TERMS OF SERVICE

My Record Locker

Effective Date: October 11, 2026

1. Definitions

"Platform" means the My Record Locker web applications and websites We operate, including MyRecordLocker.com and its subdomains, websites We host for Customers (including on domains Customers connect), and all related services, APIs and documentation.

"We," "Us," "Our," or "Kryptomneme" means Kryptomneme LLC, the operator of the Platform.

"Customer" means the organization that creates an account, subscribes to a plan, and pays for the Service.

"User" means any individual a Customer authorizes to use the Service, including its owners, administrators, employees, caretakers and Learners.

"Learner" means any individual invited by a Customer to complete training modules through the Platform.

"Completion Record" means the cryptographically signed, tamper-evident record issued by the Platform upon completion of a training module, documenting that formal instruction occurred and that a sampled identity check took place.

"Tenant Workspace" means the logically isolated environment provisioned for each Customer within the Platform.

"Disposal" means the removal, on the retention schedule the Customer configures or on a valid request, of information identifying an individual from a Completion Record and from the associated records We hold, such that the record no longer identifies the individual who completed the training. Disposal is irreversible once executed and does not remove the Completion Record itself, and does not remove the identity of the Customer or of the person named as having approved the training.

"Service" means the Platform and all functionality provided under these Terms, including training-module delivery, Completion Record issuance, record storage and export, resident logs and medication records, time keeping, expense tracking, electronic signing, templates and suggested wording, and websites and printed materials made for Customers.

2. Acceptance of Terms

By creating an account, completing the signup process, or using the Service, the Customer and each Learner agree to be bound by these Terms. If the Customer is an organization, the individual accepting these Terms represents and warrants that they have authority to bind that organization. If you do not agree to these Terms, do not use the Service.

3. Description of Service

3.1 What the Platform Does

The Platform enables Customers to deliver training modules of their choosing to their Learners. Upon successful completion of a module, the Platform issues a Completion Record — a cryptographically signed, tamper-evident record that formal instruction occurred and that a sampled identity check took place during the session.

3.2 What the Platform Does NOT Do

The Platform does not guarantee, certify, or ensure regulatory compliance. Completion Records document that training was delivered and that a sampled identity check occurred; they do not constitute a certification, accreditation, or guarantee that any regulatory requirement has been satisfied. Customers are solely responsible for determining whether their training programs, including any practical evaluations or other components delivered outside the Platform, satisfy any applicable requirements. The Platform is not endorsed by, affiliated with, or certified by any regulatory body, agency, or standards organization.

3.3 Sampled Identity

Identity verification during training sessions is sampled (for example, a one-time-password check at session start), not continuous. The Platform does not claim or guarantee that the individual who completed the training is the individual identified in the record beyond the scope of the sampled check performed.

3.4 Permanence of Records

Completion Records, once issued, are permanent and are not retroactively altered. A record reaching the end of its retention period, or subject to a valid request, undergoes Disposal: the record is retained and remains verifiable, and no longer identifies the individual who completed the training. See Section 10 (Data Retention and Deletion).

3.5 Content Approval and Instructor of Record

Every quiz published through the Platform identifies an Instructor of Record — a named individual, designated by the Customer, who attests that the training content is appropriate for its intended use. That name is recorded with the quiz and is carried on every Completion Record issued from it.

The Platform provides the mechanism by which a named individual makes that attestation. It does not verify, evaluate, or warrant the attestation itself. The Platform does not confirm that the named individual reviewed the content, is qualified to evaluate it, holds any credential stated alongside their name, consented to be named, or exercised any degree of care. The Platform records who attested; it does not assess whether the attestation was well-founded.

The attestation is the Customer's representation, and responsibility for it rests with the Customer. Customers are solely responsible for designating appropriate individuals, for ensuring that those individuals actually review what they approve, and for determining whether an attestation satisfies any requirement applicable to the Customer.

The Platform does not require that the Instructor of Record, the person who creates a quiz, and the person who completes it be different individuals. Where a Customer designates the same person in more than one of those roles, the Completion Record reflects the names as designated and asserts nothing further about independence, separation of duties, or review by a third party.

4. Accounts and Tenant Workspaces

4.1 Account Registration

Customers register by providing an email address and a company name. Each Customer receives a logically isolated Tenant Workspace. Customer is responsible for the accuracy of registration information.

4.2 Learner Management

Customers manage the Learners within their Tenant Workspace (inviting and removing them, and managing the quizzes and records their plan provides). Learners are invited by the Customer and reach the Platform through that invitation. Customers are responsible for ensuring that only authorized individuals access their Tenant Workspace.

4.3 Account Security

Customers are responsible for maintaining the confidentiality of their login credentials. Customers must promptly notify Us of any unauthorized access to their Tenant Workspace. We are not liable for any loss arising from unauthorized use of an account.

4.4 Text Messages

If you turn on text messages for your employees, you are responsible for getting each employee's consent before they receive any, for example with a signed text alert agreement. We send these messages on your behalf, only for sign-in codes, clock-in and clock-out confirmations, and alerts that need attention. We never sell employees' mobile phone numbers or share them with anyone for marketing.

5. Payment Terms

5.1 Plans and Pricing

The Platform offers pricing plans as displayed on myrecordlocker.com. All prices are in U.S. dollars unless otherwise stated. We reserve the right to change pricing upon reasonable notice; price changes do not apply retroactively to existing prepaid terms.

5.2 Payment Processing

Payments are processed through Stripe using hosted checkout. Kryptomneme LLC never receives, processes, or stores raw credit card numbers or bank account details. All payment card data is handled entirely by Stripe in accordance with Stripe's own terms and PCI DSS obligations.

5.3 Billing and Renewal

Subscriptions renew automatically at the end of each billing period unless cancelled. Customers may change their plan, adjust the quantity they purchase, or cancel through the Platform's account management interface.

5.4 Refunds

Fees are non-refundable except as required by applicable law or as We may determine at Our sole discretion. Completion Records that have already been issued cannot be "un-issued" — once a record exists, it persists.

5.5 Taxes

Stated prices do not include applicable taxes. Customers are responsible for any sales, use, VAT, or similar taxes imposed by their jurisdiction, except for taxes on Kryptomneme LLC's net income.

6. Intellectual Property

6.1 Platform Ownership

The Platform, its underlying technology, and all associated intellectual property are and remain the property of Kryptomneme LLC or its respective owners. Nothing in these Terms transfers or licenses any intellectual property rights to any Customer or Learner, except for the limited right to use the Service as expressly set forth in these Terms.

6.2 Customer Content

Customers retain ownership of any content they upload or create within the Platform (such as training materials provided for ingestion). By uploading content, Customer grants Kryptomneme LLC a limited, non-exclusive license to use that content solely for the purpose of delivering the Service (for example, processing and presenting it within training modules).

6.3 Completion Records

Completion Records are generated by the Platform and signed using Kryptomneme LLC's cryptographic keys. Customers receive access to and export of their Completion Records but do not receive the signing keys, the verification infrastructure, or the right to self-host the Platform. Custody of Completion Records means export access — not control of the signing or verification systems.

6.4 Your Content and Your Decisions

The Service gives Customers tools, such as templates, suggested wording, forms, logs, reminders, schedules, quizzes, websites and marketing materials. These tools are a starting point. The Customer decides what to create, approve, publish, send, record and act on.

(a) The Customer owns, and is solely responsible for, all content that the Customer or its users create, edit, approve, upload, publish or send using the Service, including content that began as a template or suggestion from the Service.

(b) The Customer is solely responsible for every decision that the Customer or its users make using the Service or anything it produces, including decisions about care, staffing, medication, training, marketing, pricing and compliance.

(c) We do not review, approve or verify the Customer's content or decisions, and We are not responsible for them or for any result of relying on them. A template, suggestion, reminder, alert or default setting in the Service is not advice and does not replace the Customer's own judgment or the advice of the Customer's own professionals.

(d) Nothing in this section limits Our obligations under any Business Associate Agreement between the Customer and Us.

7. Data Ownership and Custody

7.1 Customer Data

The Customer owns the data it provides to the Platform and the data generated within its Tenant Workspace (including Completion Records, Learner information, and training results). Kryptomneme LLC processes this data solely to provide the Service.

7.2 Export

Customers may export their data (including Completion Records) in CSV or JSON format at any time through the Platform's custody interface. Upon termination, Customers may request a full export of their Tenant Workspace data; see Section 11 (Termination).

7.3 No Self-Hosting

The Service is provided as a hosted, multi-tenant platform. Customers do not receive access to source code, signing keys, server infrastructure, or the ability to self-host any component of the Platform.

8. Acceptable Use

Customers and Learners agree to:

(a) Use the Service only for lawful purposes and in accordance with these Terms.

(b) Provide accurate information during registration, account setup, and training sessions.

(c) Not attempt to circumvent, disable, or interfere with any security, identity-verification, or integrity feature of the Platform.

(d) Not reverse-engineer, decompile, or attempt to extract the source code or signing keys of the Platform.

(e) Not use the Service to generate fraudulent training records or misrepresent completion of training.

(f) Comply with all applicable laws and regulations governing their use of training records produced by the Platform, including any workplace safety requirements.

9. Privacy

Use of the Service is also governed by Our Privacy Policy, available at /privacy/. The Privacy Policy is incorporated into these Terms by reference.

For enterprise Customers requiring a Data Processing Addendum (DPA), a standard-form DPA is available at /dpa/ and is incorporated into these Terms by reference. It takes effect on acceptance of these Terms, without a separate signature.

10. Data Retention and Deletion

10.1 Retention Period

Completion Records and associated event data are retained for the retention period configured at the time of record issuance. Retention periods are configured by the Customer based on the Customer's own regulatory or business requirements. Customers are responsible for determining the retention period appropriate to their use and configuring the Platform accordingly.

10.2 Deletion and Anonymization

A Completion Record reaching the end of its retention period, or subject to a valid deletion request, undergoes Disposal. The record is retained and remains verifiable; it no longer identifies the individual who completed the training. Disposal is irreversible once executed.

10.3 Regulatory Holds

Customers are responsible for determining whether any legal or regulatory obligation requires retention of records beyond the standard retention period and for communicating any such requirement to Us before requesting deletion.

11. Termination

11.1 By Customer

Customers may cancel their subscription at any time through the Platform's account management interface. Cancellation takes effect at the end of the current billing period.

11.2 By Kryptomneme LLC

We may suspend or terminate a Customer's access to the Service if the Customer breaches these Terms, fails to pay applicable fees after reasonable notice, or if continued provision of the Service to the Customer would violate applicable law. We will provide reasonable notice where practicable.

11.3 Effect of Termination

Upon termination, the Customer may request a full export of its Tenant Workspace data. Following export (or after a reasonable period if no export is requested), the Tenant Workspace will be marked as terminated. Issued Completion Records remain verifiable through the Platform's verification endpoint for the remainder of the applicable retention period — termination of a subscription does not destroy previously issued records.

12. Disclaimers of Warranty

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE." TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, KRYPTOMNEME LLC DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

WITHOUT LIMITING THE FOREGOING:

(a) WE DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, OR COMPLETELY SECURE.

(b) WE DO NOT WARRANT THAT COMPLETION RECORDS SATISFY ANY PARTICULAR REGULATORY REQUIREMENT. CUSTOMERS ARE SOLELY RESPONSIBLE FOR DETERMINING REGULATORY COMPLIANCE.

(c) WE DO NOT WARRANT THAT THE IDENTITY VERIFICATION MEASURES EMPLOYED BY THE PLATFORM ARE INFALLIBLE. IDENTITY CHECKS ARE SAMPLED, NOT CONTINUOUS.

(d) THE PLATFORM'S SECURITY MEASURES EMPLOY REASONABLE SAFEGUARDS AND INDUSTRY-STANDARD ENCRYPTION FOR DATA IN TRANSIT, BUT NO SYSTEM IS IMMUNE TO ALL THREATS. WE DO NOT REPRESENT OR WARRANT THAT THE PLATFORM IS IMPERVIOUS TO UNAUTHORIZED ACCESS.

(e) WE DO NOT WARRANT THAT ANY INSTRUCTOR OF RECORD REVIEWED THE CONTENT THEY APPROVED, WAS QUALIFIED TO EVALUATE IT, HOLDS ANY CREDENTIAL STATED ALONGSIDE THEIR NAME, OR EXERCISED ANY DEGREE OF CARE. THE PLATFORM RECORDS ATTESTATIONS; IT DOES NOT VERIFY THEM.

13. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL KRYPTOMNEME LLC, ITS OFFICERS, DIRECTORS, MEMBERS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATED TO THE USE OF OR INABILITY TO USE THE SERVICE, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE), EVEN IF KRYPTOMNEME LLC HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

KRYPTOMNEME LLC'S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATED TO THESE TERMS OR THE SERVICE SHALL NOT EXCEED THE GREATER OF (A) THE AMOUNTS PAID BY THE CUSTOMER TO KRYPTOMNEME LLC IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM, OR (B) ONE HUNDRED U.S. DOLLARS ($100).

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES; IN SUCH JURISDICTIONS, KRYPTOMNEME LLC'S LIABILITY IS LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW.

14. Indemnification

Customer agrees to indemnify, defend, and hold harmless Kryptomneme LLC and its officers, directors, members, employees, and agents from and against any claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising out of or related to: (a) the Customer's or its Learners' use of the Service; (b) any violation of these Terms; (c) any claim that the Customer's use of Completion Records constitutes a representation of regulatory compliance not supported by the records themselves; (d) any third-party claim arising from the Customer's training programs or workplace practices; or (e) any content or decision described in Section 6.4.

15. Governing Law and Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of the State of California, without regard to its conflict-of-laws principles. Any dispute arising under these Terms shall be subject to the exclusive jurisdiction of the state and federal courts located in Contra Costa County, California.

16. Changes to These Terms

We may update these Terms at any time. The current version is the one posted at myrecordlocker.com/terms/, and the Effective Date at the top shows when it last changed. Continued use of the Service after that date constitutes acceptance of the revised Terms. If a Customer does not agree to the revised Terms, the Customer's remedy is to cancel the subscription.

17. Miscellaneous

17.1 Entire Agreement

These Terms, together with the Privacy Policy and any applicable DPA, constitute the entire agreement between the Customer and Kryptomneme LLC with respect to the Service.

17.2 Severability

If any provision of these Terms is found to be unenforceable, the remaining provisions will remain in full force and effect.

17.3 Waiver

Failure to enforce any provision of these Terms does not constitute a waiver of that provision or any other provision.

17.4 Assignment

Customer may not assign these Terms without Kryptomneme LLC's prior written consent. Kryptomneme LLC may assign these Terms in connection with a merger, acquisition, or sale of all or substantially all of its assets.

17.5 Force Majeure

Kryptomneme LLC shall not be liable for any failure or delay in performing its obligations under these Terms due to causes beyond its reasonable control, including but not limited to natural disasters, acts of government, internet disruptions, or failures of third-party service providers.

18. Contact Information

For questions, email hello@myrecordlocker.com