Status: MVP / BETA DRAFT — For internal and legal review only . Not final. Effective Date: October 1, 2026 Last Updated:

September 18, 2026 FriskOL Co., a Delaware corporation (“FriskOL,” “we,” “us,” or “our”), has developed an AI-powered, inclusive K–12 learning platform, including an AI learning companion (“PhyLO”) and connected Student, Guardian, Teacher , and Tutor experiences (the

“Services”).
 

PLEASE READ THESE TERMS OF SERVICE (“T erms”) AND OUR PRIVACY POLICY CAREFULLY BEFORE USING THE SERVICES. BY

CREATING AN ACCOUNT , PROVIDING PARENTAL CONSENT FOR A CHILD’S ACCOUNT , OR OTHERWISE USING THE SERVICES, YOU

ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE LEGALLY BOUND BY THESE TERMS AND OUR

PRIVACY POLICY , WHICH IS INCORPORATED BY REFERENCE. IF YOU DO NOT AGREE, YOU MAY NOT ACCESS OR USE THE

SERVICES.

FriskOL is currently in MVP / beta release. Features, availability, and functionality are still being tested and may change, be added, or

be removed at any time, as described in Section 2. The Services are intended for users located in the United States and

are designed to operate under United States law . FriskOL makes no representation that the Services are appropriate or lawful for use in

other jurisdictions.

1. Who May Enter These Terms (“ Account Holder”)

Because many FriskOL learners are children, these Terms distinguish between the learner who uses the Services and the Account Holder

who legally accepts these Terms: For a learner under 13: the Account Holder is the learner’s

parent or legal guardian, who creates the account, provides

verifiable parental consent through Kids Web Services (“KWS,” www .kidswebservices.com) as described in our Privacy Policy , and

accepts these Terms on the household’s behalf. The parent/guardian is responsible for the account and for supervising

the child’s use of the Services. For a learner between 13 and 17: the learner may create their own account and act as the Account Holder for Free Tier use, consistent with the age threshold used throughout this Policy . To subscribe to the Paid Tier, a parent or legal guardian must be the Account Holder for that subscription, since a minor’s payment and subscription commitments are not reliably enforceable in the same way as an adult’s. For an individual user 18 or older (including educators and tutors using FriskOL independently , not on behalf of an institution) that individual is the Account Holder and accepts these Terms directly .References to “you” in these Terms mean the Account Holder , except where a provision expressly concerns the learner’s use of the Services. Children under 13 may only use FriskOL after a parent/guardian has completed KWS age verification and provided verifiable parental consent. See our Privacy Policy , and KWS’s own site at www .kidswebservices.com, for details on the consent process, parental rights, and how to review , correct, or delete a child’s

information.
 

2. MVP / Beta Status of the Services

FriskOL is in active development. By using the Services during this phase, you acknowledge and agree that: Features, content, and functionality may be added, changed, limited, or removed at any time, with or without notice; The Services may experience downtime, bugs, or interruptions; We may request feedback from beta users, and your continued use

may inform future changes to the Services (see Section 10,

Feedback); We may end the beta period, transition beta accounts to a general- availability version of the Services, or discontinue a beta feature at our discretion.
 

3. Account Registration

To use FriskOL, you must register for an account and provide accurate information. You agree to: Provide truthful, accurate registration information and keep it current; Maintain the confidentiality of your account credentials; Notify us immediately at friskoling@gmail.com of any unauthorized use of an account or other security breach; and Accept responsibility for all activity occurring under your account,

including activity by a child linked to your account, to the extent permitted by law . Accounts are for use by a single individual or household and may not be shared, sold, or transferred, except as necessary for a parent/guardian to manage a linked child account.
 

4. Subscription Plans

FriskOL currently offers two plans:

Free Tier — access to a limited set of FriskOL features at no cost.

Paid Tier — access to the full set of FriskOL features for a

recurring subscription fee. FriskOL does not currently offer licensing agreements, group or institutional agreements, or bulk/organizational pricing. Each Account Holder subscribes individually .
 

Renewal. Paid subscriptions automatically renew at the end of each billing period unless canceled before renewal.

Cancellation. You may cancel at any time through your account settings or the platform through which you subscribed (e.g., theApple App Store or Google Play Store, if applicable). Cancellation stops future charges but does not entitle you to a refund foramounts already paid, unless required by law . Price and Feature Changes. Because FriskOL is in MVP/beta, pricing and the features included in each tier may change. We will provide advance notice of material changes to paid subscribers. If you do not agree to a change, you may cancel before it takes effect.
 

Refunds. Except where required by law , subscription fees are non-

refundable. No Advertising. FriskOL does not display third-party advertising to any user , including children.

 

5. User-Uploaded Study Content

FriskOL allows users to upload their own study materials (notes, flashcard-style content, practice questions, and similar materials) for

use with PhyLO and other learning tools (“User Content”).
 

5.1 Ownership. As between you and FriskOL, you (or , for a child’s User Content, the child’s parent/guardian on the child’s behalf) retain

ownership of User Content you upload.
 

5.2 License to FriskOL. You grant FriskOL a worldwide, non-exclusive, royalty-free license to host, store, reproduce, process, anddisplay User Content solely as necessary to provide and improve the Services for your account — for example, generating study aids,

practice content, or PhyLO responses based on material you’ve uploaded. This license does not permit FriskOL to sell User Content,

make it publicly visible to other users without your action to share it, or use it for advertising.
 

5.3 Content Standards. Because FriskOL serves K–12 learners, User Content must be educational or study-related and age-appropriate.

You may not upload Content that: Is sexually explicit, violent, or otherwise inappropriate for a K–12 audience; Harasses, bullies, or threatens any person; Discloses another person’s personal information without consent; Infringes another person’s copyright, trademark, or other rights; Contains malware or code intended to disrupt the Services; or Otherwise violates these Terms or applicable law .
 

5.4 Representations. By uploading User Content, you represent that you have the right to do so and that the Content does not violate the

rights of any third party .
 

5.5 Moderation. FriskOL has not reviewed, and cannot review , all User Content in advance. We do not endorse or guarantee the accuracy of User Content. We may , at our discretion, review , remove, or restrict access to User Content that we believe violates these Terms, and may report content or conduct that appears to endanger a child’s safety to appropriate authorities. You can report concerning Content to friskoling@gmail.com.
 

5.6 No Commercial Use by Other Users. Other users may not copy , resell, or use your User Content for any commercial purpose.

 

6. Use of Third-Party AI and Cloud Services FriskOL uses third-party AI and cloud infrastructure providers, currently Google Gemini (via Google Cloud/Vertex AI) and AWS

Cloud, to power PhyLO and deliver personalized learning content. As described in our Privacy Policy: Learner interaction data is de-identified before it is sent to Gemini; FriskOL does not transmit personally identifiable information to Gemini.

Data is used only to generate in-session, personalized learning content and is not used to train, fine-tune, or improve FriskOL ’s

models or Google’s models. Your use of the Services does not create any contractual relationship

between you and Google, AWS, or any other third-party provider FriskOL uses. AI-generated content may be inaccurate, incomplete, or unsuitable for a particular learner’s needs. AI-generated content is a learning aid, not a substitute for a qualified educator’s or specialist’s professional judgment, and should be reviewed by a parent, guardian, or educator particularly for learners with diverse needs.

 

7. Prohibited Uses

You agree not to: Violate any applicable law or regulation; Circumvent or attempt to circumvent KWS age verification or parental consent mechanisms; Impersonate another person or misrepresent your identity , age, or authority;

Interfere with, disrupt, or gain unauthorized access to the Services, accounts, or systems; Reverse engineer , decompile, scrape, or attempt to access FriskOL ’s source code, models, or proprietary technology , except as permitted by law; Use the Services to develop, train, or improve a competing product or AI system; Upload malware, viruses, or other harmful code; orResell, sublicense, or provide access to the Services to third parties without FriskOL ’s written consent, including on an institutional or group basis.

 

8. Intellectual Property

The Services, including PhyLO, our software, features, functionality , content, trademarks, and logos, are owned by FriskOL or its licensors

and protected by applicable law . Your use of the Services does not grant you ownership of, or any license to, FriskOL ’s intellectual property except the limited right to use outputs generated for you through the Services, subject to your compliance with these Terms.
 

9. Feedback

Because FriskOL is in beta, we may ask for or you may choose to provide feedback, bug reports, or suggestions (“Feedback”). You grant FriskOL a perpetual, worldwide, royalty-free license to use and incorporate Feedback into the Services without compensation or

attribution to you. We are under no obligation to act on any Feedback.10. Disclaimer of Warranties; Beta Services
 

TO THE MAXIMUM EXTENT PERMITTED BY LAW , THE SERVICES ARE PROVIDED “ AS IS” AND “ AS AVAILABLE, ” WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY , INCLUDING WARRANTIES OF MERCHANTABILITY , FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. BECAUSE FriskOL IS IN MVP/BETA RELEASE, WE DO NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED, ERROR-FREE, SECURE, OR THAT ANY PARTICULAR FEATURE WILL

REMAIN AVAILABLE. FriskOL IS AN EDUCATIONAL TOOL, NOT A LICENSED TEACHER,THERAPIST , OR DIAGNOSTIC SERVICE. THE SERVICES ARE NOT INTENDED TO DIAGNOSE OR TREAT ANY LEARNING DISABILITY OR OTHER CONDITION, AND SHOULD NOT REPLACE ASSESSMENT OR INSTRUCTION BY A QUALIFIED EDUCATOR OR SPECIALIST WHERE ONE IS NEEDED.
 

11. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW , FriskOL AND ITS OFFICERS, DIRECTORS, EMPLOYEES, CONTRACTORS, AND

SERVICE PROVIDERS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY , OR

PUNITIVE DAMAGES ARISING OUT OF OR RELATING TO YOUR USE OF THE SERVICES. FriskOL ’S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THE SERVICES SHALL NOT EXCEED THE GREATER OF: (A) THE TOTAL AMOUNT PAID BY YOU TO FriskOL FOR THE SERVICES DURING THE TWEL VE (12) MONTHS PRECEDING THE

EVENT GIVING RISE TO THE CLAIM; OR (B) ONE HUNDRED U.S. DOLLARS (US $100). Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law .

 

12. Indemnification

To the maximum extent permitted by law , the Account Holder agrees to defend, indemnify , and hold harmless FriskOL and its officers, directors, employees, contractors, and service providers from claims, damages, losses, and expenses (including reasonable attorneys’ fees) arising out of or relating to: (a) the Account Holder’s or a linked learner’s use of the Services; (b) violation of these Terms or applicable

law; or (c) User Content uploaded through the account.

 

13. Termination

FriskOL may suspend or terminate an account at its discretion if it reasonably believes these Terms have been violated, or as necessary to comply with legal or child-safety obligations. A parent/guardian may terminate a linked child’s account at any time by withdrawing

parental consent, as described in our Privacy Policy . Provisions that bytheir nature should survive termination — including Intellectual

Property , Disclaimers, Limitation of Liability , Indemnification, and Dispute Resolution — will survive.

 

14. Dispute Resolution and Arbitration

This section applies to the Account Holder , who is the party accepting these Terms. Please read it carefully — it affects your legal rights. Informal Resolution First. Before filing a claim, you agree to contact us at friskoling@gmail.com and attempt to resolve the dispute

informally for at least 30 days. Binding Arbitration. If informal resolution is unsuccessful, any dispute arising out of or relating to these Terms or the Services shall be resolved by binding individual arbitration under the Federal Arbitration Act, administered by JAMS under its applicable rules, before a single arbitrator . Class Action Waiver. YOU AND FriskOL AGREE THAT DISPUTES WILL BE RESOL VED ON AN INDIVIDUAL BASIS ONLY . CLASS ACTIONS, CLASS ARBITRATIONS, AND REPRESENTATIVE PROCEEDINGS ARE NOT PERMITTED.

Nothing in this section prevents FriskOL from seeking injunctive relief in court to protect its intellectual property or confidential information, or prevents either party from bringing an individual claim in small claims court where eligible.

 

15. Governing Law and Venue

These Terms are governed by the laws of the State of California, without regard to conflict-of-laws principles. Where a dispute is not subject to arbitration, exclusive jurisdiction and venue shall lie in the state or federal courts located in California.

 

16. Changes to These Terms  We may modify these Terms from time to time, particularly as FriskOL moves from MVP/beta to general availability . We will provide notice of material changes through the Platform or by email. If a change affects how we collect or use a child’s information, we will seek renewed

parental consent as required by COPPA before the change takes effect for that child’s account. Continued use after the effective date of a change constitutes acceptance.

 

17. Contact Information: Questions about these Terms, your account, billing, or privacy may be

directed to: Email: friskoling@gmail.com Notes for internal review (remove before publishing)
 

1. This draft has not been reviewed by an attorney, and given the combination of a children’s audience, user-generated content, and a binding arbitration/class-action-waiver clause, it should not go live without that review — this is a higher-stakes documentation the Privacy Policy .
 

2. The “ Account Holder” structure (Section 1) is the key design choice in this draft: it routes contractual obligations (including arbitration and indemnification) through an adult for children under 13, since a direct agreement with a minor is generally not enforceable the way an adult contract is. For 13–17, the current draft lets the teen be their own Account Holder for free-tier use (matching COPPA ’s own threshold), with a parent/guardian stepping in only for paid subscriptions. This is a risk-tolerance choice, not a legal requirement either way flag it for your attorney , and let me know if you’d rather require guardian involvement for all minors regardless of tier .
 

3. Content moderation (Section 5.5) is written at a general level appropriate for MVP . Once you have real usage data, you may want to add specifics. e.g., whether uploaded content from a child’s account is visible to that child’s parent/guardian by default, and what the actual reporting/response workflow looks like.
 

4. Because Section 14 (arbitration/class-action waiver) applies to whoever is the Account Holder , the same minor-enforceability caveat in note 2 applies there for 13–17-year-old free-tier users  another point worth flagging to your attorney specifically .