Language Model Use and Transparency Disclosure

Consumer Dividends

Effective date: June 14, 2026

Last updated: October 2, 2026

This disclosure explains how our products use language models, what data is processed, and what the outputs are and are not. We publish it so that customers, their clients, and regulators can understand our posture in one document. Hand this to your compliance team, your broker, or your counsel.

1. What our products do

No product we sell uses a language model. Holdings tools are single files that run arithmetic in your browser. There is no model call anywhere in them, at any point.

Holdings tools are deterministic calculators you buy once and run on your own machine. They make no network requests of any kind, which you can confirm yourself in your browser's network panel.

2. What our products do not do

Our products do not make decisions about individuals.

If a deployer of our product chooses to use the output as a substantial factor in an employment-related or consequential decision about an individual, that deployer is responsible for compliance with the laws that apply to that decision, including any disclosure, notice, bias audit, or impact assessment obligations.

3. What data is sent to a language model

None. We have no language model provider, and none is listed in our Subprocessor List. Anything you enter into a Holdings tool never leaves your device at all.

4. Whether your data trains models

No. We do not use the content of your inputs, or any report generated for you, to train, fine-tune, or otherwise improve any model. Your data stays yours.

5. How outputs are produced

Holdings tools apply fixed arithmetic to the figures you enter. The methodology is documented inside each tool, so the same inputs always return the same output and any figure can be traced back to the rule that produced it.

6. Known limitations

7. Bias and fairness

Holdings tools apply the same arithmetic to every input and collect no personal characteristics, so there is no scoring of individuals to audit.

8. Transparency to end users

Because our products do not make decisions about individuals and do not interact directly with employees, applicants, tenants, or buyers, the disclosure obligations that apply to consumer-facing or employee-facing automated decision tools do not directly apply to us. The Connecticut CART Act notice requirements at Section 31-57aa (effective for systems deployed on or after October 1, 2027) apply to deployers using automated decision technology in employment contexts. We are not such a deployer.

We recommend that customers using our products document their use of the products in their own internal records and, where the output will be used in a way that touches an employee or applicant, consider whether their own jurisdiction requires them to disclose that an automated tool informed the work.

9. Where processing happens

Holdings tools process nothing remotely: they run in your browser, on your machine, with no connection at all.

10. Your rights and how to exercise them

You have the right to:

Email support@consumerdividends.com from the address associated with your account.

11. Updates

We update this disclosure when the law changes, when we add a new product, or when our practices change. The "Last updated" date at the top reflects the most recent change.

12. Contact

support@consumerdividends.com

Consumer Dividends, Hawaii, United States.