Terms & Conditions

These Terms & Conditions (the "Terms") govern your access to and use of the application, verification, and screening platform operated by on Carousel Inc., a corporation organized under the laws of Québec, Canada, with offices at 5101 rue Buchan, Montréal, Québec, Canada ("Carousel", "we", "us"). They apply to our websites, hosted application portals, forms, verification flows, and related communication tools, including SMS and email (together, the "Platform").

By starting or submitting an Application, creating an account, enrolling in Carousel Verified, or otherwise using the Platform, you agree to these Terms and to our Privacy Policy, which is incorporated by reference. If you do not agree, do not use the Platform.

1. Who Carousel Is — and Is Not

Carousel provides application and verification infrastructure. Businesses across industries — including residential and commercial leasing, property management, lending and private credit, auto finance, equipment leasing, merchant and marketplace onboarding, and insurance — use the Platform to collect applications and to run identity, credit, background, court-record, income, employment, and bank-account verifications through licensed third-party providers.

2. Key Definitions

• "Application" means the collection of information, documents, and Verification Results assembled through the Platform in connection with a transaction you are applying for (for example, a tenancy, lease, loan, financing, account, or onboarding).
• "Requesting Party" means the business to which your Application is directed or delivered — for example, a landlord, property manager, lender, dealer, lessor, marketplace, or insurer. The Requesting Party is Carousel's business customer in Customer-Sponsored Applications and your chosen recipient in Applicant-Owned Applications.
• "Verification Step" means an individual check run through the Platform, which may include identity verification (including government-ID capture and biometric face match/liveness), credit reporting, court and eviction record searches, bank-account and income verification, questionnaires, and document uploads. The Verification Steps in your flow depend on how the Requesting Party (or you) configured the Application.
• "Verification Result" means the output returned by a third-party provider for a Verification Step, whether pass, fail, or inconclusive.
• "Carousel Verified" means Carousel's optional reusable identity service described in Section 6.

3. Two Ways Applications Work: Who Pays and Who Owns

The Platform supports two engagement models. The model that applies to your Application is disclosed in the application flow before you pay or submit — on the payment screen (if you pay) or on the introduction/consent screen (if the Requesting Party pays). Your rights differ between the two models, so please read this section carefully.

3.1 Applicant-Owned Applications (you pay, you own)

In an "Applicant-Owned Application", you purchase your Application directly from Carousel:

• Contract. Your contract for the Application is with Carousel. You are Carousel's customer for that purchase, and the fees described in Section 7 apply.
• Ownership and control. The Application record belongs to you. You decide which Requesting Party or Parties receive it. Carousel delivers your Application only at your direction.
• Reuse and sharing. Where offered, you may share the same Application with additional Requesting Parties — there is no limit on the number of recipients or on how long your Application remains shareable while it is active in your account. Time-sensitive results do go stale, however: a consumer-report Verification Step (for example, credit or court/eviction records) that is more than thirty (30) days old at the time of a new delivery must be re-run, at the price disclosed to you, before that delivery. The information and documents you submitted yourself do not expire in this way, and a completed identity verification remains valid until the expiry of the underlying ID document. Each recipient receives its own delivery and may not re-share your Application beyond the purpose for which you sent it.
• Deletion and access. Because you own the Application, you exercise access, correction, and deletion rights directly with Carousel, as described in the Privacy Policy. Deleting your Application does not retract copies already delivered to a Requesting Party at your direction; those copies are governed by that Requesting Party's own obligations.
• No guarantee of outcome. Purchasing an Application does not guarantee that any Requesting Party will accept it, consider it, or approve you.

3.2 Customer-Sponsored Applications (the Requesting Party pays and owns)

In a "Customer-Sponsored Application", a Requesting Party invites you to apply and pays Carousel for the Verification Steps:

• Contract. Carousel provides the Platform to the Requesting Party under a separate business agreement. Your use of the Platform is still governed by these Terms, but you are not charged by Carousel unless a fee to you is expressly disclosed in the flow.
• Ownership and control. The Application record is collected for, and controlled by, the Requesting Party. Carousel processes it as the Requesting Party's service provider.
• Access, correction, and deletion. Requests concerning your Application should be directed to the Requesting Party, who controls the record. Carousel will assist the Requesting Party in honoring such requests and will redirect requests we receive, as described in the Privacy Policy. Certain records Carousel must keep for billing, audit, dispute-resolution, or legal purposes survive deletion requests.
• Decisions. The Requesting Party alone decides on your Application, including any adverse decision, and is responsible for any legally required adverse-action or adverse-decision notices.

3.3 Rules common to both models

• Consents you give in the flow (Section 5) are identical in effect in either model.
• Carousel Verified enrollment (Section 6) is always a direct, optional relationship between you and Carousel, regardless of who paid for the Application.
• If a flow combines models (for example, the Requesting Party pays for some Verification Steps and you pay for others), each fee and its payer is disclosed before you pay or submit.

4. Eligibility and Your Responsibilities

• You must be at least 18 years old (or the age of majority in your jurisdiction, if higher) and applying on your own behalf, or with documented legal authority to act for another adult (for example, as guarantor or co-applicant with that person's consent).
• You agree that all information and documents you submit are true, accurate, current, and complete, and that you will not submit another person's identity documents, falsified documents, or manipulated media.
• You are responsible for maintaining the confidentiality of any credentials and one-time passcodes sent to you.

5. Consents and Authorizations You Give in the Flow

Depending on the Verification Steps configured for your Application, you will be asked in the flow to give some or all of the following consents. Each is presented at the relevant step, and you may decline — though declining a required step may mean your Application cannot be completed.

• Identity verification. You authorize Carousel and its identity-verification provider to capture images of your government-issued ID and of your face, to extract data from them, and to perform a biometric face match and liveness check to confirm you are the person on the ID. Biometric data handling, including retention and destruction, is described in the Privacy Policy's Biometric Information section and, where required by law, in a separate written consent presented at the step.
• Consumer reports and background records. You authorize the procurement of consumer reports and background information about you — which may include credit reports, court records, and eviction-related records — from licensed consumer reporting agencies and providers, for delivery to the Requesting Party (or to you, in an Applicant-Owned Application, for onward delivery at your direction) in connection with your Application. Where the law of your jurisdiction requires standalone written disclosure and authorization (for example, under the U.S. Fair Credit Reporting Act), it is presented as a separate document at the step.
• Bank-account and income verification. You authorize connection to your financial account through a data aggregator, and the retrieval of account, balance, transaction, income, or employment data, solely for the verification purposes disclosed at the step. Your banking credentials are provided to the aggregator, not to Carousel.
• Electronic signatures and records. You consent to transact electronically and to sign electronically. Your electronic signature and electronic records have the same effect as ink and paper, in accordance with applicable law, including the U.S. ESIGN Act and UETA, and, in Québec, the Act to establish a legal framework for information technology (LCCJTI). You may request paper copies or withdraw e-consent as described at the signing step; withdrawal does not affect documents already signed.
• SMS and email. As described in Section 9.

6. Carousel Verified (Optional Reusable Identity)

At the identity-verification step, you may be offered the option to enroll in Carousel Verified. Enrollment is optional and requires your separate, explicit consent at that step. If you enroll:

• What is saved. Your verified identity record — the verified data from your ID document and the biometric reference needed to recognize you — is retained under Carousel's own direct relationship with you. Biometric data is processed and stored by our identity-verification provider on Carousel's behalf, for no longer than the retention schedule published in the Privacy Policy (at most until the expiry of your ID document, and shorter where law requires).
• How reuse works. On a later application anywhere on the Platform, you can verify with a face scan alone, matched against your saved record, instead of re-scanning your ID. A reuse delivers the same verification results to the recipient as a full verification would.
• Your control. You may withdraw from Carousel Verified and have your verified identity record deleted at any time by contacting privacy@oncarousel.com or through the mechanism in the Platform. Withdrawal simply means future applications require the full flow again.
• Independence from Requesting Parties. Your Carousel Verified record is maintained by Carousel, not by any Requesting Party. It is not deleted when a Requesting Party deletes its application records, and no Requesting Party controls it.
• Biometric law compliance. Where you are in a jurisdiction with biometric-privacy legislation (for example, Illinois BIPA, Texas CUBI, Washington HB 1493, or Québec's Act respecting the protection of personal information in the private sector), enrollment is collected through a written/electronic consent meeting that law's requirements, and retention and destruction follow the published schedule in the Privacy Policy.

7. Fees, Payment, and Refunds (Applicant-Owned Applications)

This section applies when you pay Carousel. All prices are shown at checkout before you pay, in the currency displayed, plus applicable taxes.

• What you are buying. Your fee covers the running of the disclosed Verification Steps and assembly and delivery of your Application. Third-party provider costs are included in the displayed price.
• Completed steps are earned. A Verification Step is complete when the third-party provider returns a result — whether pass, fail, or inconclusive. Because provider costs are incurred when a step runs, fees for completed Verification Steps are non-refundable, including where the result is not what you hoped or the Requesting Party declines your Application.
• Incomplete steps. If a Verification Step cannot be completed for reasons within Carousel's or the provider's control, we will re-run it at no charge or refund the fee attributable to that step.
• Payment processing. Payments are processed by our payment processor; Carousel does not store full card numbers. A disclosed processing fee may apply once per Application.
• Consumer-law rights. Nothing in this section limits refund or cancellation rights that cannot be waived under the consumer-protection law of your jurisdiction, including the Québec Consumer Protection Act.

8. Disputes About Verification Results; Adverse Decisions

• If you believe information in a consumer report or Verification Result is inaccurate or incomplete, you have the right to dispute it with the consumer reporting agency or provider that produced it. The flow and your delivered Application identify the source of each report; on request, Carousel will tell you which provider produced a given Verification Result and how to reach them.
• If a Requesting Party takes adverse action based in whole or in part on a consumer report, that Requesting Party is responsible for providing you the notices required by applicable law (for example, FCRA adverse-action notice in the U.S., or notices under provincial credit-reporting legislation in Canada), including the identity of the reporting agency and your dispute rights.
• Carousel does not alter Verification Results and cannot change a Requesting Party's decision.

9. SMS and Electronic Communications

• By providing your phone number in the flow and proceeding, you agree to receive transactional text messages from Carousel — one-time passcodes, verification and status updates, and reminders you trigger during the process. We do not send marketing texts and we do not use purchased phone lists.
• Message frequency depends on your activity. Message and data rates may apply. Reply STOP to opt out at any time and HELP for help, or contact privacy@oncarousel.com. Opting out of SMS may require completing verification by another disclosed method.
• Messages are delivered through our SMS provider in compliance with applicable carrier and A2P messaging requirements.

10. Acceptable Use

You agree not to: (a) submit false, fraudulent, or misleading information or documents, or another person's identity; (b) attempt to defeat, spoof, or manipulate any Verification Step, including biometric checks; (c) access or use another person's Application or Verification Results without lawful authority; (d) use the Platform to obtain information about any person other than yourself except with documented authority; (e) probe, scrape, reverse engineer, or interfere with the Platform; or (f) use the Platform in violation of applicable law, including consumer-reporting, fair-lending, and fair-housing laws. Carousel may suspend or cancel Applications and refuse service where it reasonably suspects fraud or misuse.

11. Intellectual Property; License

The Platform, including its software, design, text, and trademarks, belongs to Carousel and its licensors. Carousel grants you a limited, revocable, non-exclusive, non-transferable license to use the Platform to prepare, purchase, and manage your own Applications. You retain ownership of the information and documents you submit; you grant Carousel a license to host, process, and transmit them as needed to provide the services and as described in the Privacy Policy.

12. Disclaimers

Except as expressly stated in these Terms and to the maximum extent permitted by applicable law, the Platform and all Verification Results are provided "as is" and "as available." Carousel does not warrant that Verification Results are error-free — reports reflect the records of the providers and bureaus that produce them — and does not warrant any particular outcome of any Application. Nothing in this section excludes warranties, conditions, or guarantees that cannot be excluded under applicable consumer-protection law, including the legal warranty under the Civil Code of Québec and the Québec Consumer Protection Act.

13. Limitation of Liability

To the maximum extent permitted by applicable law: (a) neither party is liable for indirect, incidental, consequential, special, punitive, or exemplary damages, or for lost profits, revenue, data, or opportunities; and (b) Carousel's total aggregate liability arising out of or related to these Terms or the Platform will not exceed the greater of (i) the amounts you paid Carousel in the twelve (12) months preceding the event giving rise to liability and (ii) one hundred dollars (CAD $100). These limitations do not apply to liability that cannot be limited under applicable law, including for bodily or moral injury, gross negligence or intentional fault under Québec law, or fraud.

14. Release

Decisions on your Application are made by Requesting Parties, and report contents are produced by providers. To the maximum extent permitted by law, you release Carousel from claims arising out of (a) a Requesting Party's decisions, acts, or omissions, and (b) the content of reports produced by third-party providers, in each case except to the extent caused by Carousel's breach of these Terms or of applicable law. If you are a California resident, you waive California Civil Code §1542, which says: "A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party." This release does not apply where such waivers are not permitted, including for Québec consumers to the extent prohibited by the Consumer Protection Act.

15. Dispute Resolution; Arbitration and Class-Action Waiver

Please read this section carefully — it affects your rights.

• Informal resolution first. Before starting any proceeding, you and Carousel agree to try to resolve any dispute informally by written notice to privacy@oncarousel.com (or, from Carousel, to your email on file) and 60 days of good-faith discussion.
• Arbitration (where permitted). Except where prohibited by applicable law, any dispute arising out of or relating to these Terms or the Platform will be resolved by final and binding individual arbitration — administered by the American Arbitration Association under its Consumer Arbitration Rules if you reside in the United States, and otherwise by the ADR Institute of Canada under its Arbitration Rules — rather than in court, except that either party may bring an individual claim in small-claims court and either party may seek injunctive relief for intellectual-property misuse.
• Class-action waiver (where permitted). Disputes will be arbitrated or litigated only on an individual basis; class, collective, and representative proceedings are waived to the extent permitted by law.
• Consumer carve-outs. This Section does not apply where it cannot: in particular, if you are a consumer in Québec, the Québec Consumer Protection Act prohibits mandatory pre-dispute arbitration and class-waiver clauses, and you retain your right to go to court, including via class action; similar rules in other Canadian provinces and other jurisdictions are likewise respected. If any part of this Section is unenforceable as to you, the remainder of the Terms still applies and disputes will be resolved in the courts identified in Section 16.

16. Governing Law and Venue

These Terms are governed by the laws of the Province of Québec and the federal laws of Canada applicable therein, without regard to conflict-of-laws rules — except that if you reside in a jurisdiction whose law grants you mandatory protections (including consumer-protection, credit-reporting, biometric-privacy, or data-protection rights) that cannot be waived by a choice of Québec law, those protections apply to you notwithstanding this clause. Subject to Section 15, disputes will be brought in the courts of the district of Montréal, Québec, or, where mandatory law gives you the right to sue in your home jurisdiction, in that jurisdiction.

17. Changes; Termination; Miscellaneous

• Changes. We may update these Terms from time to time. For material changes we will give advance notice as required by applicable law (in Québec, written notice of the change, its effective date, and your right to refuse and cancel, per the Consumer Protection Act's rules on unilateral amendment). The version in effect when you submit an Application governs that Application.
• Termination. You may stop using the Platform at any time; Sections that by nature survive (including 7, 8, 12–16) survive. Carousel may suspend access for misuse under Section 10.
• Entire agreement; language. These Terms and the Privacy Policy are the entire agreement between you and Carousel concerning the Platform. A French version of these Terms will be made available to Québec users in accordance with the Charter of the French Language, and nothing in these Terms limits the French-language rights of Québec consumers; where a French version is provided, it governs for Québec consumers in case of discrepancy. If any provision is unenforceable, the remainder stands. You may not assign these Terms; Carousel may assign them in connection with a merger, acquisition, or sale of assets with notice to you.

18. Contact

on Carousel Inc.
5101 rue Buchan, Montréal, Québec, Canada
Email: privacy@oncarousel.com