Rayana
Draft — pending counsel review. This document is a founder-prepared draft for review and is not the effective agreement. Bracketed items are unresolved, and nothing here is legal or investment advice.

Rayana — Terms of Service (DRAFT)

STATUS: FOUNDER-PREPARED DRAFT FOR SECURITIES COUNSEL REVIEW. Milestone 0.1 of SaaS-plan/SAAS_PLAN.md. This document is not legal advice and is not effective until reviewed, redlined, and approved by qualified securities counsel, with bracketed placeholders resolved. Its purpose is to encode the publisher-side, no-personalized-advice posture (see firewall/README.md and research/publisher_model_portfolio_precedent.md) so counsel confirms and refines rather than drafts from scratch.

Two structural design rules counsel should preserve: 1. Liability coverage for all presented information — every representation of no-advice, no-warranty, and limited-liability is drawn to cover all Content, including AI-generated, model/hypothetical, and third-party data. 2. No corner-painting — every no-advice representation is scoped to "the Service" as defined, never to Rayana in perpetuity, and §22 expressly reserves a future separately-registered advisory offering (Phase 6.3). Do not let any redline convert a Service-scoped disclaimer into a company-wide promise.

Last updated: [DATE] · Effective: [DATE]

These Terms of Service ("Terms") are a binding agreement between you ("you," "your," or "Subscriber") and [RAYANA LEGAL ENTITY, LLC], a [Delaware] limited liability company ("Rayana," "we," "us," or "our"), governing your access to and use of the Rayana research website, applications, application programming interfaces, and related content and services (collectively, the "Service").

PLEASE READ THESE TERMS CAREFULLY. They contain important disclaimers about the nature of the Service (Sections 5–6), risk disclosures (Section 7), disclaimers of warranties and limitations of our liability (Sections 18–20), and a binding arbitration agreement and class-action waiver (Section 25) that affect your legal rights.

BY CREATING AN ACCOUNT, CLICKING "I AGREE," OR ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS AND BY THE PRIVACY POLICY AND ANY DISCLAIMERS, EACH INCORPORATED BY REFERENCE. IF YOU DO NOT AGREE, DO NOT USE THE SERVICE.

1. The most important thing to understand first

Rayana is a financial publisher, not an investment adviser, broker-dealer, or fiduciary. The Service delivers general, impersonal research — quantitative scores, rankings, signal breakdowns, model portfolios, market commentary, and automated (AI-generated) analysis — that is the same for every subscriber and is not tailored to you, your holdings, your objectives, or your circumstances.

Nothing on the Service is a recommendation that you buy, sell, or hold any security or asset. The Service does not tell you what to do with your money. You are solely responsible for your own investment decisions, and you should consult your own licensed financial adviser, broker, and tax professional before acting on any information. See Sections 5, 6, and 7. Everything else in these Terms builds on this.

2. Definitions

  • "Content" means all information, data, text, scores, ratings, rankings, signals, model portfolios, charts, analytics, commentary, briefs, and other material made available through the Service, whether generated by Rayana's engine, by automated or artificial-intelligence systems, or sourced from third parties.
  • "Model Portfolio" means an impersonal, hypothetical portfolio curated and published by Rayana and made available identically to all subscribers of the applicable tier, together with any broadcast open / add / hold / trim / exit events associated with it.
  • "Signals" means the individual quantitative or qualitative factor inputs and outputs produced or aggregated by Rayana's engine.
  • "Output" means any Content generated by automated systems, including large-language-model ("LLM") or other artificial-intelligence components (for example, the AI ticker analyst and daily market briefs).
  • "Sandbox" means the optional descriptive paper-trading feature described in Section 6, which reports analytics on hypothetical positions you enter but does not recommend any action.
  • "Free Tier," "Standard," and "Pro" mean the subscription tiers described in Section 12 and on the then-current pricing page.
  • "API" means the application programming interface and any Model Context Protocol ("MCP") endpoint made available to eligible tiers.
  • "Service" is defined in the preamble and, for the avoidance of doubt, does not include any separate service that Rayana or an affiliate may offer in the future under separate terms (see Section 21).

3. Eligibility and accounts

3.1 Age and capacity. You must be at least 18 years old and able to form a binding contract to use the Service.

3.2 Jurisdiction. The Service is offered from the United States and is intended for users located in the United States. We make no representation that the Content is appropriate or available for use in any other jurisdiction, and you are responsible for compliance with local laws.

3.3 No investor-status requirement. Because the Service is an impersonal publication and not personalized advice, it is not conditioned on your being an accredited or qualified investor. This does not make the Content suitable for you; see Section 5.

3.4 Registration. You agree to provide accurate account information, to keep it current, and to keep your credentials confidential. You are responsible for all activity under your account. Notify us promptly of any unauthorized use.

3.5 One account; no sharing. Accounts are personal to you and may not be shared, resold, or used on behalf of others except as expressly permitted for a Pro API plan.

4. The Service (what Rayana provides)

The Service may include, depending on your tier: impersonal ticker scores and rankings; Signal breakdowns; one or more Model Portfolios with broadcast change events; a public and searchable ticker research surface; AI-generated ticker analysis and daily market briefs; pattern, cluster, and rotation overlays; hypothetical / model performance track records; the descriptive Sandbox; a newsletter; and, for eligible tiers, the API and MCP endpoint. Features vary by tier and may change, subject to Sections 22 and 23.

All of the foregoing is Content published on an impersonal, same-for-all basis, except the Sandbox, which reports on hypothetical positions you enter but remains descriptive only (Section 6).

5. Publisher status — no investment advice, no fiduciary relationship

5.1 Rayana is a publisher. Rayana provides the Service as a bona fide publisher of general and impersonal financial information and commentary of regular and general circulation. Rayana is not registered as an investment adviser, broker-dealer, or municipal advisor, and does not act as one in providing the Service.

5.2 The Content is impersonal. All Content, including every score, ranking, Signal, Model Portfolio, and any buy / sell / hold / add / trim / exit designation, is published identically to all subscribers of the applicable tier and is general in nature. It is not based on, conditioned on, or tailored to your individual financial situation, investment objectives, risk tolerance, tax position, existing holdings, or any other personal circumstance.

5.3 Not a recommendation to you; not an offer. No Content is, or should be construed as, (a) personalized investment advice; (b) a recommendation that you buy, sell, or hold any security, asset, or investment strategy; (c) an offer, solicitation, or invitation to buy or sell any security; or (d) an assurance of any particular outcome. Descriptions such as "Strong Buy," "score," "trim," or "exit" refer to impersonal, published ratings and to Rayana's own hypothetical Model Portfolios, not to any action you should take with your own assets.

5.4 No fiduciary or advisory relationship. Your use of the Service does not create an investment-advisory, fiduciary, brokerage, agency, or other special or confidential relationship between you and Rayana. Rayana owes you no duty of suitability, best interest, or care with respect to your investment decisions.

5.5 Your responsibility. You are solely responsible for evaluating the Content and for your own investment, trading, and financial decisions. You should not treat any Content as a substitute for the individualized advice of a licensed financial adviser, broker, attorney, or tax professional, whom you should consult before acting.

5.6 No monitoring of your circumstances. Rayana does not know and does not consider your personal circumstances, and has no obligation to monitor, update, or advise you regarding any Content, security, or Model Portfolio after it is published.

6. The Sandbox is descriptive only — it is not advice

6.1 The Sandbox lets you create a hypothetical ("paper") portfolio, including by cloning a Model Portfolio, and view descriptive analytics about the positions you enter — such as exposure, Greeks, profit-and-loss, and distance-to-target.

6.2 The Sandbox reports; it does not prescribe. The Sandbox describes the characteristics of the hypothetical positions you choose to enter. It does not recommend, direct, or advise you to open, close, increase, reduce, or hold any position, and it does not evaluate whether any position is suitable for you. Any metric the Sandbox displays is a description of a condition, not an instruction to act.

6.3 No personalization of advice. Entering positions into the Sandbox does not cause Rayana to provide you with personalized investment advice, and does not create an advisory or fiduciary relationship. The positions you enter are hypothetical and do not represent actual trades, holdings, or brokerage activity.

7. Assumption of risk and risk disclosures

7.1 Investing involves risk of loss. Trading and investing in securities, options, digital assets, commodities, and other instruments involves substantial risk, including the possible loss of your entire investment. Past performance — including any hypothetical or model performance shown on the Service — does not guarantee or indicate future results.

7.2 You assume all risk. You acknowledge and agree that any action you take based on the Content is taken at your own risk, and that Rayana is not responsible for any trading or investment losses you may incur. See Sections 18–20.

7.3 Instrument-specific risks. Without limiting the foregoing:

  • Options and derivatives (including any Greeks displayed in the Sandbox) involve a high degree of risk, may expire worthless, and can result in losses exceeding the premium paid. You should read the Options Clearing Corporation's Characteristics and Risks of Standardized Options before trading options.
  • Digital assets / cryptocurrency are highly volatile, may be largely unregulated, can lose all value, and may be subject to fraud, custody, and liquidity risks.
  • Commodities and leveraged or futures-based products carry additional volatility, roll, and leverage risks. 7.4 No tax, legal, or accounting advice. The Content is not tax, legal, or accounting advice. Consult your own professionals.

8. Automated and AI-generated Content

8.1 Portions of the Content are Output generated by automated systems, including large-language-model and other artificial-intelligence components (for example, the AI ticker analyst and daily briefs).

8.2 AI Output may be wrong. Such Output may be incomplete, outdated, inaccurate, or entirely incorrect ("hallucinated"), may misstate facts, and is not verified by a human or presented as a statement of fact. It is generated once and served to all subscribers on an impersonal basis. You must not rely on any Output as a statement of fact or as advice, and you should independently verify any information before acting on it. The disclaimers and limitations in Sections 5, 7, and 18–20 apply fully to all Output.

9. Model Portfolios and hypothetical / model performance

9.1 Model Portfolios are hypothetical and impersonal. Each Model Portfolio is a hypothetical portfolio curated by Rayana and published identically to all subscribers of the applicable tier. A Model Portfolio is not a portfolio managed for you, is not advice to replicate it, and does not reflect actual trading in any account.

9.2 Hypothetical-performance disclosure. Any performance figures for a Model Portfolio or Signal are hypothetical and/or based on back-testing unless expressly and prominently identified as actual results. Hypothetical performance has inherent limitations: it is prepared with the benefit of hindsight, does not represent actual trading, does not reflect the impact that market conditions might have had on Rayana's decision-making had Rayana actually been managing money, and generally does not reflect the deduction of fees, commissions, slippage, taxes, or other costs. No representation is made that any account will or is likely to achieve profits or losses similar to those shown. Different assumptions or methods could produce materially different results.

9.3 Forward-looking statements. Scores, rankings, Signals, and commentary are probabilistic and forward-looking in nature and are not predictions or guarantees. Actual events and results may differ materially.

10. Third-party data and content

10.1 The Content incorporates data and materials obtained from third-party sources. Rayana believes such sources to be reliable but does not independently verify them and does not warrant their accuracy, completeness, or timeliness.

10.2 No endorsement. References to any security, issuer, third party, or link do not constitute an endorsement. Third-party content is the responsibility of its provider and may be subject to that provider's own terms and rights.

10.3 Certain third-party data is licensed to Rayana subject to restrictions. You obtain no rights in third-party data except the limited right to use it within the Service as permitted by Section 14. See also Sections 15 and 16 regarding redistribution.

11. Public, delayed, and free content

Some Content (including certain public research pages, a delayed Model Portfolio, and the daily market brief) may be made available publicly or on the Free Tier. Such Content may be delayed, abridged, or less current than paid Content, is provided subject to these Terms, and carries all of the disclaimers herein.

12. Subscriptions, fees, and billing

12.1 Tiers. The Service is offered on a Free Tier and on paid Standard and Pro tiers (and any other tier we may offer), with features and prices described on the then-current pricing page.

12.2 Payment processor. Paid subscriptions are billed through our third-party payment processor (currently Stripe). By subscribing, you authorize us and our processor to charge your payment method, and you agree to the processor's terms. Rayana does not store full payment-card numbers.

12.3 Auto-renewal. Paid subscriptions renew automatically at the end of each billing period (monthly or annual, as selected) at the then-current rate, until you cancel. You authorize recurring charges accordingly.

12.4 Cancellation. You may cancel at any time through your account settings. Cancellation takes effect at the end of the current billing period; you retain access until then.

12.5 Refunds. Except where required by law, fees are non-refundable and partial periods are not prorated.

12.6 Price changes. We may change prices prospectively; we will give notice as required by law before a change takes effect on renewal.

12.7 Taxes. Fees are exclusive of taxes, which you are responsible for.

12.8 Free Tier. The Free Tier is provided "as is," may be rate-limited, and may be changed, limited, or discontinued at any time without liability to you.

13. Acceptable use

You agree not to, and not to permit any third party to:

13.1 access or use the Service other than as expressly permitted, or in violation of any law or regulation, including securities laws (for example, you may not use the Content in furtherance of market manipulation, insider trading, or any fraudulent or manipulative scheme);

13.2 scrape, crawl, harvest, or bulk-download Content except through the API as expressly permitted for your tier;

13.3 reproduce, redistribute, resell, sublicense, publish, broadcast, or otherwise make available any Content, Signal, score, Output, or Model Portfolio to any third party, or use it to build or feed a competing product or dataset (see Sections 15–16);

13.4 reverse engineer, decompile, or attempt to derive the source code, models, weights, or methodology underlying the Service, except to the extent this restriction is prohibited by law;

13.5 circumvent or interfere with rate limits, entitlements, paywalls, security, or usage controls, or access the Service through another person's account;

13.6 introduce malware, overload or disrupt the Service, or attempt unauthorized access to any system or data;

13.7 use the Service to provide investment advice or a competing advisory or newsletter service to third parties, or represent that Rayana has endorsed or is responsible for your use.

We may suspend or terminate access for any violation (Section 24).

14. License to you

Subject to your compliance with these Terms and payment of applicable fees, Rayana grants you a limited, revocable, non-exclusive, non-transferable, non-sublicensable license to access and use the Service and Content for your own personal, internal, non-commercial use (or, for a Pro API plan, for the internal business use expressly described in Section 17). No other rights are granted.

15. Intellectual property

15.1 The Service and all Content — including the Rayana engine, scoring and Signal methodologies, Model Portfolios, software, text, graphics, and the compilation and arrangement thereof — are owned by Rayana or its licensors and are protected by intellectual-property laws. "Rayana" and related marks are our trademarks.

15.2 Except for the limited license in Section 14, all rights are reserved. You acquire no ownership in any Content, Signal, score, Output, or Model Portfolio.

16. Your content and feedback

16.1 Your inputs. You retain ownership of information you submit (for example, search queries and hypothetical Sandbox positions). You grant Rayana a worldwide, royalty-free license to host, process, and use such inputs to operate, secure, and improve the Service, and as further described in Section 17 and the Privacy Policy.

16.2 Feedback. If you send us suggestions or feedback, you grant Rayana a perpetual, irrevocable, royalty-free license to use it without restriction or obligation to you.

17. Data license and consent (Milestone 0.3)

17.1 Consent to use of usage and derived data. You acknowledge and agree that Rayana may collect, process, de-identify, aggregate, and analyze data arising from your use of the Service — including search activity (which may contribute to Rayana's orca_search signal), feature usage, and other interaction and device data — and may use such data on an anonymized and/or aggregated basis for any lawful business purpose, including to operate, secure, analyze, and improve the Service and to create, derive, publish, license, and sell aggregated or anonymized data products, insights, and signals.

17.2 De-identification. Data used under Section 17.1 for external data products will be aggregated and/or de-identified so that it does not identify you. Rayana will not sell data that identifies you personally except as described in the Privacy Policy and permitted by law.

17.3 Survival. This license is granted so that Rayana's present and future data-related offerings do not require re-consent, and it survives termination of your account with respect to data already collected. This Section is subject to the Privacy Policy, which governs personal information; if the two conflict as to personal information, the Privacy Policy controls.

18. API and MCP terms (eligible tiers)

18.1 If your tier includes API or MCP access, Rayana grants you a limited, non-exclusive, non-transferable right to call the API for your own internal use, subject to the documented rate limits, scopes, and entitlements for your tier.

18.2 No redistribution of underlying data. You may not use the API to redistribute, resell, sublicense, or expose Content, Signals, scores, Output, or underlying third-party or source data to third parties, to cache or store it beyond what the documentation permits, or to build a competing or derivative dataset or product. Rayana may modify, deprecate, throttle, or discontinue any API or endpoint.

18.3 Your API credentials are confidential and you are responsible for all use under them.

19. Disclaimer of warranties

THE SERVICE AND ALL CONTENT ARE PROVIDED "AS IS" AND "AS AVAILABLE," WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED BY LAW, RAYANA AND ITS LICENSORS AND SUPPLIERS DISCLAIM ALL WARRANTIES, EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE.

WITHOUT LIMITING THE FOREGOING, RAYANA DOES NOT WARRANT THAT: (a) THE CONTENT (INCLUDING ANY SCORE, SIGNAL, MODEL PORTFOLIO, OUTPUT, OR THIRD-PARTY DATA) IS ACCURATE, COMPLETE, RELIABLE, CURRENT, OR ERROR-FREE; (b) THE CONTENT WILL PRODUCE ANY PARTICULAR INVESTMENT RESULT OR PROFIT, OR AVOID LOSS; OR (c) THE SERVICE WILL BE UNINTERRUPTED, SECURE, OR FREE OF HARMFUL COMPONENTS. ANY RELIANCE ON THE CONTENT IS AT YOUR SOLE RISK.

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES, SO SOME OF THE ABOVE MAY NOT APPLY TO YOU.

20. Limitation of liability

20.1 No liability for investment or trading losses. TO THE MAXIMUM EXTENT PERMITTED BY LAW, RAYANA AND ITS AFFILIATES, AND THEIR RESPECTIVE OFFICERS, MEMBERS, EMPLOYEES, AGENTS, LICENSORS, AND SUPPLIERS (THE "RAYANA PARTIES"), WILL NOT BE LIABLE FOR ANY TRADING OR INVESTMENT LOSSES, LOST PROFITS, OR LOST OPPORTUNITY, OR FOR ANY DECISION YOU MAKE OR ACTION YOU TAKE IN RELIANCE ON THE CONTENT.

20.2 Exclusion of indirect damages. IN NO EVENT WILL THE RAYANA PARTIES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF DATA, GOODWILL, OR PROFITS, ARISING OUT OF OR RELATED TO THE SERVICE OR THESE TERMS, WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR OTHERWISE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

20.3 Liability cap. THE RAYANA PARTIES' TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATED TO THE SERVICE OR THESE TERMS WILL NOT EXCEED THE GREATER OF (a) THE TOTAL FEES YOU PAID TO RAYANA FOR THE SERVICE IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (b) US $100.

20.4 Basis of the bargain; carve-outs. THE LIMITATIONS IN THIS SECTION ARE A FUNDAMENTAL BASIS OF THE BARGAIN AND APPLY EVEN IF A REMEDY FAILS OF ITS ESSENTIAL PURPOSE. SOME JURISDICTIONS DO NOT ALLOW CERTAIN LIMITATIONS, SO PARTS MAY NOT APPLY TO YOU. NOTHING IN THESE TERMS LIMITS LIABILITY THAT CANNOT BE LIMITED BY LAW.

21. Indemnification

You will indemnify, defend, and hold harmless the Rayana Parties from and against any claims, liabilities, damages, losses, and expenses (including reasonable attorneys' fees) arising out of or related to: (a) your use of the Service or the Content; (b) your investment, trading, or financial decisions; (c) your violation of these Terms or any law or third-party right; or (d) your redistribution or misuse of any Content in violation of Sections 13, 15, or 18.

22. Reservation of future and separate services (no corner-painting)

22.1 These Terms govern only the Service as defined. All representations that the Service is impersonal and does not constitute investment advice are statements about the Service as currently defined in these Terms, and are not representations about Rayana, its affiliates, or any other service.

22.2 Future offerings reserved. Rayana and its affiliates may in the future develop and offer additional, different, or separately branded products and services — including personalized, advisory, or managed services — which may require registration as an investment adviser or other licensure and which may be provided by Rayana or by a separate affiliated entity. Any such offering will be governed by separate terms and, where applicable, separate advisory agreements and disclosures, and is not part of, and does not alter the character of, the Service governed by these Terms.

22.3 No waiver of the distinction. Nothing in these Terms shall be construed to prevent Rayana or an affiliate from lawfully offering such a separate registered or advisory service in the future, nor to characterize the current Service as anything other than impersonal publishing.

23. Changes to the Service

Rayana may modify, add, suspend, or discontinue any part of the Service (including any feature, Model Portfolio, Signal, or tier) at any time. We will use reasonable efforts to notify you of material adverse changes to a paid feature. Your continued use after a change constitutes acceptance, subject to Section 26.

24. Term and termination

24.1 These Terms apply while you use the Service. You may stop using the Service and cancel at any time (Section 12.4).

24.2 We may suspend or terminate your access, with or without notice, for any violation of these Terms, for suspected unlawful use, or as necessary to protect the Service or other users; and we may discontinue the Service as provided in Section 23.

24.3 Survival. Sections 2, 5–10, 15–22, and 25–26, and any accrued payment obligations and data licenses granted under Section 17, survive termination.

25. Governing law; arbitration; class-action waiver

25.1 Governing law. These Terms are governed by the laws of the State of [Delaware / __], without regard to conflict-of-laws principles, and, where applicable, the Federal Arbitration Act and federal securities laws.

25.2 Informal resolution. Before filing a claim, you agree to contact us at [[email protected]] and attempt to resolve the dispute informally for at least 30 days.

25.3 Binding arbitration. Except as provided below, any dispute arising out of or relating to these Terms or the Service will be resolved by final and binding arbitration administered by [AAA / JAMS] under its rules, on an individual basis, seated in [__].

25.4 Class-action waiver. You and Rayana each waive any right to bring or participate in a class, collective, or representative action. Disputes will be resolved only on an individual basis.

25.5 Opt-out. You may opt out of arbitration by notifying us within 30 days of first accepting these Terms, as described at [opt-out link/address].

25.6 Injunctive relief. Either party may seek injunctive relief in court to protect intellectual-property rights.

26. General

26.1 Changes to these Terms. We may update these Terms. We will post the updated Terms with a new "Last updated" date and, for material changes, provide reasonable notice. Continued use after the effective date constitutes acceptance; if you do not agree, stop using the Service.

26.2 Entire agreement. These Terms, the Privacy Policy, and any tier-specific or API terms are the entire agreement between you and Rayana regarding the Service and supersede prior agreements on that subject.

26.3 Severability. If any provision is held unenforceable, it will be limited or severed to the minimum extent necessary, and the remaining provisions remain in effect.

26.4 No waiver. Our failure to enforce any provision is not a waiver.

26.5 Assignment. You may not assign these Terms without our consent; we may assign them to an affiliate or successor.

26.6 Force majeure. Rayana is not liable for delays or failures caused by events beyond its reasonable control, including data-source, market-data, or infrastructure outages.

26.7 Notices. We may provide notices via the Service or to your account email. Send legal notices to [[email protected]] / [mailing address].

26.8 Relationship. Nothing in these Terms creates a partnership, joint venture, agency, or — as stated in Section 5 — advisory or fiduciary relationship.

26.9 Contact. Questions about these Terms: [[email protected]].

Companion documents: PRIVACY_POLICY.md (to be drafted, 0.1), disclaimer copy for display surfaces (0.1), and the signal-source licensing matrix (0.4, which constrains what may be redistributed under Sections 13, 15, and 18). See SAAS_PLAN.md §0 and Phase 0, and firewall/README.md for the architectural counterpart to Sections 5–6.

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