LEGAL DOCUMENT — BROKER NETWORK
Broker Confidentiality &
Data Use Agreement
CARTRIGO Advanced LLC · Version v0.1 · Draft for Legal Review · April 2026
This Agreement governs the terms under which authorized CARTRIGO brokers access, use, and handle consumer information through the CARTRIGO platform. By activating your broker account, you agree to all terms contained herein.
⚠ DRAFT FOR LEGAL REVIEW: This document is a professional draft subject to review and finalization by a licensed Florida attorney before execution. It does not constitute legal advice. For questions: compliance@cartrigoadvanced.com
Critical requirement for all brokers: Before entering any client data into the CARTRIGO platform, you MUST obtain the client's informed and voluntary consent. This is not optional — it is a legal requirement under the Fair Credit Reporting Act (FCRA) and the Gramm-Leach-Bliley Act (GLBA). Leads created without documented consent are invalid and may be removed from the system.
SECTION 1
Parties and Purpose

This Agreement is entered into between CARTRIGO Advanced LLC ("CARTRIGO" or "Platform") and the individual or entity accessing the platform as an authorized broker ("Broker").

The purpose of this Agreement is to establish the terms under which Broker may access, use, and handle client data; to protect the privacy and security of consumers; and to define Broker's compliance obligations under applicable federal and Florida state law.

PLATFORM
CARTRIGO Advanced LLC
Operates the advisory platform, manages the CRM, and sets all compliance standards for data handling.
BROKER
Authorized Broker
Accesses the platform to manage client inquiries, generate OTD estimates, and coordinate vehicle purchases.
CONSUMER
Client / Consumer
The individual whose personal and financial information is entered into and processed by the CARTRIGO platform.
SECTION 2
Authorized Use of Client Data

Broker is authorized to access and use client data exclusively for the following purposes:

Core principle: Broker may ONLY use client data for the specific purpose for which the consumer provided consent. Any use outside the scope of an active, authorized inquiry is strictly prohibited and constitutes a material breach of this Agreement.
SECTION 3
Prohibited Uses of Client Data
BROKER MAY
View and manage leads assigned to your account.
Generate OTD estimates using client's declared profile.
Contact clients via approved channels about their active inquiry.
Send OTD summaries via WhatsApp with the required disclaimer included.
Coordinate client visits to participating dealers.
Add notes and status updates to the lead record.
BROKER MAY NOT
Use client data for any personal, commercial, or business purpose outside CARTRIGO.
Download, export, or copy client data to personal devices or external systems.
Share client data with any unauthorized third party.
Allow any other person to access the platform using your credentials.
Represent CARTRIGO results as final credit approvals or guaranteed financing.
Initiate any credit inquiry without documented consumer consent and permissible purpose.
Retain client data after the inquiry is closed or after termination of this Agreement.
SECTION 4 — CRITICAL
Consent Obligations
This is the most legally critical section. Failure to obtain and document consumer consent before entering client data is a material breach of this Agreement and may expose both you and CARTRIGO to liability under the FCRA, GLBA, and Florida consumer protection law.

Before entering any client data, you must:

Acceptable consent methods — Exhibit A:

Method Acceptability Evidence Required
CARTRIGO web intake form ✓ ACCEPTED IP address, timestamp, and session ID logged automatically by platform.
CARTRIGO consumer authorization PDF — signed ✓ ACCEPTED Signed document uploaded to the lead file.
Recorded telephone consent ✓ ACCEPTED Recording retained for 5 years minimum. Date and time noted in lead record.
WhatsApp written confirmation ✓ ACCEPTED Screenshot of client's explicit written "I accept" message saved to lead file.
Verbal consent without recording ✗ NOT ACCEPTED Cannot be verified. Does not meet FCRA/GLBA documentation requirements.
Dealer authorization as substitute ✗ NOT ACCEPTED Dealer authorization does not replace direct consumer consent.
Prior consent from unrelated transaction ✗ NOT ACCEPTED Consent must be specific to the current CARTRIGO inquiry.
SECTION 5
Security Requirements

Broker agrees to maintain the following minimum security practices when accessing the CARTRIGO platform:

💻
Personal devices only
Only use personal, non-shared devices to access the platform. Never use public computers or shared devices.
🔒
Secure networks
Never access the platform on public or unsecured Wi-Fi without a VPN. Coffee shops, airports, and hotel networks are not secure.
🚪
Log out every time
Log out of the platform after each session. Do not leave an active session unattended. Sessions expire after 60 minutes automatically.
🔑
Strong password
Use a strong, unique password for your CARTRIGO account. Never reuse passwords across services or share credentials with anyone.
📱
Device lock screen
Enable PIN, fingerprint, or equivalent lock screen on any device used to access the platform or client data.
🚨
Report incidents immediately
Report any suspected compromise of credentials or device to compliance@cartrigoadvanced.com within 24 hours.
SECTION 6
Security Incident Reporting — 24-Hour Requirement

You are required to report the following events to CARTRIGO at compliance@cartrigoadvanced.com within 24 hours of discovery:

REPORT IMMEDIATELY
Unauthorized account access: Any actual or suspected unauthorized access to your CARTRIGO platform account.
REPORT IMMEDIATELY
Data exposure: Any actual or suspected exposure or disclosure of client data to unauthorized persons.
REPORT IMMEDIATELY
Lost or stolen device: Loss or theft of any device used to access the CARTRIGO platform.
REPORT IMMEDIATELY
Consumer complaint: Any communication from a client or third party indicating that client data may have been misused.
Failure to timely report a security incident is a material breach of this Agreement. CARTRIGO reserves the right to terminate Broker's access immediately upon discovery of an unreported incident.
SECTION 7
Permitted Language — What You Can and Cannot Say

Broker represents that all client communications will comply with CARTRIGO's Manual de Lenguaje Permitido. Key rules:

USE THIS LANGUAGE
"This is your preliminary OTD estimate — subject to dealer confirmation."
"Your estimated monthly payment could be between X and Y."
"Based on your declared credit profile, here is a likely scenario."
"CARTRIGO helps you prepare — the final decision is made by the dealer and lender."
"This is a reference estimate for your preparation."
NEVER SAY THIS
"Your credit is approved." — CARTRIGO does not approve credit.
"I guarantee you will qualify." — No guarantees of financing.
"Don't worry about your credit." — Never minimize real risk.
"We handle all the credit." — CARTRIGO is not a lender.
"Your rate will be X%." — Rates are determined by lenders only.
"Let me check your credit right now." — Only with documented consent and permissible purpose.
SECTION 8
Data Retention and Return / Destruction
SECTION 9
Term and Termination
TopicTerms
Effective dateThis Agreement is effective upon your electronic acceptance in the CARTRIGO broker activation flow.
Termination by CARTRIGOCARTRIGO may terminate your access immediately, with or without notice, for: violation of this Agreement, misuse of client data, consumer complaints, failure to maintain compliance practices, or inactivity for more than 90 days.
Termination by BrokerBroker may terminate by providing 30 days written notice. Upon notice, immediately cease use of client data and comply with destruction obligations.
SurvivalSections 3, 4, 5, 6, 8, 10, and 11 survive termination of this Agreement.
SECTION 10
Legal and Regulatory Compliance
SECTION 11
Indemnification

You agree to indemnify, defend, and hold harmless CARTRIGO Advanced LLC and its members, officers, and partners from and against any claims, liabilities, damages, losses, and attorneys' fees arising out of:

SECTION 12
Electronic Acceptance and Signature
E-SIGN ACT NOTICE
Your electronic acceptance of this Agreement in the CARTRIGO broker activation flow — including clicking "I Accept" or equivalent — constitutes a legally binding electronic signature under the Electronic Signatures in Global and National Commerce Act (E-SIGN) and Florida's Electronic Signature Act.

The date, time, IP address, and user identifier associated with your acceptance are recorded automatically by the CARTRIGO system and constitute evidence of execution. By accepting, you confirm that you have read, understood, and agree to all terms of this Agreement.
EXECUTION
Signature Block

For brokers who execute this Agreement via physical signature rather than electronic activation flow:

PLATFORM — PARTY A
CARTRIGO Advanced LLC
Signature: ___________________________
Printed name: ________________________
Title: Managing Member / Director
Date: _______________________________
7401 Wiles Rd, Suite 334
Coral Springs, FL 33067
BROKER — PARTY B
Authorized Broker
Signature: ___________________________
Printed name: ________________________
Company / Entity: ____________________
License / ID Number: _________________
Date: _______________________________
CONTACT & COMPLIANCE
CARTRIGO Advanced LLC
7401 Wiles Rd, Suite 334, Coral Springs, FL 33067
compliance@cartrigoadvanced.com
cartrigoadvanced.com/en