Use of the Platform, including the various Content and services provided or to be provided therein, is subject to the terms and conditions detailed in the following Terms of Use. By using the Platform, the user agrees to these terms and conditions and undertakes to act accordingly.

1. Definitions

1.1 In these Terms of Use, the following terms shall have the meanings set forth below:

• 1.1.1 “Platform” – The “42” applications and websites, including but not limited to the website located at https://42port.com and its Android and iOS native mobile applications.
• 1.1.2 “Platform Operator” or “Company” – 42 Port Financial Technologies, Inc. Wherever the term “Company” appears herein, it shall also refer to the Platform, its employees, contractors providing services to the Company and/or the Platform, officers, and any person acting in the capacity of or on behalf of the Company or the Platform.
• 1.1.3 “User” or “Visitor” – Any user or visitor of any kind, including individuals or legal entities such as companies, associations, partnerships, using the Platform directly or through their representatives, employees, or third parties acting on their behalf.
• 1.1.4 “Terms” – These Terms of Use, as most recently updated and published on the Platform.
• 1.1.5 "Content" – Includes all types of information and media, including textual, visual, audio, audiovisual Content, such as text, images, sound, video, across any current or future media or device, including their design, processing, editing, distribution, and presentation, and including (but not limited to): illustrations, animations, diagrams, characters, simulations, samples, clips, music files, software, computer files, applications, formats, protocols, databases, interfaces, symbols, icons, etc.
• 1.1.6 “User Content” – Any content uploaded to the Platform by users and published in areas designated for user input, whether separately or alongside Company content, as determined by the Platform Operator.
• 1.1.7 “Commercial Content” – Any content provided by advertisers or third parties, including users, for marketing or sales purposes, including ads, banners, and similar items, subject to agreements between the Company and the advertisers.
• 1.1.8 “Sponsored Content” – Commercial Content that may include opinions or qualitative information about securities, marked with a distinct color and including the sponsor’s name clearly.
• 1.1.9 “Deep Link” – A hyperlink directing to specific pages or Content within a site, excluding the homepage.

2. Purpose of the Platform

2.1 The Platform serves, among other purposes, as a platform for financial discourse. It allows users to read and upload various Content, including comments, discussion forums, surveys, polls, ratings, pricing, and similar Content.

3. Disclaimer: Not Investment Advice

THE CONTENT AND INFORMATION PROVIDED ON THE PLATFORM IS FOR INFORMATIONAL AND EDUCATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE INVESTMENT ADVICE, FINANCIAL ADVICE, TRADING ADVICE, OR ANY OTHER SORT OF ADVICE. 42 PORT FINANCIAL TECHNOLOGIES, INC. IS NOT A REGISTERED INVESTMENT ADVISOR, BROKER-DEALER, OR MEMBER OF FINRA OR ANY SECURITIES REGULATORY ORGANIZATION. YOU SHOULD NOT MAKE ANY DECISION, FINANCIAL, INVESTMENT, TRADING OR OTHERWISE, BASED ON ANY OF THE INFORMATION PRESENTED ON THE PLATFORM WITHOUT UNDERTAKING INDEPENDENT DUE DILIGENCE AND CONSULTATION WITH A PROFESSIONAL FINANCIAL ADVISOR.

3.1 AI-Generated Content and Algorithmic Analysis

3.1.1 The Platform utilizes artificial intelligence (AI), machine learning algorithms, and automated systems to analyze publicly available information, generate content, provide scoring assessments, and deliver insights about market events and securities.

3.1.2 AI Limitations: AI-generated scores, assessments, analyses, and content are automated outputs that may contain errors, inaccuracies, biases, incomplete information, or outdated data. Machine learning models are trained on historical data and patterns that may not predict future market behavior. These AI-generated outputs are NOT recommendations to buy, sell, or hold any security.

3.1.2.1 AI Hallucinations and False Information: Artificial intelligence systems, including large language models and machine learning algorithms, can generate information that appears plausible but is completely false, inaccurate, or fabricated (commonly known as "AI hallucinations"). You acknowledge and agree that:

• AI-generated content may contain factual errors, fictional events, or invented data that appears credible;
• AI systems may confidently present false information as fact;
• AI-generated analyses, scores, or insights may be based on flawed reasoning or incorrect assumptions;
• You must independently verify all AI-generated information before relying on it for any purpose;
• The Company is not liable for decisions you make based on AI-generated content;
• AI outputs should never be the sole basis for investment, financial, or legal decisions.

3.1.2.2 No Accuracy Guarantee: The Company makes no representations or warranties regarding the accuracy, completeness, reliability, or suitability of any AI-generated content. AI systems are probabilistic by nature and may produce different outputs for similar inputs. Use all AI-generated content at your own risk.

3.1.3 Data Sources and Delays: Information provided on the Platform is derived from third-party data sources that we believe to be reliable, but we do not independently verify their accuracy, completeness, or timeliness. Market data may be delayed or subject to reporting errors. Real-time data may not be available for all securities or markets. The Company is not responsible for errors or omissions in third-party data.

3.1.3.1 Stock Price Data Delay: The Platform may display stock quotes including ticker symbols, current prices, price changes, and percentage changes (for example: "AAPL $255.41 +2.97% +7.37"). During regular market trading hours, all stock price data displayed on the Platform is delayed by fifteen (15) minutes. Stock prices shown are not real-time quotes and should not be relied upon for time-sensitive trading decisions. After market hours, stock prices may reflect the closing price or may continue to show delayed data. The Company does not provide real-time stock quotes.

3.1.4 No Performance Guarantee: Past performance of our AI models, algorithms, or any scoring system does not guarantee future accuracy, reliability, or results. The performance of securities mentioned on the Platform is not indicative of future performance. Markets are inherently unpredictable, and AI systems cannot account for all variables affecting securities prices.

3.1.5 User Responsibility: You acknowledge that investing in securities involves substantial risk of loss, and you are solely responsible for evaluating the risks and merits of any investment decision. You should conduct your own research and consult with qualified financial professionals before making any investment decisions.

3.2 Regulatory Status and Limitations

3.2.1 Not a Broker-Dealer or Investment Advisor: 42 Port Financial Technologies, Inc. is not a registered broker-dealer, investment advisor, financial planner, or member of the Financial Industry Regulatory Authority (FINRA), the Securities and Exchange Commission (SEC), or any other securities regulatory organization. We do not execute securities transactions, provide custody services, manage investment portfolios, or offer personalized investment advice tailored to your individual circumstances, objectives, or risk tolerance.

3.2.2 No Order Flow Compensation: The Company does not receive payment for order flow, does not direct users to specific brokers or trading platforms, and does not receive compensation from broker-dealers based on user trading activity or account openings.

3.2.3 Information Only: All content, analysis, scores, and information provided on the Platform are for informational and educational purposes only. We provide tools to help you research and understand market events, but we do not recommend specific investment actions. Any mention of specific securities, companies, or investment strategies is purely educational and does not constitute a recommendation.

3.2.4 Conflicts of Interest: The Company, its officers, employees, contractors, or affiliates may hold positions in securities mentioned or analyzed on the Platform. We may have business relationships with companies whose securities are discussed on the Platform. Such relationships or positions do not influence our AI algorithms but represent potential conflicts of interest of which you should be aware.

3A. U.S. Regulatory Compliance

3A.1 Federal Securities Laws

3A.1.1 Securities Act Compliance: The Platform does not offer, sell, or distribute securities as defined under the Securities Act of 1933. We do not facilitate securities transactions, operate as an exchange, or provide a marketplace for the purchase or sale of securities. All references to securities on the Platform are for informational and educational purposes only.

3A.1.2 Exchange Act Compliance: The Company is not a broker-dealer registered with the Securities and Exchange Commission (SEC) under the Securities Exchange Act of 1934. We do not effect transactions in securities, receive transaction-based compensation, or provide recommendations for specific securities transactions. We do not maintain custody of customer funds or securities.

3A.1.3 Investment Advisers Act: The Company is not a registered investment adviser under the Investment Advisers Act of 1940 and does not provide investment advisory services. We do not provide personalized investment advice, financial planning services, or portfolio management. The content provided on the Platform is general in nature and is not tailored to any individual's specific financial situation, investment objectives, or risk tolerance.

3A.1.4 Investment Company Act: The Company is not an investment company as defined under the Investment Company Act of 1940 and does not engage in the business of investing, reinvesting, or trading in securities.

3A.1.5 Publisher's Exclusion: The Company operates as a publisher of financial information and commentary. Under Section 202(a)(11)(D) of the Investment Advisers Act, publishers of bona fide newspapers, news magazines, or business/financial publications of general and regular circulation are excluded from the definition of "investment adviser." The Platform provides generalized financial information and market commentary to the public and does not provide investment advice tailored to individual subscribers' needs.

3A.2 Anti-Fraud and Market Manipulation Provisions

3A.2.1 Rule 10b-5 Compliance: The Company does not engage in any manipulative or deceptive practices in connection with the purchase or sale of securities. We do not make untrue statements of material fact or omit material facts necessary to make statements not misleading. All content is provided in good faith based on available information.

3A.2.2 Prohibition on Pump and Dump: The Company and its employees, officers, and contractors are strictly prohibited from engaging in "pump and dump" schemes, market manipulation, or any fraudulent practices. Users are also prohibited from using the Platform to manipulate securities prices, spread false information, or engage in any unlawful trading practices.

3A.2.3 No Front Running: The Company does not engage in front-running, insider trading, or any trading practices based on non-public information about Platform content or user activity.

3A.3 State Securities Laws (Blue Sky Laws)

3A.3.1 State Law Compliance: The Platform's operations comply with applicable state securities laws. As a publisher of general financial information, we do not provide investment advice or effecuate securities transactions that would require state-level registration.

3A.3.2 Multi-State Operations: The Platform is accessible to users across all U.S. states and territories. Users are responsible for complying with their own state securities laws and regulations when making investment decisions.

3A.4 Federal Trade Commission (FTC) Compliance

3A.4.1 Truth in Advertising: All advertising and promotional content on the Platform complies with FTC regulations and guidelines. We do not make false, misleading, or deceptive claims. Material connections, sponsorships, and paid endorsements are clearly disclosed.

3A.4.2 Endorsement Disclosures: Any testimonials, reviews, or endorsements on the Platform reflect the honest opinions of the individuals providing them. Material connections between the Company and endorsers are disclosed in accordance with FTC guidelines.

3A.4.3 Substantiation: Claims made on the Platform regarding performance, capabilities, or benefits are substantiated by adequate evidence. We do not make claims that cannot be supported by factual data.

3A.5 Consumer Protection Laws

3A.5.1 Electronic Signatures (ESIGN Act): Electronic signatures, contracts, and records created through the Platform are valid and enforceable under the Electronic Signatures in Global and National Commerce Act (ESIGN Act, 15 U.S.C. § 7001 et seq.) and the Uniform Electronic Transactions Act (UETA). By using the Platform, you consent to conduct transactions electronically and to receive notices, disclosures, and other communications electronically.

3A.5.2 CAN-SPAM Act: All commercial email communications sent by the Company comply with the Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM Act). Our emails include:

• Accurate header information and subject lines
• Clear identification of the message as an advertisement (when applicable)
• Valid physical postal address of the sender
• Clear and conspicuous opt-out mechanisms
• Prompt processing of opt-out requests (within 10 business days)

3A.5.3 Telephone Consumer Protection Act (TCPA): If the Platform sends promotional text messages (SMS/MMS), we comply with the TCPA. We obtain prior express written consent before sending marketing messages, provide clear opt-out instructions, and honor opt-out requests promptly. Message and data rates may apply.

3A.5.4 Restore Online Shoppers' Confidence Act: For subscription services, we comply with the Restore Online Shoppers' Confidence Act by:

• Clearly and conspicuously disclosing all material terms of the subscription before obtaining billing information
• Obtaining express informed consent before charging consumers
• Providing simple cancellation mechanisms
• Sending confirmation notifications for recurring charges

3A.6 Data Protection and Privacy Laws

3A.6.1 Federal Privacy Compliance: The Company complies with applicable federal privacy laws, including the Gramm-Leach-Bliley Act (GLBA) to the extent applicable, and other federal data protection requirements.

3A.6.2 State Privacy Laws: We comply with state-specific privacy laws, including:

• California: California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) as detailed in Section 21.9
• Virginia: Virginia Consumer Data Protection Act (VCDPA)
• Colorado: Colorado Privacy Act (CPA)
• Connecticut: Connecticut Data Privacy Act (CTDPA)
• Utah: Utah Consumer Privacy Act (UCPA)
• Other state privacy laws as applicable

3A.7 Anti-Money Laundering (AML) and Know Your Customer (KYC)

3A.7.1 Limited Applicability: As the Company does not handle customer funds, execute securities transactions, or operate as a financial institution, we are not subject to Bank Secrecy Act (BSA), AML, or KYC requirements applicable to financial institutions and broker-dealers.

3A.7.2 Suspicious Activity: Notwithstanding the above, if we become aware of suspicious activity that may indicate money laundering, terrorist financing, or other illegal activities, we reserve the right to report such activity to appropriate law enforcement authorities and to terminate user accounts.

3A.8 Intellectual Property Laws

3A.8.1 Copyright Law: The Platform complies with the Digital Millennium Copyright Act (DMCA) as detailed in Section 13.5. We respect copyright holders' rights and respond to valid takedown notices.

3A.8.2 Trademark Law: We comply with the Lanham Act and federal trademark laws. We do not infringe on others' trademarks and enforce our own trademark rights.

3A.9 Communications Laws

3A.9.1 Telecommunications Act: To the extent the Platform utilizes telecommunications services or infrastructure, we comply with the Communications Act of 1934, as amended by the Telecommunications Act of 1996.

3A.9.2 Section 230 Protection: The Company operates as a provider of interactive computer services under 47 U.S.C. § 230 (Section 230 of the Communications Decency Act). We are not liable as the publisher or speaker of user-generated content posted on the Platform. Section 230 protects us from liability for third-party content, though we may remove content or terminate accounts at our discretion.

3A.10 Export Control and Economic Sanctions

3A.10.1 OFAC Compliance: The Company complies with U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctions programs. We do not provide services to individuals or entities on OFAC sanctions lists or in sanctioned jurisdictions.

3A.10.2 Export Administration Regulations: We comply with the Export Administration Regulations (EAR) administered by the U.S. Department of Commerce and do not export controlled technology or software to prohibited parties or destinations.

3A.11 Accessibility

3A.11.1 Americans with Disabilities Act (ADA): The Company is committed to ensuring digital accessibility for people with disabilities. We strive to make the Platform accessible to all users and continuously work to improve the accessibility of our services.

3A.11.2 WCAG Standards: We aim to conform to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards. If you experience accessibility issues, please contact us using the contact information provided in Section 22.

3A.12 Regulatory Changes

3A.12.1 Evolving Regulations: Financial services and technology regulations are continually evolving. The Company monitors regulatory developments and updates its practices to maintain compliance with applicable laws.

3A.12.2 User Compliance: Users are solely responsible for complying with all federal, state, and local laws applicable to their use of the Platform and any investment or trading activities they undertake based on information obtained from the Platform.

3A.12.3 No Legal Advice: Nothing in these Terms or on the Platform constitutes legal, tax, or accounting advice. Users should consult with appropriate professionals regarding their specific legal and regulatory obligations.

3A.13 Regulatory Inquiries and Cooperation

3A.13.1 Government Cooperation: The Company cooperates fully with regulatory authorities, including the SEC, FINRA, FTC, state securities regulators, and other government agencies. We respond promptly to regulatory inquiries and legal process.

3A.13.2 Regulatory Reporting: We maintain records and provide reports to regulatory authorities as required by applicable laws and regulations.

3A.14 Limitations on Liability for Regulatory Compliance

3A.14.1 User Responsibility: You acknowledge that you are solely responsible for ensuring that your use of the Platform complies with all applicable federal, state, and local laws and regulations, including securities laws, tax laws, and other financial regulations.

3A.14.2 No Liability for User Violations: The Company is not liable for any violations of law committed by users or for any consequences arising from users' failure to comply with applicable legal requirements.

3A.14.3 Indemnification for Regulatory Violations: You agree to indemnify the Company for any losses, damages, fines, penalties, or costs arising from your violation of applicable securities laws, regulations, or other legal requirements.

4. Right to Use the Platform

4.1 The Company invites users to use the Platform for fair, good-faith personal and private purposes only, subject to the terms below and applicable law.

4.2 Commercial use of the Platform, excluding the publication of approved commercial or sponsored Content, is strictly prohibited without prior written approval from the Company.

4.3 These Terms apply to all uses of the Platform, including their services and Content. Certain areas or services on the Platform may be subject to additional specific terms.

4.4 These Terms apply regardless of the device or medium used to access the Platform, or the user’s location (USA or elsewhere).

4.5 By accessing the Platform, the user confirms their agreement to the Terms of Use, regardless of whether they have read them in full.

4.6 Any use beyond these Terms is prohibited unless expressly authorized in writing by the Company. Unauthorized use grants the Company full legal remedies.

4.7 If financial Content is sourced from the US Stock Exchanges or any global exchange or external Platform, such use is also subject to the source's terms and conditions, including applicable securities regulations.

4.8 Age Requirement: You must be at least 18 years of age to use the Platform. By agreeing to these Terms, you represent and warrant that you are at least 18 years old.

4A. User Representations and Warranties

4A.1 Acceptance Authority: You represent and warrant that:

• You have the legal capacity and authority to enter into these Terms and to form a binding agreement under applicable law;
• If you are accepting these Terms on behalf of a company or legal entity, you have the authority to bind that entity to these Terms;
• You are at least 18 years of age or the age of majority in your jurisdiction, whichever is greater;
• Your use of the Platform does not violate any applicable laws or regulations;
• All information you provide to the Company is accurate, complete, and current;
• You will maintain the accuracy of such information throughout your use of the Platform.

4A.2 Compliance Representations: You represent and warrant that:

• You are not located in, organized under the laws of, or a resident of any country or region subject to U.S. trade sanctions or embargoes;
• You are not listed on any U.S. government list of prohibited, sanctioned, or restricted parties;
• You will comply with all applicable federal, state, and local laws in your use of the Platform;
• You will not use the Platform for any unlawful purpose or in violation of these Terms;
• You are not a competitor of the Company using the Platform for competitive research or product development;
• If you are a registered investment adviser, broker-dealer, or other regulated financial professional, you will comply with all applicable professional and regulatory obligations in your use of the Platform.

4A.3 No Prohibited Activities: You represent and warrant that you will not:

• Engage in any activity that constitutes securities fraud, market manipulation, or insider trading;
• Use the Platform to facilitate or promote any illegal activities;
• Interfere with or disrupt the integrity or performance of the Platform;
• Attempt to gain unauthorized access to the Platform or its systems;
• Violate the intellectual property rights of the Company or any third party;
• Impersonate any person or entity or misrepresent your affiliation with any person or entity;
• Collect or harvest information about other users without their consent;
• Use automated systems to access the Platform except as expressly permitted;
• Post or transmit any viruses, malware, or other harmful code.

4A.4 Professional User Obligations: If you are a securities industry professional, including but not limited to a registered investment adviser, broker-dealer representative, financial planner, or employee of a financial institution, you additionally represent and warrant that:

• Your use of the Platform complies with all rules and regulations applicable to your profession, including FINRA rules, SEC regulations, and state securities laws;
• You will not use information from the Platform to provide investment advice to clients without conducting your own independent due diligence;
• You understand that the Platform's content is not sufficient for making client recommendations;
• You will not represent that the Company endorses or approves of any investment recommendations you make;
• You will maintain appropriate records of your use of the Platform as required by your regulatory obligations.

4A.5 Breach of Representations: You acknowledge that the Company has relied on your representations and warranties in providing you access to the Platform. Any breach of these representations and warranties constitutes a material breach of these Terms and may result in immediate termination of your account and legal action.

5. Platform Registration

5.1 Certain services on the Platform require registration. These services will be available after completing the registration process, providing the requested details, and agreeing to the accompanying online terms and conditions.

5.2 Registration is open to any individual and is free of charge, subject to completing the registration process as detailed. Free accounts provide limited access to Platform content. Full access to all Platform content requires a paid subscription as described in Section 5A below.

5.3 During registration, users must provide personal information such as name, contact details, and email address. Required fields will be clearly marked. Failure to provide required information will prevent access to registration-required services.

5.4 Users must provide accurate, complete, and truthful information and confirm its accuracy. Inaccurate information may prevent access to services and obstruct communication. Users must update their details online if changes occur.

5.5 Registration data will be stored in the Company’s database. The Company may use this data as described in these Terms.

5.6 Users will be required to choose an email and password for identification. The Company may establish additional or alternative identification methods. Users must keep credentials confidential and update passwords regularly, at least once every six months.

5.6.1 Account Security Obligations: You are solely responsible for maintaining the confidentiality and security of your account credentials, including your email address and password. You agree to:

• Choose a strong, unique password that is not used for other services;
• Not share your password with any other person or entity;
• Not allow any other person to access your account or use your credentials;
• Immediately notify the Company if you suspect any unauthorized access to or use of your account;
• Log out of your account at the end of each session when using shared or public devices;
• Enable two-factor authentication if offered by the Platform.

5.6.2 Account Sharing Strictly Prohibited: Sharing your account, credentials, or subscription with any other person is strictly prohibited and constitutes a material breach of these Terms. Each subscription is for a single user identified by a unique email address and password. The Company employs technical measures to detect account sharing, and accounts found to be shared may be immediately terminated without refund.

5.6.3 Liability for Unauthorized Use: You are fully responsible for all activities that occur under your account, whether or not authorized by you. The Company is not liable for any loss or damage arising from your failure to maintain account security. You agree to indemnify the Company for any losses resulting from unauthorized use of your account that results from your failure to maintain adequate security.

5.6.4 Account Credentials as Confidential Information: Your account credentials are confidential proprietary information of the Company. Sharing credentials may constitute misappropriation of trade secrets and could result in civil and criminal liability.

5.7 Users may not register with more than one email address without legitimate business purposes approved by the Company.

5.7.1 Multiple Account Restrictions: Creating multiple accounts to circumvent subscription limitations, abuse free trials, or evade account restrictions or terminations is strictly prohibited. The Company reserves the right to link and merge accounts, terminate all associated accounts, and pursue legal remedies for such violations.

5.8 The Company may deny access to registration-based services at its discretion, including in the following cases:

• False information was provided during registration.
• Actions that harm or may harm the Platform or third parties.
• Use of the Platform to perform or facilitate illegal activities.
• Breach of these Terms or any other Platform agreement.
• Preventing others from accessing or enjoying services.
• Sharing credentials with third parties.
• Outstanding unpaid debt to the Company or its affiliates.

5.9 Registration through social networks may be offered.

5.10 User Account Termination: You may terminate your account at any time by contacting us via the contact methods provided on the Platform.

5.11 Inactive Accounts:

5.11.1 Dormancy Period: If your account remains inactive (no login or usage) for twelve (12) consecutive months, the Company may designate your account as dormant and may take the following actions:

• Send notification to your registered email address;
• Restrict access to certain features;
• Delete user-generated content, bookmarks, or preferences;
• Archive or delete the account entirely after providing reasonable notice.

5.11.2 Reactivation: You may reactivate a dormant account by logging in, provided the account has not been deleted. The Company is not obligated to restore any data that was deleted during the dormancy period.

5.11.3 Subscriptions and Dormancy: If you have an active paid subscription, your account will not be considered dormant, and normal billing will continue regardless of usage. It is your responsibility to cancel subscriptions you no longer wish to maintain.

5A. Subscription and Payment Terms

5A.1 Subscription Plans

5A.1.1 Free Account: Users who register for a free account will have limited access to the Platform's content. The free account allows users to view a limited number of market news events and other content as determined by the Company at its sole discretion. The Company reserves the right to modify the limitations of free accounts at any time without prior notice.

5A.1.2 Paid Subscription: Users who purchase a paid subscription will have full, unrestricted access to all content available on the Platform, including unlimited access to market news events, analyses, scores, and all other features and content offered by the Platform.

5A.2 Nature of Subscription

5A.2.1 Content Access Only: The paid subscription grants access to the Platform's informational and educational content only. THE SUBSCRIPTION IS NOT FOR THE PURPOSE OF:

• Buying or selling equities, securities, or any other financial instruments;
• Executing trades or securities transactions;
• Receiving personalized investment advice or financial recommendations;
• Portfolio management services;
• Broker-dealer services or any regulated financial services.

All content provided through the paid subscription remains informational and educational in nature, as described in Section 3 of these Terms.

5A.3 Payment Methods

5A.3.1 Accepted Payment Methods: Subscription payments are processed exclusively through platform-native payment systems:

• For Android App Users: Payments are processed through Google Play Store using Google Play Billing (which may include Google Pay and other payment methods accepted by Google Play).
• For iOS App Users: Payments are processed through Apple App Store using Apple's In-App Purchase system (which may include Apple Pay and other payment methods accepted by the App Store).

5A.3.2 No Alternative Payment Methods: The Company does not accept payments through credit cards directly, Stripe, PayPal, bank transfers, or any other payment processors or methods outside of the Google Play Store (for Android) and Apple App Store (for iOS). All subscription transactions must be conducted through the respective app store's payment infrastructure.

5A.3.3 App Store Terms: Your subscription and payment are also governed by the applicable app store's terms of service (Google Play Terms of Service or Apple Media Services Terms and Conditions). You acknowledge that the app store provider, not the Company, is responsible for processing your payment and handling billing-related inquiries.

5A.4 Subscription Periods and Pricing

5A.4.1 Available Plans: The Platform offers the following subscription options:

• Monthly Subscription: A subscription that renews automatically on a monthly basis.
• Annual Subscription: A subscription that renews automatically on an annual (yearly) basis.

5A.4.2 Pricing: Current subscription pricing is displayed in the Platform (mobile app) prior to purchase and in your respective app store. Prices are subject to change at the Company's discretion. If you have an active subscription, price changes will apply upon your next renewal period after notice of the change.

5A.4.3 Automatic Renewal: All subscriptions automatically renew at the end of each subscription period (monthly or annually) unless canceled prior to the renewal date. You will be charged the then-current subscription fee for the renewal period through your app store account.

5A.4.4 Per-User Subscription: Each subscription is tied to a single user account identified by a unique email address and password. A subscription may not be shared with, transferred to, or used by any other person or user account. Each individual user must maintain their own separate subscription.

5A.5 Cancellation and Refunds

5A.5.1 Cancellation Timing: You may cancel your subscription at any time through your app store account settings (Google Play Store or Apple App Store). Upon cancellation:

• Monthly Subscriptions: Your cancellation will take effect at the end of the current monthly billing period. You will retain full access to paid content until the end of that month.
• Annual Subscriptions: Your cancellation will take effect at the end of the current annual billing period. You will retain full access to paid content until the end of that year.

5A.5.2 No Partial Refunds: Cancellation does not result in a refund for the current subscription period. You will continue to have access to paid features through the end of your current billing cycle, but you will not be charged for subsequent periods.

5A.5.3 Refund Requests: All refund requests must be directed to the applicable app store (Google Play Store or Apple App Store) in accordance with their refund policies. The Company does not process refunds directly. Refunds, if any, are at the sole discretion of the app store provider and subject to their terms and policies.

5A.5.4 Effect of Cancellation: After your subscription expires (at the end of the billing period following cancellation), your account will revert to a free account with limited access as described in Section 5A.1.1. Your account data and settings will be preserved, and you may resubscribe at any time to regain full access.

5A.6 Subscription Management

5A.6.1 Account Responsibility: You are responsible for managing your subscription, including monitoring your subscription status, renewal dates, and cancellation. The Company is not responsible for charges resulting from your failure to cancel a subscription you no longer wish to maintain.

5A.6.2 App Store Controls: To view, modify, or cancel your subscription, you must access your subscription settings through:

• Google Play Store (Android): Open the Google Play Store app → Menu → Subscriptions → Select 42 → Manage or Cancel
• Apple App Store (iOS): Open Settings → [Your Name] → Subscriptions → Select 42 → Cancel Subscription

5A.6.3 Subscription Information: Your current subscription status, type (monthly or annual), and next billing date can be viewed within the Platform (mobile app) and in your respective app store account.

5A.7 Suspension and Termination by Company

5A.7.1 Right to Terminate: The Company reserves the right to suspend or terminate your subscription and access to the Platform at any time if you violate these Terms, engage in fraudulent activity, abuse the Platform, or for any other reason at the Company's sole discretion.

5A.7.2 No Refund Upon Termination: If the Company terminates your subscription due to your breach of these Terms or other misconduct, you will not be entitled to any refund of subscription fees paid.

5A.8 Free Trials and Promotional Offers

5A.8.1 Availability: The Company may, at its sole discretion, offer free trial periods or promotional discounts for paid subscriptions. Such offers are subject to specific terms and conditions that will be communicated at the time of the offer.

5A.8.2 Trial Conversion: If you sign up for a free trial, your subscription will automatically convert to a paid subscription at the end of the trial period unless you cancel before the trial expires. You will be charged the applicable subscription fee through your app store account upon conversion.

5A.8.3 Eligibility: Free trials and promotional offers may be limited to new subscribers only or subject to other eligibility requirements. The Company reserves the right to determine eligibility and to revoke access if fraud or abuse is detected.

5A.8.4 One Trial Per User: Free trials are limited to one trial per user, per email address, per device, and per payment method. Creating multiple accounts or using different email addresses to obtain multiple free trials is strictly prohibited and constitutes fraud.

5A.8.5 Abuse Prevention: The Company employs technical measures to detect and prevent free trial abuse, including but not limited to:

• Tracking device identifiers, IP addresses, and payment methods;
• Linking accounts suspected of being created by the same individual;
• Requiring payment method verification before trial access is granted;
• Immediately terminating accounts and subscriptions suspected of abuse;
• Pursuing legal action and charging the full subscription amount for fraudulent use.

5A.8.6 No Trial Stacking: You may not combine multiple promotional offers or extend trial periods by canceling and re-subscribing. Previous trial users are not eligible for subsequent trials or promotional offers unless explicitly stated.

5A.9 Changes to Subscription Terms

5A.9.1 Right to Modify: The Company reserves the right to modify subscription pricing, plans, features, or these subscription terms at any time. We will provide advance notice of material changes in accordance with Section 20 of these Terms.

5A.9.2 Acceptance of Changes: Your continued use of a paid subscription after such changes take effect constitutes your acceptance of the modified terms and pricing. If you do not agree to the changes, you may cancel your subscription as described in Section 5A.5.

5B. Tax Obligations

5B.1 User Tax Responsibility: You are solely responsible for determining and paying any and all taxes, duties, levies, or charges of any nature (including income taxes, capital gains taxes, sales taxes, use taxes, and value-added taxes) that may be assessed on your use of the Platform, your subscription payments, or any investment or trading activities you conduct based on information obtained from the Platform.

5B.2 No Tax Advice: The Company does not provide tax advice and does not provide tax reporting services. Nothing on the Platform should be construed as tax advice. You should consult with a qualified tax professional regarding your specific tax obligations.

5B.3 Subscription Fees and Sales Tax: Subscription fees charged through the Google Play Store or Apple App Store may be subject to applicable sales tax, use tax, value-added tax (VAT), or similar taxes as determined by the app store provider and your jurisdiction. The Company does not control or collect these taxes; they are collected by the respective app store.

5B.4 Investment Tax Obligations: If you make investment or trading decisions based on information from the Platform, you are solely responsible for:

• Maintaining accurate records of your transactions;
• Reporting investment income, capital gains, or losses to tax authorities;
• Paying all applicable taxes on investment income and gains;
• Complying with all tax reporting requirements in your jurisdiction.

5B.5 No Tax Reporting by Company: The Company does not issue tax forms (such as IRS Form 1099) to users because we do not facilitate securities transactions or maintain custody of funds. You must obtain tax documents from your broker or financial institution where your actual trading activity occurs.

5B.6 International Tax Obligations: If you are located outside the United States, you are responsible for complying with all tax laws and reporting requirements in your country of residence, including any obligations related to foreign account reporting or foreign income.

5B.7 Tax Indemnification: You agree to indemnify and hold harmless the Company from any claims, liabilities, penalties, or expenses (including legal fees) arising from your failure to pay taxes or comply with tax reporting obligations.

6. Links to the Platform

6.1 The Platform is not responsible for services provided on external websites linked to it or displayed in advertisements.

6.2 Deep linking to Platform content is prohibited unless the link is to a full, unmodified web page.

6.3 Linking directly to individual Content (e.g., images or graphics) is strictly prohibited. Complete webpage addresses must be displayed in the browser's address bar and not altered or hidden.

6.4 Linking to the Platform from sites containing pornographic, discriminatory, illegal, or otherwise unlawful Content is strictly prohibited.

7. Links from the Platform

7.1 The Platform includes links to third-party internet pages. These are provided for convenience only, and the Company has no control over their Content.

7.2 The presence of a link does not imply endorsement, reliability, accuracy, legality, or any responsibility. Use of such Content is at the user's own risk.

7.3 Users may find linked Content inappropriate, offensive, or objectionable. The Company is not liable for such Content or consequences arising from its use.

7.4 The Company does not guarantee that links on the Platform are valid or active, and may remove or refrain from adding links at its sole discretion.

8. User Content – Restrictions, Rights, and Responsibilities

8.1 The Platform contains areas designated for user content, including user opinions, commentary, and analysis. Such Content is considered User Content and is subject to these Terms.

8.2 Publishing content requires prior registration.

8.3 Users shall not be entitled to any compensation from the Company or others for Content they publish.

8.4 Users must declare that published Content is accurate and in good faith and does not violate any laws.

8.5 Responsibility for user-generated Content lies solely with the user who created it.

8.6 The Company does not review, verify, or endorse User Content and bears no responsibility for its accuracy, legality, or source.

8.7 User Content may include personal opinions, including reviews of individuals, products, or events, which do not reflect the Company's views.

8.8 Prohibited Content includes, but is not limited to, false information, copyright infringement, pornography, Content involving minors, viruses, unauthorized access to data, defamation, harassment, hate speech, illegal encouragements, deceptive advertising, or any content violating laws or third-party rights.

• Providing or promoting personalized investment advice, or impersonating a licensed financial advisor.
• Promoting "pump and dump" schemes, spreading false rumors, or engaging in any other form of market manipulation.

8.8.1 Prohibition on Investment Advice by Users: Users are strictly prohibited from providing personalized investment advice or recommendations through the Platform. This prohibition includes:

• Recommending specific securities for purchase or sale to other users;
• Providing advice tailored to another user's specific financial situation;
• Holding yourself out as a financial advisor, investment adviser, or broker-dealer when you are not licensed;
• Offering portfolio management services or asset allocation advice;
• Providing recommendations for compensation or consideration;
• Posting content that could be construed as investment advice under securities laws.

8.8.2 Permitted Educational Content: Users may share general educational information, personal opinions about markets or securities (clearly labeled as personal opinion), analysis or research (not recommendations), and questions seeking information. All such content must include prominent disclaimers that it is not investment advice and must not be personalized to specific individuals.

8.8.3 Market Manipulation Prohibition: Users are strictly prohibited from:

• Posting false or misleading information intended to manipulate securities prices;
• Coordinating with others to artificially inflate or deflate stock prices;
• Engaging in "pump and dump" or "short and distort" schemes;
• Spreading rumors or unsubstantiated claims about securities;
• Making statements designed to create artificial trading volume;
• Failing to disclose material conflicts of interest (e.g., owning securities being discussed);
• Posting with intent to profit from others' reliance on false information.

8.8.4 Enforcement and Reporting: The Company actively monitors user content for violations of securities laws and these prohibitions. Users can report suspected violations using the reporting tools within the Platform. The Company cooperates with securities regulators and law enforcement in investigating suspected market manipulation or unauthorized investment advice. Violations may result in immediate account termination, reporting to regulatory authorities (SEC, FINRA, state regulators), and potential civil and criminal liability.

8.8.5 Professional Licensing Verification: If you hold yourself out as a financial professional, you may be required to verify your licenses and credentials. Impersonating a licensed professional is prohibited and may constitute fraud.

8.9 Users may not impersonate others or use the platform for unauthorized commercial purposes.

8.10 Publishing Commercial or Sponsored Content must comply with the rules outlined in these Terms and be clearly disclosed as such.

8.11 The Company assumes no responsibility for Content published by users, including reliance upon or consequences from such Content.

8.12 Submitting Content grants the Company a global, royalty-free, perpetual license to use, distribute, edit, and publish the Content.

8.13 Users waive any claims for damages arising from deletion or modification of Content.

8.14 Feedback and Suggestions:

8.14.1 Voluntary Submission: You may, from time to time, provide feedback, suggestions, ideas, comments, improvements, or recommendations (collectively, "Feedback") regarding the Platform, its features, or our services. All Feedback is voluntary and unsolicited.

8.14.2 License Grant: By submitting Feedback, you grant the Company a worldwide, perpetual, irrevocable, royalty-free, fully paid-up, transferable, sublicensable license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, publicly perform, and publicly display such Feedback in any form, format, media, or medium now known or later developed, without any obligation to compensate you.

8.14.3 No Obligation: The Company has no obligation to:

• Review, consider, or implement any Feedback;
• Maintain Feedback in confidence;
• Pay or reimburse you for any Feedback;
• Respond to or acknowledge receipt of Feedback;
• Credit you for Feedback that is implemented.

8.14.4 No Ownership or Rights: You acknowledge and agree that:

• Submission of Feedback does not establish any confidential, fiduciary, or other special relationship between you and the Company;
• The Company may already be developing or considering similar ideas;
• You are not entitled to any compensation, attribution, or other consideration for your Feedback;
• The Company may use Feedback for any purpose, including incorporating it into the Platform or other products;
• You waive any moral rights or other rights of attribution you may have in the Feedback.

8.14.5 Warranties on Feedback: You represent and warrant that your Feedback:

• Is original to you and does not infringe any third-party rights;
• Does not contain confidential or proprietary information belonging to others;
• Does not violate any law or contractual restriction;
• Is provided without expectation of compensation or consideration.

9. Commercial Content – Restrictions, Rights, and Responsibilities

9.1 The Platform may include advertisements and commercial Content submitted by third parties.

9.2 The Company is not responsible for commercial Content or any outcomes from its use.

9.3 The Company does not verify the accuracy of such advertisements.

9.4 By registering or purchasing via the Platform, users consent to receive promotional messages unless they opt out.

9.5 Advertisements do not constitute endorsements by the Company.

9.6 Transactions arising from commercial Content are strictly between users and advertisers. The Company is not a party to such transactions.

9.7 Trademarks and advertisements are the property of their respective owners.

9.8 Advertising services may use cookies and web beacons to track user behavior. Their use is governed by their own privacy policies.

9.9 The Company may remove or change advertisements at any time.

9.10 Sponsored Content answering user questions may be subject to investment advisory laws. The Company is not responsible for this Content.

10. Company Involvement in Content Delivery and Editing

10.1 The Company will not edit User Content submitted in response to specific questions, except for general factual data.

10.2 The Company does not guarantee responses or engagement with Content submitted.

10.3 The Company may refuse to publish or remove Content at its sole discretion without notice or explanation.

10.4 Users should not rely on the Platform to store unique Content.

10.5 The Platform does not replace licensed investment advisory services.

10.6 The Company may disclose user identity or data under specific legal or protective circumstances.

10.7 Some content is provided by third parties and is offered "as is." Users should not rely exclusively on such Content.

10.8 The Company may modify or terminate Platform services or Content at its discretion.

10.9 The Company disclaims liability for misuse of Platform content.

11. User Use of Content

11.1 Use of the Platform and its Content is solely at the user's risk.

11.2 Users waive claims against the Company regarding content functionality or consequences of use.

11.3 Users may not copy, share, or republish Platform content for commercial or public use without prior permission.

11.4 Prohibited Data Extraction and Automated Access: The use of automated tools, including but not limited to robots, crawlers, scrapers, spiders, bots, or any automated means to access, monitor, copy, or extract data or content from the Platform is strictly prohibited without prior written authorization from the Company. This prohibition includes:

• Screen scraping or automated extraction of any Platform content or data;
• Use of any automated system to access the Platform in a manner that sends more requests to our servers than a human could reasonably produce in the same period;
• Circumventing or attempting to circumvent any technological measures implemented to prevent automated access;
• Reverse engineering, decompiling, or disassembling any software, algorithms, or systems used by the Platform;
• Creating derivative databases or datasets from Platform content;
• Reselling, redistributing, or providing access to Platform data to any third party;
• Using Platform data to train competing AI models or machine learning systems;
• Interfering with or disrupting the Platform's servers, networks, or security measures.

11.4.1 API Usage: If the Company provides authorized API access, such use is subject to separate API terms and conditions, including rate limits, access restrictions, and acceptable use policies. Violation of API terms may result in immediate suspension of access.

11.4.2 Enforcement: Violation of these restrictions may result in immediate termination of your account, legal action, and liability for damages, including costs and attorneys' fees. We reserve the right to employ technological measures to detect and prevent unauthorized automated access.

11.5 Framing Platform content is not allowed.

11.6 Users may not alter or conceal Platform content or layout, including advertisements.

11.7 Economic content is not financial advice. Users assume full responsibility for decisions made based on Content.

11.8 Content is not tailored financial or investment advice and is not a substitute for professional judgment.

11.9 The Platform does not provide personalized financial or pension advice or investment recommendations.

12. Use of Content by the Company

12.1 The Company may, but is not obligated to, store or retain Content published on the Platform.

12.2 The Platform may employ software that collects and analyzes data regarding user activity to improve services. Use of the Platform constitutes consent to such collection. The data may be stored and used for future decision-making about services.

12.3 The Company reserves the right to use any content in any manner it deems appropriate, including commercial use, distribution, publication, or transfer to third parties, without user compensation.

12.4 The Company and its stakeholders may have an interest in the Content or financial assets displayed on the Platform or linked platforms.

12.5 The Company and its stakeholders may hold securities, including those mentioned on the Platform.

13. Intellectual Property

13.1 All copyrights and intellectual property rights in the Platform, its services, and all Content (including but not limited to software, algorithms, AI models, designs, text, graphics, logos, icons, images, audio clips, data compilations, and the overall look and feel of the Platform) are owned by the Company or by third parties who have authorized the Company to use their Content.

13.2 Users may not copy, reproduce, distribute, publicly display, perform, transmit, alter, process, create derivative works from, sell, lease, sublicense, reverse engineer, decompile, or disassemble any content or service, in any format or medium, without prior written permission from the Company.

13.3 Where permission is granted, users must not remove or alter any intellectual property notices, including copyright or trademark symbols, attached to the Content.

13.4 Trademark Usage

The name "42", "42 Port Financial Technologies", and all related logos, product and service names, designs, and slogans are trademarks of the Company or its affiliates. You may not use these trademarks without our prior written permission. All other trademarks, service marks, and logos used on the Platform are the property of their respective owners.

13.5 Digital Millennium Copyright Act (DMCA) Notice

13.5.1 Copyright Infringement Claims: We respect the intellectual property rights of others and expect our users to do the same. If you believe that content on the Platform infringes your copyright, please provide our designated Copyright Agent with the following information in writing:

• A physical or electronic signature of the copyright owner or person authorized to act on behalf of the owner;
• Identification of the copyrighted work claimed to have been infringed;
• Identification of the material that is claimed to be infringing, with sufficient detail to allow us to locate it on the Platform;
• Your contact information, including address, telephone number, and email address;
• A statement that you have a good faith belief that use of the material is not authorized by the copyright owner, its agent, or the law;
• A statement, made under penalty of perjury, that the information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner's behalf.

Our designated Copyright Agent can be reached through the contact information provided on the Platform.

13.5.2 Counter-Notification: If you believe that content you posted was removed or disabled in error or misidentification, you may file a counter-notification containing:

• Your physical or electronic signature;
• Identification of the material that was removed and its location before removal;
• A statement under penalty of perjury that you have a good faith belief the material was removed by mistake or misidentification;
• Your name, address, telephone number, and a statement consenting to jurisdiction in the federal court for the judicial district of your address (or Delaware if outside the U.S.), and that you will accept service of process from the complaining party.

13.5.3 Repeat Infringer Policy: The Company will terminate, in appropriate circumstances, the accounts of users who are repeat infringers of intellectual property rights.

14. Limitation of Liability and Indemnity

14.1 Limitation of Liability

14.1.1 DISCLAIMER OF CONSEQUENTIAL DAMAGES: TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL THE COMPANY, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, AFFILIATES, OR LICENSORS BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE PLATFORM, INCLUDING BUT NOT LIMITED TO:

• Lost profits, trading losses, or investment losses;
• Loss of revenue, business, or anticipated savings;
• Loss of data, business opportunity, or goodwill;
• Damages resulting from reliance on any information, analysis, scores, or AI-generated content provided on the Platform;
• Damages resulting from delayed, inaccurate, incomplete, or unavailable data or information;
• Damages resulting from Platform downtime, interruption of service, or technical malfunctions;
• Damages resulting from failure of notifications, alerts, or any communication systems;
• Damages resulting from errors, inaccuracies, or omissions in third-party data;
• Damages resulting from unauthorized access to or alteration of your transmissions or data;
• Any other damages arising from the use or inability to use the Platform;

EVEN IF THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION MAY NOT APPLY TO YOU.

14.1.2 CAP ON LIABILITY: TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE COMPANY'S TOTAL LIABILITY TO YOU FOR ANY AND ALL CLAIMS ARISING OUT OF OR RELATED TO THESE TERMS OR YOUR USE OF THE PLATFORM, WHETHER IN CONTRACT, TORT, OR OTHERWISE, SHALL NOT EXCEED THE GREATER OF: (A) THE TOTAL AMOUNT YOU PAID TO THE COMPANY IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO LIABILITY, OR (B) ONE HUNDRED DOLLARS ($100).

14.1.3 Trading and Investment Losses: The Company is not liable for any losses incurred from investment or trading decisions made based on information, analysis, scores, or content provided on the Platform. You acknowledge that securities trading involves substantial risk and that past performance does not guarantee future results.

14.1.4 Third-Party Content and Services: The Company is not responsible for the accuracy, reliability, or availability of any third-party data, content, or services, including but not limited to market data providers, analytics services, or any external platforms or services linked from or integrated with the Platform.

14.2 User Indemnification

14.2.1 You agree to defend, indemnify, and hold harmless the Company, its officers, directors, employees, agents, affiliates, and licensors from and against any and all claims, damages, obligations, losses, liabilities, costs, and expenses (including reasonable attorneys' fees and costs) arising from or related to:

• Your use or misuse of the Platform;
• Your breach of these Terms;
• Your violation of any law, regulation, or third-party rights;
• Any Content you submit, post, or transmit through the Platform;
• Any investment or trading decisions you make based on Platform information;
• Your negligence, willful misconduct, or violation of applicable securities laws;
• Any dispute between you and any third party arising from your use of the Platform.

14.2.2 This indemnification obligation will survive termination of these Terms and your use of the Platform. The Company reserves the right to assume exclusive defense and control of any matter subject to indemnification by you, in which case you agree to cooperate with the Company's defense of such claim.

15. Platform Availability and Security

15.1 The Company does not guarantee the continuous availability of the Platform or their services and may discontinue them at any time.

15.2 Use of the Platform is subject to risks inherent in internet-based systems, including malware, hacking, eavesdropping, and data breaches. The Company takes security measures but cannot ensure absolute protection and shall not be liable for damages resulting from such risks.

15.3 Software offered for download on the Platform is used at the user's own risk. The Company and software providers are not responsible for resulting damages.

15.4 The Company may modify the structure, design, availability, or any aspect of the Platform without prior notice. Users shall not have any claim related to such changes or resulting malfunctions.

15A. Beta and Experimental Features

15A.1 Availability of Beta Features: The Company may, from time to time, offer features, functionalities, or services that are in beta, testing, preview, early access, or experimental stages (collectively, "Beta Features"). Beta Features may be clearly labeled as "Beta," "Preview," "Experimental," "Alpha," "Test," or similar designations.

15A.2 No Warranties for Beta Features: Beta Features are provided on an "as-is" and "as-available" basis without any warranties or guarantees of any kind. Beta Features may:

• Contain bugs, errors, or defects;
• Not function as intended or expected;
• Cause errors, crashes, or data loss;
• Be incomplete or lack full functionality;
• Be changed, modified, or removed at any time without notice;
• Never be released as final production features;
• Perform slower or less reliably than production features.

15A.3 Use at Your Own Risk: You acknowledge that Beta Features are experimental and may not be suitable for production use or critical decision-making. You use Beta Features entirely at your own risk and agree not to rely on them for important financial, investment, or business decisions.

15A.4 No Liability for Beta Features: The Company shall have no liability whatsoever for any damages, losses, or issues arising from your use of or reliance on Beta Features. All disclaimers and limitations of liability in these Terms apply with full force to Beta Features.

15A.5 Feedback on Beta Features: If you provide feedback on Beta Features, such feedback is governed by Section 8.14 (Feedback and Suggestions). The Company may use your feedback to improve or modify Beta Features without compensation or attribution to you.

15A.6 Data Collection for Beta Features: When you use Beta Features, the Company may collect additional usage data, error reports, and performance metrics to improve the features. Such data collection is governed by our Privacy Policy.

15A.7 Discontinuation of Beta Features: The Company may discontinue, modify, or remove Beta Features at any time without notice or liability. You acknowledge that Beta Features may never become generally available features.

15A.8 No Service Level Agreements: Beta Features are not subject to any service level agreements, uptime guarantees, or support commitments.

16. Governing Law, Arbitration, and Class Action Waiver

16.1 Governing Law: These Terms and any dispute or claim arising out of or in connection with them shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law provisions.

16.2 Binding Arbitration: You and the Company agree that any dispute, claim, or controversy arising out of or relating to these Terms or the breach, termination, enforcement, interpretation, or validity thereof, or the use of the Platform (collectively, "Disputes") will be resolved by binding arbitration, except that each party retains the right to bring an individual action in small claims court and the right to seek injunctive or other equitable relief in a court of competent jurisdiction to prevent the actual or threatened infringement, misappropriation, or violation of a party's copyrights, trademarks, trade secrets, patents, or other intellectual property rights.

16.3 Arbitration Rules: The arbitration will be administered by the American Arbitration Association ("AAA") in accordance with the Consumer Arbitration Rules (the "AAA Rules") then in effect, except as modified by this "Dispute Resolution" section. (The AAA Rules are available at www.adr.org or by calling the AAA at 1-800-778-7879.) The Federal Arbitration Act will govern the interpretation and enforcement of this section.

16.3.1 Arbitration Fees and Costs:

• Payment of Fees: The party initiating the arbitration shall pay the initial filing fee. If the Company initiates arbitration, we will pay all arbitration filing fees. If you initiate arbitration, you will pay the consumer filing fee established by the AAA (currently limited based on claim amount).
• Company Payment: If your claim is for $10,000 or less, the Company will pay all other AAA arbitration fees (including arbitrator fees) unless the arbitrator determines your claim was frivolous or brought for an improper purpose.
• Claims Over $10,000: For claims exceeding $10,000, fees will be allocated according to the AAA Rules.
• Attorney Fees: Each party is responsible for its own attorney fees and costs unless a statute or the arbitrator awards attorney fees to the prevailing party. If you prevail on a claim for which you are legally entitled to attorney fees, you may seek to recover those fees from the arbitrator.
• Fee Waiver: If you cannot afford to pay the arbitration fees, you may request that the Company pay them by providing a declaration of inability to pay to the Company and the AAA.

16.3.2 Arbitration Location: If you reside in the United States, arbitration will take place in your county of residence or another mutually agreed location. Arbitration may be conducted by telephone, video conference, based on written submissions, or in person as determined by the arbitrator.

16.3.3 Arbitrator Powers and Limitations: The arbitrator shall have the power to award any relief that would be available in court, including monetary damages, declaratory relief, and injunctive relief. However, the arbitrator may not award relief exceeding the individual party's actual damages and may not award punitive or exemplary damages except where permitted by statute. The arbitrator's award shall be in writing and include the reasons for the award.

16.4 CLASS ACTION WAIVER: YOU AND THE COMPANY AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. Further, unless both you and the Company agree otherwise, the arbitrator may not consolidate more than one person's claims, and may not otherwise preside over any form of a representative or class proceeding.

16.5 30-Day Opt-Out Right: You have the right to opt-out and not be bound by the arbitration and class action waiver provisions set forth in sections 16.2, 16.3, and 16.4 by sending written notice of your decision to opt-out to the contact address provided on our Platform. The notice must be sent within thirty (30) days of your first use of the Platform, otherwise you shall be bound to arbitrate disputes in accordance with the terms of those sections. If you opt-out of these arbitration provisions, the Company also will not be bound by them.

16.6 The competent courts in the State of Delaware shall hold exclusive jurisdiction for any legal matter not subject to arbitration as described above, or to enforce an arbitration award.

17. Bookmarks

17.1 The Platform may offer a feature allowing registered Users to bookmark specific Content, such as market news events, for future reference ("Bookmarks").

17.2 The Company will make a reasonable effort to retain saved Bookmarks, but does not guarantee their availability or accuracy. This feature is provided as-is, for convenience only, and Users should not rely on it as a sole source of record-keeping. The Company shall not be liable for the loss, deletion, or unavailability of any Bookmarks and reserves the right to modify, limit, or discontinue the bookmarking feature at its sole discretion, with or without notice.

17A. Third-Party Service Providers

17A.1 Use of Third-Party Services: The Platform utilizes various third-party service providers to deliver, maintain, and improve our services. These providers may include, but are not limited to:

• Cloud hosting and infrastructure providers;
• Payment processing services;
• Authentication and identity verification services;
• Market data and financial information providers;
• Analytics and performance monitoring services;
• Push notification and communication services;
• Database and data storage services;
• Content delivery networks;
• Customer support and communication tools.

17A.2 Third-Party Responsibilities: These third-party providers operate independently and are not under the direct control of the Company. Each provider is responsible for its own services, data handling practices, security measures, and compliance with applicable laws. Your use of the Platform may be subject to the terms of service and privacy policies of these third-party providers.

17A.3 No Endorsement: The Company's use of third-party service providers does not constitute an endorsement of their services for independent use. We select providers we believe to be reputable, but we do not guarantee their performance, security, or availability.

17A.4 Data Sharing: By using the Platform, you acknowledge and consent to the sharing of your information with third-party service providers to the extent necessary for them to perform services on our behalf. Such sharing is conducted in accordance with our Privacy Policy and applicable data protection laws.

17A.5 Third-Party Liability: The Company is not liable for any acts, omissions, errors, or failures of any third-party service provider, including but not limited to data breaches, service interruptions, inaccurate data, payment processing errors, or any other failures in third-party services. Your sole remedy for any issues with third-party services may be limited to those remedies available from the third-party provider directly.

17A.6 Market Data Providers: Financial market data provided on the Platform, including stock quotes (ticker symbols, prices, price changes, and percentage changes), is sourced from third-party data providers. Stock price data is delayed by fifteen (15) minutes during market trading hours and is not provided in real-time. This data may be subject to additional terms and conditions imposed by those providers, including restrictions on redistribution and commercial use. Market data may be delayed, may contain errors, and is provided "as is" without warranty of any kind. The Company does not independently verify the accuracy or completeness of market data. Users acknowledge that delayed data should not be used for time-sensitive trading decisions.

17A.7 Payment Processing: Payment processing services for subscriptions are provided by Google Play Store (for Android users) or Apple App Store (for iOS users). The Company does not directly process payments, store payment card information, or have access to your full payment details. All payment transactions are subject to the applicable app store's terms of service and privacy policy. The Company is not responsible for payment processing errors, delays, or security breaches occurring within the app store's payment systems. All billing inquiries and refund requests should be directed to the respective app store.

17A.8 Changes to Providers: The Company reserves the right to change, add, or discontinue any third-party service provider at any time without notice. Such changes may affect the functionality, features, or performance of the Platform.

18. Notifications

18.1 As part of the Service, the Platform may send Users service-related or promotional push notifications to their mobile device.

18.2 Users may manage their notification preferences and opt-in or opt-out of receiving such notifications. Users acknowledge that the primary method for controlling push notifications is through their mobile device's operating system settings (e.g., iOS or Android).

18.3 The User is solely responsible for configuring and maintaining their device's local settings to ensure the proper display and receipt of notifications. The Company is not responsible for any failure to receive notifications due to the User's device settings, mobile carrier network, or other factors outside the Company's reasonable control.

18A. Communications and Recording

18A.1 Recording of Communications: The Company may record, monitor, or store communications between you and the Company, including but not limited to:

• Customer support telephone calls;
• Live chat sessions;
• Email correspondence;
• In-app messages;
• Video calls or conferences;
• Voice messages or audio communications.

18A.2 Purpose of Recording: Communications may be recorded for the following purposes:

• Quality assurance and training;
• Compliance with legal and regulatory requirements;
• Dispute resolution and record-keeping;
• Fraud prevention and security;
• Service improvement and analytics;
• Verification of instructions or agreements.

18A.3 Consent to Recording: By using the Platform and communicating with the Company, you expressly consent to the recording, monitoring, and storage of your communications. If you do not consent to being recorded, you should not communicate with us via channels that may be recorded, or you should notify us at the beginning of the communication.

18A.4 State-Specific Notice: If you are located in a jurisdiction that requires two-party consent for recording (such as California, Florida, Illinois, Maryland, Massachusetts, Montana, New Hampshire, Pennsylvania, or Washington), we will provide you with notice before recording begins. Your continued participation in the communication after receiving notice constitutes your consent.

18A.5 Retention of Recordings: Recorded communications may be retained for as long as necessary for the purposes stated above or as required by law. Recordings are subject to our Privacy Policy.

18A.6 Access to Recordings: You may request access to recordings of your communications with the Company by contacting us using the information in Section 23. We will provide access to the extent required by applicable law and subject to verification of your identity.

18A.7 No Recording by Users: You may not record communications with the Company without providing prior notice and obtaining consent. Unauthorized recording of Company personnel or communications may violate wiretapping laws and result in criminal and civil liability.

19. Newsletter

19.1 The Company may offer an electronic newsletter (the "Newsletter") to which Users may subscribe. By subscribing, the User consents to receive the Newsletter at the email address provided during registration or at subscription.

19.2 The User may unsubscribe from the Newsletter at any time by following the "unsubscribe" instructions provided in every Newsletter email or by contacting the Company.

19.3 The Company retains sole discretion over the content, frequency, and timing of any Newsletters it may choose to publish and send.

19A. Warranty Disclaimers

19A.1 "AS IS" AND "AS AVAILABLE" BASIS: THE PLATFORM, INCLUDING ALL CONTENT, SERVICES, FEATURES, SOFTWARE, AI ALGORITHMS, DATA, AND INFORMATION PROVIDED THROUGH OR IN CONNECTION WITH THE PLATFORM, IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED.

19A.2 DISCLAIMER OF ALL WARRANTIES: TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO:

• Implied Warranties: Any implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, or arising from course of dealing or usage of trade;
• Accuracy and Reliability: Any warranty that the Platform, content, data, or information will be accurate, complete, current, reliable, or error-free;
• Availability: Any warranty that the Platform will be available, accessible, uninterrupted, timely, secure, or operate without delays, errors, or defects;
• Data Integrity: Any warranty that data transmitted through the Platform will be secure, uncorrupted, or free from viruses, malware, or other harmful components;
• Results: Any warranty regarding the results, outcomes, or consequences of using the Platform or relying on its content;
• Third-Party Content: Any warranty regarding the accuracy, reliability, or legality of third-party content, data, or services;
• AI and Algorithms: Any warranty that AI-generated content, scores, analyses, or algorithmic outputs will be accurate, unbiased, complete, or suitable for any particular purpose.

19A.3 NO GUARANTEE OF PERFORMANCE: The Company does not warrant or guarantee that:

• The Platform will meet your requirements or expectations;
• The Platform will be compatible with all devices, browsers, or operating systems;
• Any defects, errors, or bugs in the Platform will be corrected;
• The Platform or its servers are free from viruses or other harmful components;
• Data or information obtained through the Platform will lead to profitable investment or trading decisions;
• Market data will be real-time, accurate, or free from delays;
• Notifications, alerts, or other communications will be delivered timely or at all.

19A.4 FINANCIAL MARKETS DISCLAIMER: The Company makes no warranties or representations regarding securities markets, market conditions, price movements, trading volumes, or any other aspect of financial markets. Securities trading involves substantial risk, and past performance does not guarantee future results.

19A.5 USER RESPONSIBILITY: You acknowledge that your use of the Platform is at your sole risk and that you are solely responsible for any damage to your device, loss of data, or any other loss resulting from your use of the Platform. You assume full responsibility for implementing sufficient procedures and safeguards to satisfy your requirements for data accuracy and backup.

19A.6 JURISDICTIONAL VARIATIONS: Some jurisdictions do not allow the exclusion of certain warranties or limitations on applicable statutory rights of a consumer. If these laws apply to you, some or all of the above exclusions or limitations may not apply, and you may have additional rights.

19A.7 SOFTWARE UPDATES: The Company may, but is not obligated to, provide updates, upgrades, bug fixes, or modifications to the Platform. Any such updates are provided "as is" without warranty and may introduce new features, remove existing features, or change functionality without notice.

19B. Force Majeure

19B.1 Excused Performance: The Company shall not be liable for any failure or delay in performing its obligations under these Terms if such failure or delay is due to circumstances beyond its reasonable control (a "Force Majeure Event").

19B.2 Force Majeure Events Include:

• Acts of God, including natural disasters, earthquakes, floods, storms, hurricanes, fires, or epidemics;
• War, terrorism, invasion, civil unrest, riots, or armed conflict;
• Government actions, including changes in laws or regulations, sanctions, embargoes, or government orders;
• Labor disputes, strikes, or lockouts not involving the Company's employees;
• Telecommunications, internet, or network failures not caused by the Company;
• Power outages or failures of utilities or infrastructure;
• Cyber attacks, hacking, distributed denial of service (DDoS) attacks, or other malicious activities by third parties;
• Securities market closures, trading halts, or exchange malfunctions;
• Failures or interruptions in third-party services or data providers;
• Any other event or circumstance beyond the Company's reasonable control.

19B.3 Suspension of Obligations: During the continuation of a Force Majeure Event, the Company's obligations under these Terms shall be suspended to the extent prevented by the Force Majeure Event. The Company will use commercially reasonable efforts to resume performance as soon as practicable after the Force Majeure Event ceases.

19B.4 No Liability: The Company shall not be liable to you or any third party for any loss, damage, delay, or failure to perform resulting from a Force Majeure Event, including but not limited to lost profits, trading losses, loss of data, or business interruption.

19B.5 Extended Force Majeure: If a Force Majeure Event continues for more than thirty (30) consecutive days, either party may terminate these Terms upon written notice to the other party, without liability except for obligations that accrued prior to the Force Majeure Event.

19B.6 Notice: The Company will make reasonable efforts to notify users of any Force Majeure Event affecting Platform availability or functionality, but is not obligated to provide such notice.

19C. Export Compliance and International Use

19C.1 Export Control Laws: You acknowledge that the Platform, including its software, technology, and technical data, may be subject to export control laws and regulations of the United States and other countries. You agree to comply with all applicable export and import laws and regulations in your use of the Platform.

19C.2 Prohibited Jurisdictions: You may not access, use, download, or export any part of the Platform or its content to, from, or within any country, region, or jurisdiction that is subject to U.S. trade sanctions, embargoes, or export restrictions, including but not limited to countries designated by the U.S. Office of Foreign Assets Control (OFAC) or other U.S. government agencies.

19C.3 Restricted Parties: You represent and warrant that you are not:

• Located in, organized under the laws of, or a resident of any country or region subject to U.S. sanctions or embargoes;
• Identified on any U.S. government list of prohibited, sanctioned, or restricted parties, including the OFAC Specially Designated Nationals List, the U.S. Commerce Department's Denied Persons List, Entity List, or Unverified List;
• Owned or controlled by, or acting on behalf of, any person or entity on such lists;
• Otherwise prohibited from accessing or using the Platform under applicable laws or regulations.

19C.4 User Responsibility: You are solely responsible for ensuring that your use of the Platform complies with all applicable laws in your jurisdiction, including but not limited to securities laws, data protection laws, and export control regulations. You acknowledge that laws vary by jurisdiction and that content permissible in one jurisdiction may be prohibited in another.

19C.5 No Assurance of Availability: The Platform is operated from the United States and is intended primarily for users located in the United States. The Company makes no representation that the Platform or its content is appropriate, available, or compliant with laws outside the United States. If you access the Platform from outside the United States, you do so at your own risk and initiative and are responsible for compliance with local laws.

19C.6 Securities Laws: The information provided on the Platform relates to securities traded on U.S. exchanges and is intended for U.S. persons. Such information may not be appropriate for users in other jurisdictions where the offering, solicitation, or distribution of such information may be restricted or prohibited by law. Users outside the United States should consult local legal and financial advisors before using the Platform or making investment decisions based on its content.

19C.7 Termination for Non-Compliance: The Company reserves the right to terminate or restrict your access to the Platform immediately and without notice if we have reason to believe you are in violation of any export control laws, sanctions, or other applicable international trade restrictions.

20. Changes to These Terms

20.1 The Company reserves the right, at its sole discretion, to modify or replace these Terms at any time. We will provide notice of material changes via email (to the email address associated with your account) or a prominent in-app notification. Such revisions will become effective thirty (30) days after we provide notice. What constitutes a material change will be determined at our sole discretion.

20.2 By continuing to access or use our Platform after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, you are no longer authorized to use the Platform.

21. Privacy Policy

Effective Date: January 27, 2026

21.1 Introduction: The Company respects the privacy of its users and is committed to protecting your personal information. This Privacy Policy explains what information we collect, how we use it, how we protect it, and your rights regarding your personal data. By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

21.2 Information We Collect

21.2.1 Information You Provide to Us: When you register for an account, use the Platform, or communicate with us, you may provide us with the following information:

• Account Information: Email address, password, name, and any other information you provide during registration or profile setup.
• Payment Information: Payment information is processed through Google Play Store or Apple App Store. We do not collect or store your credit card or payment information directly.
• User Content: Any content you submit, post, or upload to the Platform, including comments, forum posts, ratings, reviews, or other user-generated content.
• Communications: Messages, inquiries, or feedback you send to us through contact forms, email, or customer support channels.
• Contact Lists: If you choose to use features that connect you with other users, you may grant us access to your device's contact list. We do not store credentials for accessing these lists.

21.2.2 Information Collected Automatically: When you use the Platform, we and our service providers automatically collect certain information about your device and usage:

• Device Information: Device type, operating system and version, device identifiers (such as advertising ID), mobile network information, and device settings.
• Usage Data: Pages or content viewed, features used, actions taken, time spent on the Platform, session duration, search queries, bookmarks, and interactions with content.
• Log Data: IP address, browser type and version, referring/exit pages, date and time stamps, clickstream data, and crash reports.
• Location Information: General location based on IP address. We do not collect precise geolocation data unless you explicitly grant permission.
• Cookies and Similar Technologies: We use cookies, web beacons, pixels, and similar tracking technologies as described in Section 21.10 below.

21.2.3 Information from Third Parties: We may receive information about you from third parties, including:

• Social Media Platforms: If you register or log in through social media accounts (such as Google or Apple Sign-In), we may receive profile information from those platforms in accordance with their privacy policies and your privacy settings.
• Service Providers: Our analytics, advertising, and infrastructure providers may share information about your interactions with the Platform or other services.
• Publicly Available Sources: Information that is publicly available online or through other public sources.

21.3 How We Use Your Information

21.3.1 We use the information we collect for the following purposes:

• Provide and Maintain Services: To create and manage your account, process subscriptions, deliver Platform features and content, and provide customer support.
• Personalization: To customize your experience, recommend content, and tailor features to your interests and usage patterns.
• Communications: To send you service-related notifications, updates, security alerts, subscription confirmations, and customer support messages.
• Marketing: To send promotional materials, newsletters, and marketing communications about new features, products, or services (you may opt-out at any time).
• Analytics and Improvement: To analyze usage patterns, understand user behavior, improve Platform features, develop new services, and enhance user experience.
• Security and Fraud Prevention: To detect, prevent, and respond to fraud, security incidents, abuse, and other harmful or illegal activities.
• Legal Compliance: To comply with legal obligations, enforce our Terms, protect our rights and property, and respond to legal requests or processes.
• Research and Development: To conduct research, statistical analysis, and testing to improve our algorithms, AI models, and services.
• Advertising: To display relevant advertisements and measure advertising effectiveness (including through third-party advertising partners).

21.4 Legal Basis for Processing (for EEA/UK Users)

21.4.1 If you are located in the European Economic Area (EEA) or United Kingdom, our legal basis for collecting and using your personal information depends on the specific information and context:

• Contract Performance: Processing is necessary to provide the Platform services you have requested or to enter into a contract with you (e.g., account management, subscription processing).
• Legitimate Interests: Processing is necessary for our legitimate interests, such as improving our services, preventing fraud, ensuring security, and conducting analytics, provided these interests do not override your rights.
• Consent: You have given explicit consent for specific processing activities, such as receiving marketing communications or using certain tracking technologies (you may withdraw consent at any time).
• Legal Obligation: Processing is necessary to comply with applicable legal or regulatory requirements.

21.5 Data Sharing and Disclosure

21.5.1 Third-Party Service Providers: We share your information with third-party service providers who perform services on our behalf, including:

• Cloud hosting and infrastructure providers (e.g., data storage, server hosting)
• Analytics providers (e.g., usage analytics, performance monitoring)
• Customer support and communication tools
• Market data and financial information providers
• Push notification services
• Email and messaging service providers

These service providers are bound by contractual obligations to keep your information confidential and use it only for the purposes for which we disclose it to them.

21.5.2 App Store Providers: When you purchase a subscription through Google Play Store or Apple App Store, your payment information and transaction details are processed by those platforms according to their privacy policies. We receive limited information about your subscription status but do not have access to your full payment credentials.

21.5.3 Advertising Partners: We may share aggregated, anonymized, or de-identified data with advertising partners and analytics providers. We do not "sell" your personal information in the traditional sense, but we may share data for targeted advertising purposes as permitted by law.

21.5.4 Business Transfers: If the Company undergoes a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred to the successor entity or acquiring party.

21.5.5 Legal Requirements: We may disclose your information if required by law, legal process, or government request, or if we believe disclosure is necessary to:

• Comply with legal obligations or respond to lawful requests from public authorities
• Enforce our Terms of Use or other agreements
• Protect the rights, property, or safety of the Company, our users, or the public
• Prevent or investigate fraud, security incidents, or other illegal activities
• Defend against legal claims or litigation

21.5.6 With Your Consent: We may share your information for other purposes with your explicit consent or at your direction.

21.5.7 Public Content: Any content you post publicly on the Platform (such as comments, forum posts, or reviews) may be viewed by other users and may be indexed by search engines.

21.6 Data Retention

21.6.1 We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including:

• For the duration of your account's active status and for a reasonable period thereafter
• To provide ongoing services and support
• To comply with legal obligations, tax requirements, and accounting obligations
• To resolve disputes and enforce our agreements
• For backup, archival, and fraud prevention purposes

21.6.2 When we no longer need your personal information, we will securely delete or anonymize it. Anonymized or aggregated data that cannot be used to identify you may be retained indefinitely for analytics and research purposes.

21.6.3 If you request deletion of your account, we will delete or anonymize your personal information within a reasonable timeframe, except where we are required to retain it for legal, regulatory, or legitimate business purposes.

21.7 Data Security

21.7.1 We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit and at rest
• Secure authentication and access controls
• Regular security assessments and monitoring
• Employee training on data protection and security practices
• Contractual safeguards with third-party service providers

21.7.2 Security Limitations: However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity under your account.

21.7.3 Security Breach Notification: In the event of a data breach that affects your personal information, we will notify you and applicable regulatory authorities as required by law. Specifically:

• Timing: We will notify affected users without unreasonable delay and, where feasible, within 72 hours of discovering the breach, unless law enforcement determines that notification would impede a criminal investigation;
• Method: Notification will be provided via email to the address on file, in-app notification, and/or prominent notice on the Platform;
• Content: The notification will include, to the extent known: (i) the nature of the breach; (ii) the categories of data affected; (iii) the approximate number of users affected; (iv) the likely consequences of the breach; (v) measures taken to address the breach; and (vi) recommended actions you should take to protect yourself;
• Assistance: We will provide reasonable assistance and information to help you minimize potential harm from the breach;
• Investigation: We will conduct a thorough investigation of the breach and take steps to prevent future incidents.

21.7.4 Security Incident Response: If you believe your account has been compromised or you notice suspicious activity, you must immediately notify us and change your password. We may temporarily suspend your account to protect against further unauthorized access.

21.8 Your Privacy Rights

21.8.1 General Privacy Rights: Depending on your location and applicable law, you may have the following rights regarding your personal information:

• Right to Access: Request a copy of the personal information we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal information.
• Right to Erasure ("Right to Be Forgotten"): Request deletion of your personal information, subject to certain legal obligations and exceptions.
• Right to Restriction: Request that we limit the processing of your personal information in certain circumstances.
• Right to Data Portability: Request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Right to Object: Object to our processing of your personal information based on legitimate interests, direct marketing, or for research/statistical purposes.
• Right to Withdraw Consent: If processing is based on your consent, you may withdraw consent at any time (without affecting the lawfulness of processing before withdrawal).
• Right to Lodge a Complaint: File a complaint with your local data protection authority if you believe we have violated your privacy rights.

21.8.2 Exercising Your Rights: To exercise any of these rights, please contact us using the contact information provided in Section 21.14 below. We will respond to your request within the timeframe required by applicable law (typically 30-45 days). We may need to verify your identity before processing your request.

21.8.3 Limitations: These rights are not absolute and may be subject to limitations under applicable law. For example, we may retain certain information where we have a legal obligation to do so or where retention is necessary for legitimate business purposes.

21.9 California Privacy Rights (CCPA/CPRA)

21.9.1 Applicability: If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights regarding your personal information.

21.9.2 California Consumer Rights:

• Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.
• Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: You have the right to opt-out of the "sale" or "sharing" of your personal information as those terms are defined under California law. We do not sell personal information in the traditional sense, but sharing data with advertising partners may be considered a "sale" or "sharing" under CCPA.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA rights.

21.9.3 Categories of Personal Information Collected: In the preceding 12 months, we have collected the following categories of personal information: identifiers (name, email, IP address), commercial information (subscription history), internet activity (usage data, browsing behavior), device information, and inferences (preferences, behavior patterns).

21.9.4 Do Not Sell or Share My Personal Information: To opt-out of the sale or sharing of your personal information, please contact us using the methods in Section 21.14 or adjust your privacy settings within the Platform.

21.9.5 Authorized Agent: You may designate an authorized agent to submit requests on your behalf. We will require written proof of the agent's authority and may need to verify your identity directly.

21.9.6 Shine the Light Law: California residents may also request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes without your consent.

21.10 Cookies and Tracking Technologies

21.10.1 What Are Cookies: Cookies are small text files stored on your device when you visit the Platform. We use cookies and similar tracking technologies (web beacons, pixels, local storage) to recognize you, remember your preferences, understand how you use the Platform, and improve your experience.

21.10.2 Types of Cookies We Use:

• Essential Cookies: Necessary for the Platform to function properly, such as authentication, security, and session management. These cannot be disabled.
• Performance/Analytics Cookies: Collect information about how you use the Platform, which pages you visit, and any errors you encounter. This helps us improve Platform performance.
• Functional Cookies: Remember your preferences and settings to provide enhanced, personalized features.
• Advertising/Targeting Cookies: Used by us and our advertising partners to deliver relevant advertisements and measure advertising effectiveness.

21.10.3 Third-Party Cookies: We may allow third-party service providers (such as analytics and advertising partners) to place cookies on your device. These third parties have their own privacy policies governing their use of cookies.

21.10.4 Managing Cookies: You can control and manage cookies through your browser or device settings. You may disable or delete cookies, but this may affect the functionality of the Platform and limit your access to certain features. Visit your browser's help section for instructions on managing cookies.

21.10.5 Do Not Track Signals: Some browsers support "Do Not Track" (DNT) signals. Currently, there is no industry standard for responding to DNT signals. We do not respond to DNT signals at this time, but we provide you with choices about data collection and use as described in this Privacy Policy.

21.10.6 Mobile App Tracking: Mobile apps may use device identifiers (such as Apple's IDFA or Google's Advertising ID) for analytics and advertising. You can limit ad tracking through your device settings (iOS: Settings > Privacy > Tracking; Android: Settings > Google > Ads).

21.11 International Data Transfers

21.11.1 Location of Processing: Your information will be processed and stored in the United States, where our servers and service providers are located. If you are using the Platform from outside the U.S., you acknowledge that your information will be transferred to, stored, and processed in the U.S.

21.11.2 Adequacy of Protection: The United States may not have the same data protection laws as your country of residence. However, we take reasonable measures to ensure that your information receives an adequate level of protection.

21.11.3 EU/UK Data Transfers: For users in the European Economic Area (EEA), United Kingdom, or Switzerland, we rely on appropriate data transfer mechanisms, such as Standard Contractual Clauses (SCCs) approved by the European Commission, to ensure your data is protected when transferred outside your jurisdiction.

21.11.4 Consent to Transfer: By using the Platform and providing your information, you consent to the transfer and processing of your data in the United States and other countries where we or our service providers operate.

21.12 Automated Decision-Making and Profiling

21.12.1 Automated Systems: We use automated systems, including AI and machine learning algorithms, to analyze data, personalize content, generate recommendations, and improve Platform functionality. These systems may create profiles based on your usage patterns and preferences.

21.12.2 No Solely Automated Decisions: We do not make decisions that produce legal or similarly significant effects on you based solely on automated processing without human involvement.

21.12.3 Your Rights: If you are in the EEA or UK, you have the right not to be subject to decisions based solely on automated processing that produce legal or significant effects. You may request human review of automated decisions.

21.13 Children's Privacy

21.13.1 Age Restriction: The Platform is not intended for or directed at individuals under the age of 18. We do not knowingly collect personal information from children under 18 years of age.

21.13.2 Parental Notice: If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information from our systems as soon as reasonably practicable.

21.13.3 Parental Rights: If you are a parent or guardian and believe your child has provided us with personal information, please contact us using the information in Section 21.14, and we will delete the information.

21.14 Privacy Contact Information

21.14.1 Data Controller: 42 Port Financial Technologies, Inc. is the data controller responsible for your personal information.

21.14.2 Privacy Inquiries: If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us through the contact methods provided on the Platform (app or website), or via the Platform's contact form.

21.14.3 Response Time: We will respond to your privacy inquiries and requests within the timeframe required by applicable law.

21.15 Changes to This Privacy Policy

21.15.1 Updates: We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify you of material changes via email or through a prominent notice in the Platform.

21.15.2 Effective Date: The "Effective Date" at the beginning of this Privacy Policy indicates when the policy was last updated. Your continued use of the Platform after changes take effect constitutes your acceptance of the updated Privacy Policy.

21.15.3 Review: We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

21.16 Additional Provisions

21.16.1 User Responsibility: You are responsible for ensuring that the personal information you provide to us is accurate, complete, and current. You must update your information promptly if it changes.

21.16.2 Third-Party Links: The Platform may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

21.16.3 Social Media Features: The Platform may include social media features (such as share buttons or interactive widgets). These features may collect your IP address, track which pages you visit, and may set cookies. Your interactions with these features are governed by the privacy policy of the company providing them.

21.16.4 Public Forums: Any information you post in public areas of the Platform (such as comment sections or forums) may be read, collected, and used by others. Exercise caution when disclosing personal information in public areas.

21.16.5 Prohibition on Unauthorized Data Collection: You may not use automated tools, scraping techniques, or any other means to collect user information from the Platform without our express written permission. Collecting or harvesting user information is strictly prohibited and may result in legal action.

22. General Provisions

22.1 Severability

22.1.1 If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving its intent. If such modification is not possible, the invalid provision shall be severed from these Terms.

22.1.2 The invalidity, illegality, or unenforceability of any provision shall not affect the validity, legality, or enforceability of the remaining provisions, which shall remain in full force and effect.

22.1.3 To the extent that any provision of these Terms is found to be excessively broad in duration, scope, or covered activity, that provision shall be construed to cover the maximum duration, scope, or activity permitted by applicable law.

22.2 Entire Agreement

22.2.1 These Terms of Use, together with our Privacy Policy (Section 21), constitute the entire agreement between you and the Company regarding your use of the Platform and supersede all prior or contemporaneous understandings, agreements, representations, and warranties, both written and oral, regarding the Platform.

22.2.2 No terms, provisions, or conditions of any purchase order, acknowledgment, or other business form that you may use in connection with your use of the Platform will have any effect on these Terms, and all such terms are hereby rejected.

22.2.3 Any ambiguity in these Terms shall not be construed against the Company as the drafter.

22.3 Waiver

22.3.1 No Waiver by Inaction: The Company's failure to enforce any right or provision of these Terms will not be deemed a waiver of such right or provision. No waiver by the Company of any breach of these Terms shall be deemed a waiver of any subsequent breach.

22.3.2 Written Waiver Required: Any waiver of any provision of these Terms will be effective only if in writing and signed by an authorized representative of the Company.

22.3.3 Specific Waiver Only: A waiver of any breach or default under these Terms shall not constitute a waiver of any other or subsequent breach or default.

22.4 Assignment and Transfer

22.4.1 Company Assignment Rights: The Company may assign, transfer, or delegate these Terms and our rights and obligations hereunder, in whole or in part, at any time without notice or your consent, including in connection with a merger, acquisition, corporate reorganization, sale of assets, or by operation of law.

22.4.2 User Assignment Prohibited: You may not assign, transfer, or delegate these Terms or your rights or obligations hereunder, in whole or in part, without the Company's prior written consent. Any attempted assignment, transfer, or delegation without such consent will be null and void.

22.4.3 Account Transfer Prohibited: Your account is personal to you and may not be transferred, sold, or assigned to any other person or entity. Upon your death or incapacity, your account and subscription will terminate unless otherwise required by law.

22.4.4 Binding on Successors: These Terms will be binding upon and inure to the benefit of the parties and their respective successors and permitted assigns.

22.5 Notice Provisions

22.5.1 Notices to Users: The Company may provide notices to you via email (to the email address associated with your account), through in-app notifications, by posting on the Platform, or by any other legally acceptable means. You consent to receive electronic notices and agree that such electronic notices satisfy any legal requirement that such notices be in writing.

22.5.2 Notices to Company: All legal notices to the Company must be sent to the contact information provided on the Platform or via the contact form available in the Platform. Notices to the Company are effective when received by the Company.

22.5.3 Email Notice Address: For legal notice purposes, you agree to keep your email address current in your account settings. Notices sent to the email address on file will be deemed delivered whether or not you actually receive the email.

22.5.4 Notice Timing: Notices provided via email will be deemed given 24 hours after the email is sent, unless the sending party receives notification that the email address is invalid. Notices provided by posting on the Platform will be deemed given upon posting.

22.6 Survival

22.6.1 Surviving Provisions: The following sections shall survive any termination or expiration of these Terms or your account: Sections 3 (Disclaimer: Not Investment Advice), 3A (U.S. Regulatory Compliance), 8.12-8.13 (User Content licenses and waivers), 11 (User Use of Content - restrictions), 12 (Use of Content by the Company), 13 (Intellectual Property), 14 (Limitation of Liability and Indemnity), 16 (Governing Law and Arbitration), 19A (Warranty Disclaimers), 21 (Privacy Policy - to the extent necessary), 22 (General Provisions), and any other provision that by its nature should survive termination.

22.6.2 Accrued Rights: Termination of these Terms or your account will not affect any rights or obligations that have accrued prior to termination, including payment obligations.

22.7 Relationship of the Parties

22.7.1 Independent Parties: You and the Company are independent contractors. Nothing in these Terms creates a partnership, joint venture, agency, franchise, sales representative, or employment relationship between you and the Company.

22.7.2 No Authority: You have no authority to make or accept any offers or representations on behalf of the Company. You will not represent yourself as an agent, employee, or representative of the Company.

22.7.3 No Benefits: Neither party is entitled to any employee benefits, workers' compensation, unemployment insurance, or other employment-related benefits from the other party.

22.8 Third-Party Beneficiaries

22.8.1 No Third-Party Rights: Except as expressly stated in these Terms, these Terms do not and are not intended to confer any rights or remedies upon any person or entity other than you and the Company.

22.8.2 Service Provider Exception: Notwithstanding the above, our service providers (including app store providers, hosting providers, and data providers) are intended third-party beneficiaries of the provisions in these Terms that limit liability and provide disclaimers.

22.9 Language and Translation

22.9.1 English Language Governs: These Terms are drafted in the English language. If these Terms are translated into any other language, the English language version shall control in the event of any conflict or discrepancy.

22.9.2 Translation for Convenience: Any translation is provided for convenience only and may not accurately represent the English version.

22.10 Headings and Interpretation

22.10.1 Headings: The headings and captions used in these Terms are for convenience only and shall not affect the interpretation of these Terms.

22.10.2 Examples: Any examples provided in these Terms are for illustrative purposes only and shall not limit the scope of any provision.

22.10.3 Including: The use of "including" means "including without limitation."

22.11 Force Majeure

22.11.1 The provisions of Section 19B (Force Majeure) are incorporated by reference into these General Provisions and apply to all obligations under these Terms.

22.12 Electronic Communications Consent

22.12.1 Consent to Electronic Records: By accepting these Terms, you consent to receive communications from us electronically, including via email, in-app notifications, or by posting notices on the Platform. You agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

22.12.2 Electronic Signature: Your use of the Platform, clicking "I Agree," checking a box, or any similar action constitutes your electronic signature and your agreement to be bound by these Terms with the same force and effect as if you had signed these Terms manually.

22.12.3 Withdrawal of Consent: You may withdraw your consent to receive electronic communications by contacting us, but if you do, we may terminate your account.

22.13 Remedies and Equitable Relief

22.13.1 Cumulative Remedies: All remedies available to the Company under these Terms or at law or in equity are cumulative and not exclusive.

22.13.2 Injunctive Relief: You acknowledge that any breach of Sections 11 (User Use of Content), 13 (Intellectual Property), or any unauthorized use of the Platform may cause irreparable harm to the Company for which monetary damages would be an inadequate remedy. Accordingly, the Company shall be entitled to seek equitable relief, including injunction and specific performance, in addition to all other remedies available at law or in equity.

22.13.3 No Limitation on Legal Remedies: Nothing in these Terms limits the Company's right to seek any legal or equitable remedy available under applicable law.

23. Contacting the Platform

23.1 The Company complies with applicable law and respects the privacy and reputation rights of its users. If you believe the Content on the Platform infringes your rights, please contact us via the Platform’s contact form, and we will address your concerns promptly.

23.2 Dispute Resolution Process: Before initiating any legal action or arbitration, you agree to first attempt to resolve any dispute informally by contacting the Company:

• Initial Contact: Send a detailed description of your dispute, including your account information, the nature of the issue, and your desired resolution to the contact information provided on the Platform;
• Company Response: The Company will acknowledge receipt of your dispute within 5 business days and will provide a substantive response within 30 days of receipt;
• Good Faith Negotiation: Both parties agree to negotiate in good faith for at least 30 days before initiating arbitration or litigation;
• Informal Resolution Period: This informal resolution process must be completed before filing any arbitration or legal claim.

23.3 Customer Support Response Times: For non-legal inquiries:

• Urgent Issues: Account access problems, payment issues, or security concerns will receive a response within 24 hours;
• General Inquiries: Feature questions, technical support, and general assistance will receive a response within 3-5 business days;
• Privacy Requests: Requests to exercise privacy rights will be responded to within 45 days as required by applicable privacy laws.

23.4 Contact Information Accuracy: You are required to maintain accurate contact information in your account. If we attempt to contact you at the email address on file and the message is undeliverable, we may suspend or terminate your account. Important legal notices, security alerts, and subscription information will be sent to your registered email address.

23.5 Verification for Sensitive Requests: For security and privacy reasons, requests involving account changes, payment information, privacy rights, or account deletion may require identity verification. We may request additional information to confirm your identity before processing sensitive requests.

Please follow the changes in this document.