Privacy and Terms

Effective Date: May 27, 2026 | Last Updated: May 27, 2026

Privacy Policy

Applicable to clientpaydirect.com, tailfinpay.com, and the consumer claim/payout portal

Summary. KuliPay Inc operates a platform that helps businesses send payments to consumers (such as refunds, rebates, and claim payouts). To deliver your payment, we collect limited personal and financial information. We do not sell your personal information, and we do not share it with anyone for cross-context behavioral advertising. This Policy explains what we collect, how we use and protect it, and the choices and rights you have, including rights under U.S. state privacy laws and the federal Gramm-Leach-Bliley Act (GLBA).

1. Who We Are

This Privacy Policy (“Policy”) is issued by KuliPay Inc, a Delaware corporation, doing business as “Client Pay Direct” and “TailFin” (“KuliPay,” “we,” “us,” or “our”). It applies to the websites at clientpaydirect.com and tailfinpay.com, the consumer claim and payout portal (including claim.clientpaydirect.com), and related services we provide (collectively, the “Services”).

We provide an outbound-payments and disbursement platform. Businesses (“Clients”) engage us to deliver payments to their customers, patients, members, or other payees (“you” or “Recipients”). In delivering those payments we act both on our own behalf and, for certain processing, as a service provider/processor at the direction of our Clients.

2. Scope; Notice at Collection

This Policy covers personal information we collect from Recipients, website visitors, business contacts, and individuals communicating with us. Where we process information solely on behalf of a Client as a service provider/processor, the Client’s own privacy notice also governs that information, and you may need to contact the Client to exercise certain rights. This Policy does not cover third-party sites, payment networks, or apps (for example, Zelle®, PayPal, Venmo, or your bank), which are governed by their own privacy notices.

Notice at Collection (California and similar laws). At or before we collect personal information from you, we collect the categories described in Section 3 for the purposes described in Section 4. We do not “sell” or “share” personal information as those terms are defined under the California Consumer Privacy Act/California Privacy Rights Act (CCPA/CPRA) or analogous state laws. We retain information for the periods described in Section 11.

3. Information We Collect

The categories of personal information we collect depend on how you interact with the Services:

• Identifiers and contact data: name, postal address, email address, telephone number, and the unique claim code we issue.
• Financial account information: bank account number and routing number, debit-card information, and identifiers for third-party payment methods (for example, a PayPal or Venmo handle, or the email/mobile number used for Zelle®), as needed to deliver your payment.
• Transaction information: the amount, type, status, and history of payments to you, and the Payout Method you select.
• Identity-verification and fraud-prevention data: information used to confirm your identity and the validity of your claim or account, including address-verification, account-validation, and risk/device signals.
• Communications content: messages, support tickets, and call recordings or transcripts (where lawful and disclosed) when you interact with us.
• Information from our Clients: the payment file and contact details a Client provides so we can reach you and deliver the funds owed.
• Information collected automatically: IP address, device and browser type, operating system, pages viewed, referring URLs, and similar usage data collected through cookies and similar technologies, including security tools such as Google reCAPTCHA.
• Information from third parties: address, identity, and account-verification data and risk signals from service providers, financial institutions, and data vendors that help us deliver payments accurately and prevent fraud.

We do not knowingly request government-issued identification numbers, biometric data, precise geolocation, or other sensitive categories, and you should not send us sensitive information we have not requested. If we ever ask for any sensitive data (for example, a partial Social Security number to satisfy tax-reporting), we use it only for the purpose disclosed.

4. How We Use Information

We use personal information to:

• deliver, process, and confirm payments to you, and let you choose and receive your payout;
• verify your identity and the validity of your claim, and prevent, detect, and investigate fraud, error, and unauthorized activity;
• communicate with you about your payment, respond to inquiries, and provide support;
• perform services for our Clients, including reporting, reconciliation, and unclaimed-property/escheatment compliance;
• operate, secure, maintain, test, and improve the Services and develop new features;
• comply with legal, regulatory, tax (including IRS Form 1099 reporting where applicable), audit, and law-enforcement obligations; and
• establish, exercise, or defend legal claims.

We will not use your information for materially different purposes than those described here without providing notice and, where required, obtaining your consent.

5. Federal Financial-Privacy Notice (GLBA)

Because we handle financial account information to deliver payments, certain information we collect is “nonpublic personal information” under the Gramm-Leach-Bliley Act (GLBA). The following short-form notice summarizes our financial-privacy practices:

KuliPay GLBA Financial-Privacy Notice (Summary). • Why? Financial companies choose how they share your personal information. Federal law gives you the right to limit some — but not all — sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully. • What we collect: identifiers, contact information, account/routing numbers (or third-party payment-method identifiers), transaction data, and information from our Clients to deliver your payment. • How we share: only as needed to process and service your transaction, with the financial institutions and payment networks that execute your payment, with the Client whose payment you are receiving, with service providers who perform services for us, and as required or permitted by law. • Sharing you can limit: we do not share your nonpublic personal information with nonaffiliated third parties for their own marketing, and we do not sell it. Because our sharing falls within GLBA’s permitted-purpose exceptions, there is no separate GLBA opt-out for that sharing. • How we protect: we maintain administrative, technical, and physical safeguards consistent with the GLBA Safeguards Rule (see Section 12).

6. Health Information / HIPAA

KuliPay is generally not a “covered entity” under the federal Health Insurance Portability and Accountability Act (HIPAA). Where a healthcare-related Client engages KuliPay to deliver patient refunds or similar payments and the engagement involves “protected health information” (PHI) as defined by HIPAA, KuliPay acts as the Client’s “business associate” and processes PHI only as permitted by, and subject to, a business associate agreement (BAA) with the Client. We do not use PHI for our own marketing.

7. How We Share Information

We disclose personal information in the following circumstances:

• Payment execution: to banks, ACH operators/originators, card networks, and third-party payment providers (for example, Zelle®, PayPal, Venmo, gift-card issuers) to deliver your chosen payout.
• Our Clients: to the business that owes you the payment, for reconciliation, reporting, and compliance.
• Service providers: to vendors that perform services for us — hosting, identity and account verification, fraud prevention, customer support, analytics, and communications — under contracts that limit their use of the information.
• Affiliates: with current and future entities under common ownership or control with KuliPay, for purposes consistent with this Policy.
• Legal and compliance: to government authorities, regulators, or others when required by law, subpoena, or legal process; to enforce our agreements; to protect rights, safety, and the integrity of the Services; and to satisfy escheatment/unclaimed-property obligations.
• Business transfers: in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this Policy.
• With your direction or consent: to anyone you direct us to share with, or with your separate consent.

No sale or sharing for cross-context advertising. We have not sold, and do not sell, personal information, and we do not “share” personal information for cross-context behavioral advertising, in each case as those terms are defined under California and other state privacy laws.

8. Cookies, Analytics & Tracking

We and our service providers use cookies and similar technologies to operate the Services, remember your preferences, measure usage, and protect against fraud and abuse. Our sites use security tooling such as Google reCAPTCHA, which is subject to Google’s Privacy Policy and Terms of Service. You can control cookies through your browser settings; disabling some cookies may affect how the Services function. For more detail, see our Cookie Notice.

Do Not Track. Because there is no common industry standard for “Do Not Track” signals, our Services do not currently respond to them. We do not use the personal information collected on our Services for cross-context behavioral advertising.

9. Mobile, Email & SMS Communications

If you provide a mobile number or email address, we and our service providers may use it to send you transactional messages about your payment (for example, to deliver a claim link, request information needed to complete a payout, or send a confirmation). Message and data rates may apply, and message frequency varies based on your transaction. You can reply STOP to opt out of SMS and HELP for help. Opting out may prevent us from communicating with you in the manner needed to deliver your payment.

Telephone calls. We may call you about your payment. Calls may be recorded or monitored for training, quality assurance, security, and compliance, where lawful and as disclosed at the time of the call.

10. Automated Decision-Making & Profiling

We use automated tools (including risk- and fraud-detection systems and identity- and account-verification services) to help process payments, prevent fraud, and protect against unauthorized activity. These tools may, for example, flag a transaction for additional review or decline an attempted payout. We do not use these tools to make decisions that produce legal or similarly significant effects about you without meaningful human involvement, and where required by law you may request a review of automated decisions affecting you.

11. Data Retention

We retain personal information only as long as necessary to provide the Services, deliver and document your payment, comply with legal, tax, escheatment, accounting, and audit obligations, resolve disputes, prevent fraud, and enforce our agreements. When information is no longer needed, we delete or de-identify it. Retention periods vary by category — for example, transaction and tax-related records are typically retained for the period required by law (commonly 7 years).

12. How We Protect Information

We maintain a written information security program with administrative, technical, and physical safeguards designed to protect personal and financial information against unauthorized access, use, alteration, and disclosure, consistent with the GLBA Safeguards Rule and applicable state law. These safeguards include access controls, encryption in transit, monitoring, employee training, vendor due diligence, and incident response. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Data Breach Notification

If a security incident affects your personal information in a way that triggers a notification requirement under applicable law, we will notify you and applicable regulators in the time and manner required. We may also notify you of incidents that do not trigger legal notice where doing so is appropriate to help you protect yourself.

14. Your Privacy Rights

14.1 All U.S. Residents

Subject to applicable law and verification, you may request to access, correct, or delete personal information we hold about you; obtain a portable copy; and opt out of any sale or sharing of your personal information (we do not engage in either). We will not discriminate against you for exercising your rights.

14.2 California (CCPA/CPRA)

California residents have the rights described in Section 14.1, plus the right to: (i) know the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients; (ii) opt out of the “sale” or “sharing” of personal information; and (iii) limit the use of sensitive personal information to the purposes permitted by law (we do not use sensitive personal information for purposes that would trigger this right). We do not knowingly sell or share the personal information of consumers under 16. Under California’s “Shine the Light” law, you may request information about disclosures of personal information to third parties for their direct-marketing purposes; we do not make such disclosures.

14.3 Other State Privacy Laws

Residents of states with comprehensive privacy laws — including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, and others as they take effect — have rights to access, correct, delete, and obtain a portable copy of their personal information and to opt out of targeted advertising, sale, and certain profiling. Where required by your state, you may appeal a denial of a request by replying to our response or contacting us at the address in Section 21; if your appeal is denied, you may contact your state attorney general.

14.4 How to Exercise Your Rights

Submit a request by emailing privacy@clientpaydirect.com or by writing to the address in Section 21. We will verify your identity (typically by confirming information that matches our records, or via a verified account) before responding, and will respond within the time required by applicable law. You may use an authorized agent to submit a request on your behalf, subject to verification of the agent’s authority. If we processed your information solely as a service provider/processor for a Client, we may forward your request to that Client and direct you to them to fulfill it.

15. Children’s Privacy

The Services are intended for adults and are not directed to children. We do not knowingly collect personal information from children under 13 in violation of the federal Children’s Online Privacy Protection Act (COPPA), or from minors in violation of applicable state law. If you believe a child has provided us personal information, contact us and we will take appropriate steps to delete it.

16. U.S.-Only Services

The Services are intended for users located in the United States. We do not offer the Services to, or knowingly collect information from, individuals outside the United States, and information we collect is processed in the United States.

17. Third-Party Sites and Services

The Services may link to or interoperate with third-party sites and services (for example, your bank, a wallet, or a payment network). We are not responsible for the practices of those third parties, and this Policy does not apply to them. Review their privacy notices before using them.

18. Communications with Us

If you contact us by email or another channel, we will use the information you provide to respond. Please do not include sensitive information (for example, account numbers or government identifiers) in unencrypted email.

19. Job Applicants and Business Contacts

If you apply for employment with us or interact with us as an employee, agent, or representative of a Client or vendor, we will use the information you provide for recruiting, contract performance, business communications, and related compliance purposes, consistent with this Policy.

20. Changes to This Policy

We may update this Policy from time to time. We will post the revised Policy with a new “Last Updated” date and, where required by law, provide additional notice. Your continued use of the Services after an update takes effect constitutes acceptance of the revised Policy.

21. Contact Us

If you have questions about this Policy or our privacy practices, or wish to exercise your rights, contact us at:

TailFin (KuliPay Inc)

12 E 49th Street, Floor 11

New York, NY 10017

Effective Date: May 27, 2026

Terms of Service

Applicable to clientpaydirect.com, tailfinpay.com, and the consumer claim/payout portal

Please read these Terms carefully. They govern your use of KuliPay’s payment-delivery Services and include, in Section 22, a binding arbitration agreement and a waiver of class actions and jury trials, which affect how disputes between you and KuliPay are resolved. You may opt out of arbitration within 30 days as described in Section 22.7. These Terms also shorten the time you have to bring a claim (Section 25).

1. Acceptance of These Terms

These Terms of Service (“Terms”) are a binding agreement between you and KuliPay Inc, a Delaware corporation, doing business as “Client Pay Direct” and/or “Tailfinpay” (“KuliPay,” “we,” “us,” or “our”). They govern your access to and use of our websites, the consumer claim and payout portal, and related services (collectively, the “Services”). By accessing the Services, claiming a payment, or providing payout information, you agree to these Terms, our Privacy Policy, and our Consent to Electronic Records and Payment Authorization, each of which is incorporated by reference. If you do not agree, do not use the Services.

2. Definitions

• “Client” means a business that engages KuliPay to deliver payments to its payees.
• “Recipient” or “you” means an individual to whom a payment is being delivered through the Services.
• “Payout” means a payment delivered to you through the Services.
• “Payout Method” means the method you select to receive a Payout (for example, ACH/direct deposit, Zelle®, PayPal, Venmo, debit, digital check, paper check, or gift card).

3. The Services

KuliPay operates an outbound-payments platform that delivers Payouts to Recipients on behalf of Clients, such as refunds, reimbursements, rebates, and claim payments. We facilitate the delivery of funds; we are not a bank, do not hold deposits, and do not take ownership of the funds. Funds are moved through banks, payment networks, and third-party payment providers. The underlying obligation to pay you arises from your relationship with the Client; KuliPay’s role is to deliver the Payout the Client has authorized.

4. Eligibility

You must be at least 18 years old, a United States resident, and able to form a binding contract under applicable law to use the Services. By using the Services, you represent that you meet these requirements and that all information you provide is true, accurate, and complete.

5. Identity Verification; Account Validation

To protect against fraud and error and to comply with applicable law, we may verify your identity and the validity of your claim using information you provide and information from third-party verification services, financial institutions, and public sources. We may also validate your bank account (for example, through micro-deposit or instant-verification services) before sending a Payout. We may decline, hold, or reverse a Payout, or require additional information, where verification cannot be completed.

6. Sanctions, AML & Fraud Prevention

You represent that you are not subject to U.S. economic or trade sanctions and are not on a list of restricted parties maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) or other applicable authority, and that you will not use the Services in violation of U.S. anti-money-laundering, sanctions, or anti-terrorism laws. We may take any action we believe necessary to comply with those laws, including delaying, blocking, or canceling a Payout and reporting activity to authorities.

7. Claiming and Receiving a Payout

To receive a Payout, you may be asked to verify your claim (for example, using a unique claim code and ZIP code) and to select a Payout Method and provide the information necessary to deliver funds. You are responsible for:

• providing accurate and current payout information, including correct bank-account, card, or payment-app details;
• ensuring you are an owner of, or are authorized to receive funds at, the account or payment method you provide;
• safeguarding the credentials and devices you use to access the Services; and
• promptly notifying us of any error or suspected unauthorized activity relating to your Payout.

If you provide inaccurate information, your Payout may be delayed, returned, or misdirected. Where you authorize delivery by ACH or to a bank account, your authorization is governed by the Payment Authorization presented to you at the time of payment.

8. No Consumer Fees; Third-Party Fees

KuliPay does not charge Recipients a fee to receive a Payout through the Services. Our fees are billed to Clients. A third-party payment provider, bank, or card issuer may impose its own fees or terms (for example, fees associated with certain wallets or accounts); those are outside our control and are governed by your agreement with that provider.

9. Funds Availability; Timing

The time it takes for funds to reach you depends on your bank, the payment network, and any third-party payment provider you select, and is not controlled by KuliPay. We do not guarantee any specific delivery time. Standard ACH transfers typically settle within one to three business days; instant payment options may be available depending on the Client and Payout Method.

10. Electronic Communications and Records

The Services are provided electronically. By using the Services, you consent to receive communications, disclosures, agreements, notices, and records from us electronically, as further described in our Consent to Electronic Records and Signatures (the E-SIGN Consent). You may withdraw that consent or request paper copies as described there; doing so may delay or prevent delivery of your Payout.

11. Mobile, SMS, Email & Call Recording

If you provide a mobile number or email address, we may use it to send transactional messages about your payment (for example, a claim link, request for information needed to complete a Payout, or a confirmation), and we may call you about your payment. By providing a mobile number, you consent to receive autodialed or prerecorded transactional messages or calls from us or our service providers. Message and data rates may apply. You may reply STOP to opt out of SMS and HELP for help; opting out may prevent us from completing your Payout. We do not use the contact information you provide for telemarketing. Calls may be recorded or monitored for training, quality assurance, security, and compliance, where lawful and as disclosed at the time of the call.

12. Authorization to Deliver Funds

When you provide account or payment-method information, you authorize KuliPay and its payment partners to deliver the Payout to that account or method, to share your information with those partners as needed to deliver the Payout, and to make any correcting entry reasonably necessary to address a Payout made in error or returned, as set out in the Payment Authorization. You represent that you are authorized to receive funds at the account or method you provide.

13. Third-Party Payment Methods

Certain Payout Methods are provided by third parties (for example, Zelle®, PayPal, Venmo, and gift-card or digital-check providers). Your use of those methods is subject to the third party’s own terms and privacy policies. KuliPay is not responsible for the acts, omissions, availability, or policies of third-party payment providers or your financial institution.

14. Tax Matters

You are responsible for any taxes that may apply to a Payout. Where required by law, KuliPay or the Client may collect tax-reporting information from you (for example, a Form W-9) and may report a Payout to the U.S. Internal Revenue Service and applicable state tax authorities (for example, on Form 1099). Failure to provide a valid tax form when requested may result in backup withholding or in your Payout being delayed.

15. Unclaimed Property; Escheatment

If a Payout remains unclaimed or otherwise undeliverable after reasonable outreach, the funds may be subject to unclaimed-property/escheatment laws and may be reported and remitted to the appropriate state. You may claim funds from the relevant state-treasury or unclaimed-property office after that point. We will use reasonable efforts to contact you before any funds are escheated.

16. Health Information; HIPAA

Where a healthcare-related Client engages KuliPay to deliver patient refunds or similar payments and the engagement involves “protected health information” (PHI) under the federal Health Insurance Portability and Accountability Act (HIPAA), KuliPay acts as the Client’s business associate and processes PHI only as permitted by, and subject to, a business associate agreement (BAA) with the Client. We do not use PHI for our own marketing.

17. Privacy

Our collection and use of personal information is governed by our Privacy Policy, which is incorporated by reference. By using the Services, you acknowledge our Privacy Policy.

18. Acceptable Use

You agree not to: (a) provide false, misleading, or fraudulent information, or claim a Payout you are not entitled to receive; (b) access an account or claim that is not yours; (c) interfere with or disrupt the Services or attempt to gain unauthorized access; (d) use the Services in violation of any law or third-party rights; (e) use any automated means to access the Services except as we expressly permit; or (f) introduce malware or attempt to probe or test the security of the Services. We may suspend or terminate access for any actual or suspected violation.

19. Intellectual Property; Feedback

The Services, including all software, text, graphics, logos, and the “Client Pay Direct” and “KuliPay” names and marks, are owned by KuliPay or its licensors and are protected by law. We grant you a limited, revocable, non-exclusive, non-transferable license to use the Services solely to claim and receive your Payout. All other rights are reserved.

Feedback. If you provide ideas, suggestions, or other feedback about the Services, you grant KuliPay a perpetual, irrevocable, worldwide, royalty-free, sublicensable license to use the feedback for any purpose without obligation to you.

20. Disclaimers

The Services are provided “as is” and “as available.” To the fullest extent permitted by law, KuliPay disclaims all warranties, express or implied, including merchantability, fitness for a particular purpose, title, and non-infringement, and any warranty that the Services will be uninterrupted, secure, timely, or error-free. KuliPay does not warrant the acts or omissions of Clients, banks, payment networks, or third-party payment providers, or the timing of funds availability, which depend on those parties and your financial institution.

21. Limitation of Liability

To the fullest extent permitted by law, KuliPay and its affiliates, and their respective officers, directors, employees, and agents, will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for lost profits, lost data, or loss of goodwill, arising out of or relating to the Services, whether based in contract, tort, statute, or otherwise, even if advised of the possibility of such damages.

KuliPay’s total aggregate liability arising out of or relating to the Services or these Terms will not exceed the greater of (a) the amount of the specific Payout giving rise to the claim or (b) one hundred U.S. dollars ($100). Some jurisdictions do not allow certain limitations, so some of the above may not apply to you. The limitations in this Section are an essential basis of the bargain between you and KuliPay.

22. Dispute Resolution; Binding Arbitration; Class-Action Waiver

PLEASE READ THIS SECTION CAREFULLY. It requires you and KuliPay to resolve disputes through individual binding arbitration and waives your right to a jury trial and to participate in a class action, except as described below. You may opt out within 30 days under Section 22.7.

22.1 Informal Resolution First

Before starting an arbitration, you agree to first contact us at hello@clientpaydirect.com with a written description of the dispute and your contact information, and to allow 60 days for the parties to attempt a good-faith resolution.

22.2 Agreement to Arbitrate

You and KuliPay agree that any dispute, claim, or controversy arising out of or relating to the Services, these Terms, or our relationship (a “Dispute”) that is not resolved informally will be resolved by binding individual arbitration, rather than in court, except as provided in Section 22.6. This agreement is governed by the Federal Arbitration Act.

22.3 Arbitration Procedure

The arbitration will be administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, as modified by these Terms. The arbitration will be conducted by a single arbitrator. Unless the parties agree otherwise, the seat of arbitration will be in Delaware, and, for claims of $25,000 or less, you may elect to proceed by telephone, video, or written submissions, or in the county of your residence. The arbitrator may award the same individual relief a court could and will follow these Terms as a court would.

22.4 Class-Action and Jury-Trial Waiver

You and KuliPay agree that each may bring claims against the other only in an individual capacity, and not as a plaintiff or class member in any purported class, collective, consolidated, or representative proceeding. The arbitrator may not consolidate more than one person’s claims or preside over any form of representative or class proceeding. You and KuliPay waive any right to a jury trial.

22.5 Costs

Payment of filing, administration, and arbitrator fees will be governed by the AAA rules, except that KuliPay will pay or reimburse those fees to the extent required by the AAA Consumer Arbitration Rules or applicable law. Each party is otherwise responsible for its own attorneys’ fees unless a statute or the arbitrator provides otherwise.

22.6 Exceptions

Either party may (a) bring an individual claim in small-claims court if it qualifies, and (b) seek injunctive or equitable relief in court to protect intellectual property or address unauthorized access. If the class-action waiver in Section 22.4 is found unenforceable as to a particular claim, that claim (and only that claim) will proceed in court.

22.7 Your Right to Opt Out

You may opt out of this arbitration agreement within 30 days after first accepting these Terms by sending written notice to hello@clientpaydirect.com (or the mailing address in Section 32) stating your name and that you opt out of arbitration. Opting out will not affect any other part of these Terms.

22.8 Severability

If any portion of this Section 22 is found unenforceable, the remaining portions will remain in effect, except that if the class-action waiver in Section 22.4 is found unenforceable as to a Dispute seeking public injunctive relief or otherwise, that Dispute will proceed in court and the rest of the arbitration agreement will remain in effect for all other Disputes.

23. Governing Law

These Terms and any Dispute are governed by the laws of the State of Delaware and applicable federal law, without regard to conflict-of-laws rules. Subject to Section 22, the state and federal courts located in Delaware will have exclusive jurisdiction over any matter not subject to arbitration, and you consent to their jurisdiction and venue.

24. Indemnification

You agree to indemnify and hold harmless KuliPay and its affiliates and their respective personnel from any claims, losses, liabilities, and expenses (including reasonable attorneys’ fees) arising out of your breach of these Terms, your misuse of the Services, your violation of law, or your provision of inaccurate or unauthorized payout information.

25. Shortened Limitations Period

To the fullest extent permitted by law, any claim or cause of action arising out of or relating to the Services or these Terms must be filed within one (1) year after such claim or cause of action arose, or it will be permanently barred.

26. Force Majeure

KuliPay will not be liable for any delay or failure to perform resulting from causes outside our reasonable control, including acts of God, war, terrorism, civil unrest, labor disputes, governmental actions, pandemic, fire, flood, power or telecommunications outages, or failures of banks, payment networks, or third-party payment providers.

27. Term, Termination, Suspension & Changes

We may modify, suspend, or discontinue the Services, or update these Terms, at any time. If we make material changes, we will post the updated Terms with a new effective date and, where required, provide additional notice. Your continued use of the Services after changes take effect constitutes acceptance. We may suspend or terminate your access at any time for any actual or suspected violation of these Terms or to comply with law. Sections 12–28 survive termination.

28. Notices

We may provide notices to you electronically (for example, by email to the address you provide, by SMS, or by posting on the Services). Notices to KuliPay must be sent in writing to the address in Section 32 and are effective on receipt.

29. Assignment

You may not assign or transfer these Terms or your rights or obligations under them without our prior written consent; any attempted assignment in violation of this Section is void. We may assign these Terms to an affiliate or successor in interest, in whole or in part, without notice.

30. Miscellaneous

If any provision of these Terms is held unenforceable, the remaining provisions remain in effect. Our failure to enforce a provision is not a waiver. Headings are for convenience and do not affect interpretation. The parties are independent contractors and these Terms do not create any agency, partnership, joint venture, or employment relationship. There are no third-party beneficiaries to these Terms. These Terms, together with the Privacy Policy and the Consent to Electronic Records and Payment Authorization, are the entire agreement between you and KuliPay regarding the Services.

31. Notice to California Users

Under California Civil Code §1789.3, California users are entitled to the following consumer-rights notice: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (800) 952-5210.

32. Contact

KuliPay Inc

Attn: Legal

12 E 49th Street, Floor 11

New York, NY 10017

Effective Date: May 27, 2026

Accessibility Statement

Applicable to clientpaydirect.com, tailfinpay.com, and the consumer claim/payout portal

Our commitment. KuliPay Inc is committed to providing a website and payment experience that is accessible to the broadest possible audience, including people with disabilities. We work toward continuous improvement and welcome feedback.

1. Our Commitment

KuliPay Inc, a Delaware corporation, doing business as “Client Pay Direct” (“KuliPay,” “we,” or “us”), is committed to making clientpaydirect.com, tailfinpay.com, and the consumer claim and payout portal at claim.clientpaydirect.com (collectively, the “Services”) usable by everyone, regardless of ability. We strive to ensure that the Services comply with applicable accessibility laws, including Title III of the Americans with Disabilities Act (ADA) and analogous state and local laws, and to align with widely accepted accessibility standards.

2. Standards

We aim to align the Services with the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA, published by the World Wide Web Consortium (W3C). WCAG defines requirements for designers and developers to improve accessibility for people with disabilities. WCAG’s four principles are that content should be perceivable, operable, understandable, and robust.

3. Measures We Take

• We consider accessibility throughout design and development, and during ongoing maintenance.
• We use semantic markup, descriptive alternative text for meaningful images, sufficient color contrast, keyboard navigability, and clear form labels.
• We test the Services with assistive technologies and conduct periodic accessibility reviews.
• We train relevant personnel on accessibility and include accessibility considerations in our vendor selection.
• We monitor the Services and aim to remediate issues we identify or that are reported to us.

4. Known Limitations

Despite our efforts, parts of the Services may not yet be fully accessible. Some limitations may be caused by third-party content or tools (for example, third-party payment provider portals or embedded videos), which are outside our direct control. If you encounter content that is not accessible to you, please tell us using the contact details below.

5. Help and Alternative Formats

If you need help using the Services because of a disability — for example, to claim a payment, choose a payout method, or understand a disclosure — contact us using the details below and we will provide reasonable assistance, including, where appropriate, alternative formats or an alternative way to receive your payment.

6. Feedback and Reporting Issues

We welcome feedback on the accessibility of the Services. If you experience an accessibility barrier or have a suggestion, please contact us and provide the URL or page, a description of the issue, the assistive technology you use (if any), and your contact information so we can follow up. We aim to acknowledge accessibility reports within five (5) business days and address them as promptly as reasonably possible.

7. Formal Complaints

If you would like to make a formal accessibility complaint, contact us at the address below. We will review and respond consistent with applicable law.

8. Contact Us

KuliPay Inc

Attn: Accessibility

12 E 49th Street, Floor 11

New York, NY 10017

Effective Date: May 27, 2026

Cookie Notice

Applicable to clientpaydirect.com, tailfinpay.com, and the consumer claim/payout portal

Quick read. KuliPay uses cookies and similar technologies to make our sites work, keep them secure, and understand how they are used. We do not use cookies to deliver advertising, and we do not sell or share your information for cross-context behavioral advertising.

1. About This Notice

This Cookie Notice explains how KuliPay Inc (a Delaware corporation, doing business as “Client Pay Direct” — “KuliPay,” “we,” or “us”) uses cookies and similar technologies on clientpaydirect.com, tailfinpay.com, and the consumer claim and payout portal at claim.clientpaydirect.com (collectively, the “Services”). It supplements our Privacy Policy.

2. What Cookies Are

Cookies are small text files placed on your device by the websites you visit. They are widely used to make websites work and to provide reporting information to site operators. We also use related technologies such as web beacons, local storage, and software development kits (collectively, “Cookies”). Cookies may be “first-party” (set by us) or “third-party” (set by our service providers); they may last only for your current browser session (“session cookies”) or persist between sessions (“persistent cookies”).

3. Categories of Cookies We Use

• Strictly Necessary. Required to operate the Services and provide features you have requested — for example, maintaining a secure session, balancing load across servers, and remembering that you have accepted notices. The Services will not function properly without these.
• Security and Fraud Prevention. Help us detect and prevent fraud, abuse, and unauthorized access — for example, the Cookies set by Google reCAPTCHA when you interact with our forms. reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service.
• Remember choices you make (such as the language or device used) to improve your experience.
• Performance and Analytics. Collect aggregated information about how visitors use the Services (for example, which pages are visited most often), helping us improve the Services. We configure analytics to limit identifiability and to disable advertising features.

We do not use cookies for cross-context behavioral advertising or third-party advertising.

4. Third-Party Tools We Use

Subject to change as our vendors evolve, the third-party tools we currently use on the Services include security tooling provided by Google (reCAPTCHA), web-analytics tooling, and content-delivery and hosting providers. Where you submit a form, the third-party security tool may receive technical information about your device and interaction. You can learn more in each provider’s privacy notice.

5. Your Choices

5.1 Browser Controls

Most browsers allow you to view, manage, delete, and block cookies through their settings. Restricting cookies may impact your experience or prevent certain Services from functioning, particularly strictly necessary and security cookies.

5.2 Do Not Track and Opt-Out Preference Signals

Because there is no common industry standard for “Do Not Track,” the Services do not currently respond to it. We honor recognized opt-out preference signals where required by applicable law for the limited categories of activity those signals address; we do not use the Services for the sale, sharing, or targeted-advertising activities to which those signals primarily apply.

5.3 SMS Messages

Where we communicate with you by SMS about your payment, you can reply STOP to opt out and HELP for help. SMS opt-outs do not affect the Cookies used on the Services.

6. Updates to This Notice

We may update this Notice from time to time to reflect changes in the Cookies we use or in applicable law. We will post the updated Notice with a new effective date.

7. Contact Us

Questions about this Notice can be sent to:

KuliPay Inc

Attn: Privacy

12 E 49th Street, Floor 11

New York, NY 10017