send to us; and
    • any other information you choose to provide.

    Information We Collect Automatically

    • log data (IP address, browser type, operating system, referring URLs, device identifiers, and cookie data);
    • usage data (features you use, actions you take, time, frequency, and duration of your activities);
    • location data (general location inferred from your IP address); and
    • transaction data (details of transactions you initiate through our Services).

    Information from Third Parties

    We may collect information from identity verification providers, credit bureaus, financial institutions, and publicly available sources.

    How We Use Your Information

    • provide, maintain, and improve our Services;
    • process transactions and send related information;
    • send technical notices, updates, security alerts, and support messages;
    • monitor and analyze trends and usage;
    • detect, investigate, and prevent fraudulent transactions and other illegal activities; and
    • comply with legal obligations.

    How We Share Your Information

    We may share your information with service providers who perform services on our behalf, financial institutions and payment networks, identity verification providers, regulatory and law enforcement authorities as required by law, and other parties with your consent.

    We do not sell your personal information to third parties.

    Your Rights and Choices

    Depending on your location, you may have the right to access, correct, delete, or port your personal information, and to object to or restrict its processing. To exercise these rights, contact privacy@hollisand.co.

    Contact

    Hollis & Co., Inc.  ·  privacy@hollisand.co  ·  5831 Forward Avenue, Unit 801, Pittsburgh, PA 15217


    Section 6

    Commercial Deposit Account Agreement

    This Commercial Deposit Account Agreement governs the commercial deposit accounts ("Account") offered through Hollis & Co in partnership with Column N.A., Member FDIC.

    Account Ownership

    Accounts are available to eligible businesses and are subject to verification and approval. By opening an Account, you represent that you are authorized to open and operate the Account on behalf of the business entity.

    Deposits

    You may deposit funds into your Account via ACH transfer, wire transfer, or other approved methods. Hollis & Co., Inc. reserves the right to reject any deposit in its sole discretion.

    FDIC Insurance. USD deposit accounts are provided by Column N.A., Member FDIC. Deposits are eligible for FDIC insurance up to applicable limits. Hollis & Co is a DBA of Hollis & Co., Inc. USD deposit accounts and banking services are provided by Column N.A., Member FDIC.

    Withdrawals and Transfers

    You may withdraw funds from your Account via ACH transfer, wire transfer, or other approved methods, subject to applicable limits and restrictions.

    Account Closure

    Either party may close your Account at any time. Upon closure, any remaining balance will be transferred to a designated account.

    Compliance

    You agree to comply with all applicable laws and regulations in connection with your Account, including anti-money laundering (AML) and know-your-customer (KYC) requirements.


    Section 7

    Electronic Communications Agreement (E-Sign)

    This Electronic Communications Agreement ("E-Sign Agreement") governs the use of electronic communications between you and Hollis & Co., Inc. and Column N.A. in connection with your account and services. By applying for or using the Services, you consent to receive all disclosures, agreements, notices, statements, and other communications ("Communications") electronically, as permitted by the federal Electronic Signatures in Global and National Commerce Act ("E-Sign Act"), 15 U.S.C. § 7001 et seq.

    Scope of Electronic Communications

    Your consent to receive Communications electronically applies to all interactions with Hollis & Co and Column N.A., including:

    • This Agreement and any amendments
    • Account statements, transaction confirmations, and receipts
    • Notices of changes to terms, fees, or services
    • Privacy notices and compliance disclosures
    • Tax forms (including IRS Form 1099-INT) and year-end statements
    • Any other information required to be provided to you in writing

    Hardware and Software Requirements

    To receive electronic Communications, you must have: a device with internet access; a current browser (Chrome, Safari, Firefox, or Edge — recent version); a valid email address; and the ability to open PDF documents. Hollis & Co will notify you of any material changes to these requirements.

    Withdrawing Consent

    You may withdraw your consent to receive electronic Communications at any time by contacting us at legal@hollisand.co. Withdrawal of consent will not affect the validity of any electronic Communications previously sent. Please note that withdrawing consent may result in termination of your access to the Services, as electronic delivery is a condition of account operation.

    Updating Your Contact Information

    You are responsible for maintaining a current and accurate email address on file. Contact us immediately at legal@hollisand.co if your email address changes. Hollis & Co is not responsible for your failure to receive Communications due to an outdated or invalid email address.

    Retention of Records

    We recommend that you print or save a copy of all electronic Communications for your records. You may request a paper copy of any Communication by contacting us at legal@hollisand.co. A fee may apply for paper copies.


    Contact & Legal Notices

    All legal correspondence should be directed to:

    Hollis & Co., Inc.

    DBA: Hollis & Co

    5831 Forward Avenue, Unit 801

    Pittsburgh, PA 15217

    EIN: 42-1944327

    Delaware C-Corp · File No. 10581092

    Banking services provided by Column N.A., Member FDIC. Hollis & Co is a DBA of Hollis & Co., Inc. USD deposit accounts are not insured by Hollis & Co., Inc. FDIC insurance applies through Column N.A. up to applicable limits.