Online User Agreement

These Online User Agreement terms (“Terms”) govern your access to and use of the websites, mobile applications, content, tools, data, software, and services provided by Finapolis Inc., a Delaware corporation (“Company,” “we,” “us,” or “our”) (collectively, the “Services”). By clicking “I Agree,” creating an account, or using the Services, you agree to these Terms and our Privacy Policy. If you do not agree, do not use the Services.

You must be at least 18 years old (or the age of majority in your jurisdiction) to use the Services. If you access the Services on behalf of a company, you represent you have authority to bind that company, and “you” includes that company.

The Services are provided for general informational, educational, and independent research purposes only. The Services do not constitute and are not a substitute for personalized investment advice, portfolio management, financial planning, securities analysis, legal advice, tax advice, accounting advice, or any other professional advice regulated under federal or state law. Nothing in the Services should be construed as a recommendation, endorsement, solicitation, or offer to buy, sell, or hold any security, commodity, digital asset, or other financial instrument, or to engage in any particular investment strategy. The Company is not your fiduciary, does not owe you any fiduciary duty, and does not act in your best interest in a fiduciary capacity.

Regulatory Status. The Company is not registered as, and does not act as, a broker-dealer under the Securities Exchange Act of 1934, as amended, or applicable state securities laws. The Company is not registered as, and does not act as, an investment adviser under the Investment Advisers Act of 1940, as amended, or applicable state investment adviser statutes. The Company is not a member of the Financial Industry Regulatory Authority (FINRA) or the Securities Investor Protection Corporation (SIPC). You may verify the registration status of any broker-dealer or investment adviser by visiting FINRA BrokerCheck at https://brokercheck.finra.org or the SEC’s Investment Adviser Public Disclosure database at https://www.adviserinfo.sec.gov. Finapolis Inc. will not appear in either database because it is not registered in any such capacity. If the Company ever offers regulated financial services, those services will be offered through a separately registered entity under separately identified terms.

Nature of Outputs. Any tools, scores, screeners, ratings, signals, alerts, articles, data visualizations, or other outputs generated or displayed through the Services (“Outputs”) are impersonal, general, and hypothetical in nature. They are not tailored to your individual financial situation, investment objectives, risk tolerance, time horizon, tax circumstances, or any other personal factors. In particular: (a) any “model portfolio” or similar feature displayed through the Services is a hypothetical, illustrative construct only and does not represent an actual portfolio, a recommended allocation for any individual user, or a managed account; (b) any “buy,” “sell,” “hold,” or similar indicator is an algorithmic output generated for general informational purposes and is not a personalized recommendation to take any action with respect to any security; and (c) any score, rating, ranking, or signal is a data-driven analytical output and does not represent investment advice or a guarantee of any outcome. No Output should be relied upon as the sole or primary basis for any investment decision.

Investment Risk; No Guarantee of Results. ALL INVESTING INVOLVES RISK, INCLUDING THE POSSIBLE LOSS OF THE ENTIRE PRINCIPAL AMOUNT INVESTED. THE COMPANY MAKES NO REPRESENTATION, WARRANTY, OR GUARANTEE OF ANY KIND REGARDING THE FUTURE PERFORMANCE, RETURNS, PROFITABILITY, OR OUTCOMES OF ANY INVESTMENT DECISION MADE IN WHOLE OR IN PART IN RELIANCE ON THE SERVICES OR ANY OUTPUT. PAST PERFORMANCE OF ANY SECURITY, INDEX, MODEL PORTFOLIO, STRATEGY, OR OTHER FINANCIAL INSTRUMENT REFERENCED OR DISPLAYED THROUGH THE SERVICES IS NOT INDICATIVE OF AND DOES NOT GUARANTEE FUTURE RESULTS. HYPOTHETICAL OR SIMULATED PERFORMANCE RESULTS HAVE INHERENT LIMITATIONS: THEY ARE PREPARED WITH THE BENEFIT OF HINDSIGHT, DO NOT REFLECT ACTUAL TRADING, AND CANNOT ACCOUNT FOR THE IMPACT OF ACTUAL MARKET CONDITIONS, LIQUIDITY CONSTRAINTS, TRANSACTION COSTS, OR OTHER FACTORS THAT MAY AFFECT ACTUAL INVESTMENT RESULTS. You are solely responsible for evaluating the merits and risks of any investment decision and for obtaining independent professional advice appropriate to your circumstances before acting on any information or Output available through the Services. In consideration of your access to the Services, you agree not to hold the Company or any Third-Party Content provider (defined in Section 3) liable for any claim, loss, or damage arising from any decision you make based on information or Outputs obtained through the Services.

Use of Artificial Intelligence. Certain Outputs available through the Services are generated in whole or in part using artificial intelligence, machine learning models, or other algorithmic processes (collectively, “AI Systems”). These AI Systems analyze data inputs—which may include market data, financial metrics, historical performance data, news and sentiment data, and other inputs—to produce scores, signals, rankings, summaries, model portfolio constructs, and other analytical Outputs. You acknowledge and agree that:

(a) AI Outputs Are Not Advice. No Output generated by an AI System constitutes investment advice, a recommendation, or a solicitation. The fact that an Output was generated by an AI System rather than a human analyst does not change its character as general informational content. AI-generated Outputs are subject to all disclaimers set forth in Section 2 of this Agreement.

(b) Inherent Limitations of AI Systems. AI Systems have inherent limitations. They may produce outputs that are incorrect, incomplete, outdated, inconsistent, or that reflect biases present in their training data or underlying data inputs. AI Systems operate on historical and current data patterns and cannot predict future market conditions, unexpected events, macroeconomic shifts, or other factors that may affect investment outcomes. The Company does not represent that AI-generated Outputs are free from error, and you should not assume that an AI-generated Output is accurate, current, or complete.

(c) No Guarantee of Algorithmic Performance. The Company makes no representation or guarantee that any AI System or algorithm used in the Services will produce accurate, timely, or profitable Outputs, or that any Output will perform as expected in actual market conditions. Any historical or backtested performance data associated with AI-generated models or signals is hypothetical, prepared with the benefit of hindsight, and subject to the limitations described in Section 2. PAST ALGORITHMIC PERFORMANCE DOES NOT GUARANTEE FUTURE RESULTS.

(d) AI Systems May Change. The AI Systems and algorithms underlying the Services are subject to change, update, retraining, or discontinuation at any time without notice. The methodology, weighting, inputs, and logic of any AI System may be modified, and such changes may affect Outputs in ways that are not disclosed in real time. The Company has no obligation to notify you of changes to its AI Systems or methodologies except as required by applicable law.

(e) Human Review Recommended. You should not make any investment decision based solely on an AI-generated Output. We strongly encourage you to independently verify any Output, consult a qualified financial professional regarding your specific circumstances, and apply your own judgment before taking any investment action. The use of AI-generated financial information does not reduce the importance of independent due diligence.

The Services may include market data (including real-time, delayed, or end-of-day quotes), news, research, analytics, indexes, ratings, fundamentals, estimates, earnings data, and other third-party content (collectively, “Third-Party Content”). Third-Party Content is provided as-is for informational purposes only and may be delayed, inaccurate, incomplete, or interrupted. We and our data providers do not guarantee the accuracy, timeliness, completeness, correct sequencing, or fitness for any particular purpose of any Third-Party Content, and neither the Company nor its providers are liable for any errors, omissions, or interruptions in such content. MARKET DATA DISPLAYED THROUGH THE SERVICES MAY BE DELAYED BY FIFTEEN (15) MINUTES OR MORE AND IS NOT SUITABLE FOR USE AS THE SOLE BASIS FOR ANY REAL-TIME TRADING DECISION. You should independently verify any market data through a real-time source before executing any trade or investment transaction. The Services may include statements that are forward-looking in nature, which involve risks and uncertainties; actual results, performance, or events may differ materially from those expressed or implied in such statements.

You are responsible for maintaining the confidentiality of your credentials and for all activity under your account. Notify us immediately at support@finapolis.com of any unauthorized use. We may suspend or terminate access if we suspect unauthorized or abusive use.

You agree that you will not:

• Use any electronic communication or interactive feature of any Services for any purpose that is unlawful, tortious, abusive, invasive of another’s privacy, harassing, libelous, defamatory, obscene, threatening, hateful, or otherwise objectionable.
• Upload, post, reproduce, or distribute any information, software, data, or other material protected by copyright, trademark, patent, trade secret, rights of publicity or privacy, or other proprietary rights without the prior written permission of the rights holder.
• Collect, scrape, index, mine, or store personal data about other users of the Services without their express permission and in violation of applicable law (including any activity that contravenes our Privacy Policy).
• Use any of the Services for any commercial purpose not expressly approved by the Company in writing, or upload, post, email, or otherwise transmit any advertising or promotional materials, including without limitation “junk mail,” “surveys,” “spam,” “chain letters,” “pyramid schemes,” affiliate links, referral codes, or any other form of unauthorized solicitation or communication.
• Upload, post, email, or otherwise transmit any virus, worm, Trojan, time bomb, logic bomb, spyware, adware, or other malicious or harmful code, or engage in any activity that interrupts, damages, disables, overloads, or otherwise interferes with any of the Services or any related software, hardware, or telecommunications equipment.
• Attempt to circumvent, disable, or interfere with security-related features, access controls, rate limits, or content protections (including paywalls or entitlements) of the Services.
• Use robots, spiders, crawlers, scrapers, or other automated means to access the Services without the Company’s prior written consent, except for standard indexing by publicly available search engines.
• Decompile, disassemble, reverse engineer, or otherwise attempt to derive the source code of any the Company’s software except to the extent such restriction is prohibited by applicable law.
• Resell, redistribute, frame, mirror, or syndicate the Services, outputs, or datasets, or create a substantially similar service using the Company content or data, without express written permission.
• Use the Services to engage in or facilitate market manipulation, fraud, deceptive practices, or violations of securities, sanctions, or export-control laws.

If you purchase a paid subscription, the following terms apply. PLEASE READ THIS SECTION CAREFULLY—IT CONTAINS AUTOMATIC RENEWAL TERMS THAT WILL RESULT IN RECURRING CHARGES TO YOUR PAYMENT METHOD UNLESS YOU CANCEL.

Pricing and Taxes. Subscription fees are as stated at the time of checkout. Fees are exclusive of applicable taxes, which will be added where required by law and displayed at checkout. We reserve the right to change our subscription fees at any time; price changes will be communicated to you at least thirty (30) days in advance and will take effect at the start of the next renewal period.

Automatic Renewal—Important Disclosure. YOUR SUBSCRIPTION WILL AUTOMATICALLY RENEW AT THE END OF EACH SUBSCRIPTION PERIOD (MONTHLY OR ANNUAL, AS SELECTED AT CHECKOUT) AT THE THEN-CURRENT SUBSCRIPTION RATE, AND YOUR PAYMENT METHOD ON FILE WILL BE CHARGED AUTOMATICALLY, UNLESS YOU CANCEL BEFORE THE RENEWAL DATE. By purchasing a subscription, you expressly authorize the Company to charge your payment method on a recurring basis for successive subscription periods until you cancel. The charge will occur on or around the same date each month or year (as applicable) unless you cancel. You will receive a reminder notice by email at least five (5) days before any annual renewal charge. For monthly subscriptions, your payment method will be charged on the same calendar date each month. You may cancel your subscription at any time before the renewal date by: (i) visiting your account settings and selecting “Cancel Subscription,” or (ii) contacting us at support@finapolis.com. Cancellation takes effect at the end of the then-current subscription period; you will retain access to the Services through the end of that period. This automatic renewal offer is made pursuant to applicable law, including California Business and Professions Code §§ 17600–17606.

Free Trials. If you sign up for a free trial, your trial will automatically convert to a paid subscription at the end of the trial period at the then-current rate unless you cancel before the trial ends. We will notify you by email before your trial converts to a paid subscription. To avoid being charged, you must cancel before the trial period expires.

Refunds. Except as required by applicable law or as expressly stated in our posted refund policy, subscription fees are non-refundable and no credits will be issued for partial subscription periods. If you are a California resident and did not receive adequate disclosure of the automatic renewal terms prior to purchase, you may be entitled to a full refund of any charges in accordance with California Business and Professions Code § 17603. To request a refund under applicable law, contact support@finapolis.com.

The Services (including software, interfaces, design, text, graphics, data, and trademarks) are owned by us or our licensors and are protected by law. We grant you a limited, revocable, non-exclusive, non-transferable license to access and use the Services for your personal, non-commercial use in accordance with these Terms. All rights not expressly granted are reserved.

If you submit content (e.g., comments, feedback), you grant us a worldwide, royalty-free license to use, host, reproduce, modify, and display such content for operating, improving, and promoting the Services. You represent you have all rights needed to grant this license and that your content complies with law.

Our Privacy Policy, available at www.finapolis.com/privacy, explains in detail how we collect, use, disclose, and protect your personal information, including information collected through cookies, SDKs, and analytics technologies. The Privacy Policy is incorporated into and forms part of these Terms. By using the Services, you acknowledge that you have read and understood the Privacy Policy and consent to the practices described therein. California residents should refer to Section 10 of the Privacy Policy for a description of their rights under the CCPA/CPRA.

You consent to receive notices and disclosures electronically, and to conduct transactions electronically, consistent with the U.S. E-SIGN Act and applicable state laws. You can withdraw consent by contacting support@finapolis.com, though doing so may limit your use of the Services.

If you download our app from Apple App Store or Google Play, the respective platform’s standard terms (including end-user license and usage rules) apply in addition to these Terms. The platforms are not responsible for support or claims regarding the app.

TO THE FULLEST EXTENT PERMITTED BY LAW, THE SERVICES (INCLUDING ALL CONTENT, DATA, AND TOOLS) ARE PROVIDED “AS IS” AND “AS AVAILABLE.” WE AND OUR AFFILIATES, LICENSORS, DATA PROVIDERS, AND SUPPLIERS DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, AND QUIET ENJOYMENT. WE DO NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE. THE COMPANY EXPRESSLY DISCLAIMS ALL LIABILITY FOR ERRORS OR OMISSIONS IN, OR THE MISUSE OR MISINTERPRETATION OF, ANY INFORMATION CONTAINED IN THE SERVICES. THE COMPANY MAY CHANGE INFORMATION CONTAINED IN THE SERVICES AT ANY TIME AND MAKES NO COMMITMENT TO UPDATE THE INFORMATION CONTAINED IN THE SERVICES. YOU ASSUME THE ENTIRE RISK AS TO THE USE OF THE SERVICES.

UNDER NO CIRCUMSTANCES, INCLUDING BUT NOT LIMITED TO A NEGLIGENT ACT, WILL COMPANY OR ITS AFFILIATES, AGENTS, EMPLOYEES, OR LICENSORS (INCLUDING THIRD PARTY PROVIDERS) BE LIABLE FOR ANY DAMAGES OF ANY KIND THAT RESULT FROM THE USE OF, OR THE INABILITY TO USE, ANY OF THE SERVICES, EVEN IF ANY SUCH PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. APPLICABLE LAW MAY NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY OR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU.

IN NO EVENT WILL COMPANY OR ITS THIRD PARTY PROVIDERS BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY TORT, CONTRACT OR ANY OTHER LIABILITY ARISING IN CONNECTION WITH THE USE OF THE SERVICES, OR RELIANCE ON ANY INFORMATION OR SERVICES PROVIDED BY COMPANY. COMPANY AND ITS THIRD PARTY PROVIDERS WILL UNDER NO CIRCUMSTANCES BE LIABLE TO YOU AND/OR ANY THIRD PARTY, REGARDLESS OF THE FORM OF ACTION, FOR ANY LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES, OR ANY DIRECT, INDIRECT, SPECIAL, CONSEQUENTIAL, INCIDENTAL OR PUNITIVE DAMAGES WHATSOEVER, EVEN IF COMPANY OR ITS THIRD PARTY PROVIDERS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES RESULTING FROM: (i) THE USE OR THE INABILITY TO USE THE SERVICES; (ii) THE TIMELINESS, DELETION, MISDELIVERY, OR FAILURE TO STORE ANY USER DATA, COMMUNICATIONS OR PERSONALIZATION SETTINGS; (iii) THE COST OF GETTING SUBSTITUTE GOODS AND SERVICES RESULTING FROM ANY PRODUCTS, DATA, INFORMATION OR SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR TRANSACTIONS ENTERED INTO, THROUGH OR FROM THE SERVICES; (iv) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; (v) STATEMENTS OR CONDUCT OF ANYONE ON THE COMPANY SERVICES; (vi) THE USE, INABILITY TO USE, UNAUTHORIZED USE, PERFORMANCE OR NON-PERFORMANCE OF ANY THIRD PARTY, EVEN IF THE THIRD PARTY HAS BEEN ADVISED PREVIOUSLY OF THE POSSIBILITY OF SUCH DAMAGES; OR (vii) ANY OTHER MATTER RELATING TO THE SERVICES. YOU AGREE THAT YOU WILL NOT IN ANY WAY HOLD COMPANY RESPONSIBLE FOR ANY SELECTION OR RETENTION OF, OR THE ACTS OR OMISSIONS OF, THIRD PARTIES (INCLUDING THIRD PARTY PROVIDERS) IN CONNECTION WITH THE SERVICES.

Because some states prohibit the limitation of liability for consequential or incidental damages, in such states the limitation of liability only with respect to consequential or incidental damages may not apply to you, and the respective liability of the Company and its Third Party Providers, employees, distributors and agents is limited to the greatest extent allowable under applicable law in those states.

In the event that a court or arbitration panel, as the case may be, should hold that the limitations of liabilities or remedies available as set forth in this Agreement, or any portions thereof, are unenforceable for any reason, or that any of your remedies under this Agreement fail, then you expressly agree that under no circumstances will the total, aggregate liability of Company and its Third Party Providers, employees, distributors, agents or affiliates, to you or any party claiming by or through you for any cause whatsoever, exceed $100 (U.S.), regardless of the form of action and whether in contract, statute, tort or otherwise.

YOU AGREE TO INDEMNIFY AND HOLD COMPANY AND ITS AFFILIATES, AGENTS, EMPLOYEES, AND LICENSORS (INCLUDING THE THIRD PARTY CONTENT PROVIDERS) HARMLESS FROM ANY CLAIM, DEMAND, LOSS, COSTS OR EXPENSE, INCLUDING ATTORNEYS' FEES, MADE BY ANY PERSON ARISING OUT OF YOUR VIOLATION OF THIS AGREEMENT, STATE OR FEDERAL SECURITIES LAWS OR REGULATIONS, OR ANY OTHER PERSON'S RIGHTS, INCLUDING BUT NOT LIMITED TO INFRINGEMENT OF ANY COPYRIGHT OR VIOLATION OF ANY PROPRIETARY OR PRIVACY RIGHT.

PLEASE READ THIS SECTION CAREFULLY. It affects your rights.

You and Company agree to resolve any dispute, claim, or controversy arising out of or relating to the Services or these Terms (collectively, “Disputes”) through final and binding individual arbitration administered by JAMS under its Streamlined Arbitration Rules, or by AAA under its Consumer Arbitration Rules, as selected by the party filing. The Federal Arbitration Act (FAA) governs interpretation and enforcement.

Disputes must be brought on an individual basis. NO CLASS ACTIONS OR REPRESENTATIVE PROCEEDINGS are permitted.

Either party may bring an individual claim in small-claims court within its jurisdictional limits or seek temporary injunctive relief in a court of competent jurisdiction to preserve the status quo pending arbitration.

The arbitration will occur in Delaware or remotely by video, at the arbitrator’s discretion. Payment of filing, administration, and arbitrator fees will be governed by the applicable rules; we will pay amounts required by those rules for consumer disputes.

You may opt out of this arbitration provision within 30 days of first accepting these Terms by emailing support@finapolis.com with your name, account email, and a clear statement that you opt out.

The Services are owned by the Company or its affiliates or agents and are protected by United States copyright laws and international treaty provisions. All content, trademarks, services marks, trade names, logos, and icons are proprietary to the Company or its affiliates, licensors or agents. Other third-party products and brand names may be trademarks or registered trademarks of their respective owners and may not be affiliated with the Company. Nothing contained in the Services should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark displayed on the Services without the written permission of the Company or such third party that may own the trademarks displayed on the Services. Your use of the trademarks displayed on the Services, or any other content in the Services, except as provided herein, is strictly prohibited.

Images displayed through the Services are either the property of, or used with permission by, the Company. You are prohibited from using or authorizing the use of these images unless specifically permitted under these Terms. Any unauthorized use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity, or other regulations and statutes.

You may not access or use the Services if you are located in, or are a national or resident of, any country or region subject to comprehensive U.S. sanctions, or if you are a person on U.S. or other applicable sanctions or denied-party lists. You agree to comply with all applicable export-control and sanctions laws.

We may modify the Services or these Terms at any time. Material changes will be posted on the Services or communicated to you. If you continue using the Services after changes become effective, you accept the changes. If you do not agree, you must stop using the Services.

We may suspend or terminate your access at any time with or without notice for any reason, including violation of these Terms. Upon termination, Sections that by their nature should survive will survive, including but not limited to Sections 12, 13, 14, 15, and 23 (as applicable to Beta Users).

These Terms are governed by the laws of the State of Delaware, without regard to conflicts principles, and by applicable U.S. federal law. Subject to Section 15, the exclusive venue for any court proceeding (including small claims) shall be the state or federal courts located in Delaware, and you consent to personal jurisdiction there.

Notices may be sent to you via email, in-product messages, or posting on the Services. You can contact us at: support@finapolis.com

Current Arrangements. As of the date of this Agreement, the Company’s sole source of revenue is subscription fees paid directly by users. The Company does not currently receive compensation, commissions, revenue sharing, or other consideration from any third-party financial services provider, data vendor, securities issuer, investment manager, broker-dealer, or advertiser in connection with the content, Outputs, or data displayed through the Services, and no such third party pays for placement, prominence, or favorable treatment in any Output or tool. The Company does not have any undisclosed financial interest in any security, investment product, or financial service featured in or generated by the Services.

Future Arrangements; Disclosure Commitment. If the Company enters into any material commercial arrangement in the future that could reasonably be expected to influence or create the appearance of influencing the objectivity of any content or Output—including advertising relationships, sponsored content arrangements, affiliate programs, data licensing revenue sharing, or referral fee arrangements—the Company will update this Agreement and provide conspicuous disclosure of the nature of such arrangement, the identity of the relevant third party, and the manner in which it may affect the Services or any Output. Users will be notified of material changes to this Section in accordance with Section 18 of this Agreement.

Data Vendor Relationships. The Company licenses market data, financial information, and other Third-Party Content from third-party data providers as described in Section 3. These are arms’-length data licensing relationships in which the Company pays for data access. Data vendors do not pay the Company for placement or favorable display of their data, and the existence of a data licensing relationship does not indicate any endorsement of any security or financial product by the Company or its data providers.

These Terms are the entire agreement between you and us regarding the Services and supersede prior agreements. If any provision is held unenforceable, it will be modified to the minimum extent necessary and the remainder will remain in effect. No waiver of any term is a continuing waiver. You may not assign these Terms without our consent; we may assign them as part of a merger, acquisition, or sale of assets.

23.1 Applicability. This Section 23 applies solely to users who have been granted access to the Finapolis platform or any features thereof prior to or during a formally designated beta, pre-release, pilot, or early-access testing period (“Beta Program”). If you are accessing the Services through a Beta Program, you are a “Beta User.” Beta Users are subject to all other terms of this Agreement in addition to the terms of this Section 23. In the event of any conflict between this Section 23 and any other provision of this Agreement as applied to Beta Users, this Section 23 controls.

23.2 Definition of Confidential Information. “Confidential Information” means any information or materials disclosed by the Company to Beta Users in connection with the Beta Program that is not generally known to the public, including but not limited to: (a) unreleased features, functionality, interfaces, or designs of the Services; (b) performance data, test results, bugs, error reports, and technical specifications; (c) business plans, roadmaps, marketing strategies, or pricing; (d) proprietary algorithms, data models, scoring methodologies, and software; (e) any information marked “confidential,” “proprietary,” or “beta”; and (f) any information a reasonable person would understand to be confidential given the nature and circumstances of disclosure. Confidential Information does not include information that: (i) is or becomes publicly available through no act or omission of Beta User; (ii) was rightfully known to Beta User prior to disclosure without restriction; (iii) is independently developed by Beta User without reference to the Confidential Information; or (iv) is required to be disclosed by law, regulation, or court order, provided that Beta User gives the Company prompt written notice and cooperates with the Company in seeking a protective order.

23.3 Confidentiality Obligations. Beta User agrees to: (a) hold all Confidential Information in strict confidence using at least the same degree of care used to protect Beta User’s own confidential information, but in no event less than reasonable care; (b) not disclose, publish, distribute, or transmit any Confidential Information to any third party without the Company’s prior written consent; (c) use Confidential Information solely for the purpose of participating in the Beta Program and providing feedback to the Company; (d) not use Confidential Information for any competitive purpose, product development, or commercial exploitation; and (e) promptly notify the Company upon discovery of any unauthorized disclosure or use of Confidential Information.

23.4 No Public Disclosure; No Reviews or Benchmarks. Beta User shall not, without the Company’s prior written consent: (a) make any public statement, social media post, blog entry, press release, review, or other public communication regarding the Beta Program or any features, performance, or content of the pre-release Services; or (b) conduct or publish any benchmark tests, performance comparisons, or competitive analyses of the beta Services.

23.5 Feedback License. Beta User may, at Beta User’s election, provide comments, suggestions, ideas, bug reports, or other feedback regarding the beta Services (“Feedback”). Beta User hereby grants the Company a perpetual, irrevocable, worldwide, royalty-free, fully paid-up license to use, reproduce, modify, create derivative works from, and incorporate any Feedback into the Services or other products, without compensation to Beta User and without restriction. Beta User represents that any Feedback provided does not contain any third-party confidential information or trade secrets.

23.6 Beta Services Provided As-Is; No Warranties. Beta Services are provided “AS IS” and “AS AVAILABLE” for testing purposes only. The Company makes no warranties of any kind regarding the beta Services, including with respect to functionality, data integrity, or fitness for any particular purpose. Beta Users acknowledge that the beta Services may contain errors, defects, and instability, and that the Company has no obligation to release, continue, or commercialize any beta feature or service.

23.7 Duration; Survival. Beta User’s confidentiality obligations under this Section 23 commence upon Beta User’s first access to the Beta Program and continue for a period of three (3) years following the conclusion of Beta User’s participation in the Beta Program, or until the Confidential Information enters the public domain through no act or omission of Beta User, whichever occurs first. Upon the Company’s written request, Beta User shall promptly return or certifiably destroy all materials containing Confidential Information.

23.8 Injunctive Relief. Beta User acknowledges that a breach of this Section 23 would cause irreparable harm to the Company for which monetary damages would be an inadequate remedy, and that 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, without the requirement to post bond or prove actual damages.

24.1 What Are Cookies. Cookies are small text files placed on your device by a web server when you visit a website. The Services use cookies, web beacons, pixel tags, local storage objects, software development kits (SDKs), and similar tracking technologies (collectively, “Cookies”) to operate and improve the Services, remember your preferences, analyze usage, and deliver relevant content. By using the Services, you consent to our use of Cookies as described in this Section 24. This Cookie Policy supplements our Privacy Policy, which is incorporated into and forms part of this Agreement.

24.2 Categories of Cookies We Use. We use the following categories of Cookies:

(a) Strictly Necessary Cookies. These Cookies are required for the Services to function and cannot be disabled. They include Cookies that authenticate users, maintain session state, enable security features, and support core platform operations. These Cookies do not store personally identifiable information and are placed in response to your actions (e.g., logging in, setting preferences).

(b) Functional Cookies. These Cookies allow the Services to remember your preferences and personalization choices (such as language, region, display settings, and saved watchlists) to provide an enhanced user experience. Disabling these Cookies may affect certain features of the Services.

(c) Analytics and Performance Cookies. These Cookies collect information about how users interact with the Services—including pages visited, time spent, errors encountered, and navigation paths—to help us understand usage patterns and improve the Services. We may use third-party analytics providers (e.g., Google Analytics) for this purpose. Information collected is generally aggregated and does not directly identify individual users.

(d) Targeting and Advertising Cookies. These Cookies may be set by the Company or our advertising partners to build a profile of your interests and display relevant advertisements on the Services or other sites. They do not directly store personal information but are based on uniquely identifying your browser and device. If you disable these Cookies, you may see less targeted advertising.

24.3 First-Party and Third-Party Cookies. Cookies placed directly by the Company are “first-party” Cookies. “Third-party” Cookies are placed by our service providers and partners, including analytics, advertising, and social media vendors. Third parties may use Cookies to collect information about your online activities across websites and over time. The Company does not control third-party Cookies and their use is subject to the privacy policies of those third parties.

24.4 Session and Persistent Cookies. Session Cookies are temporary and expire when you close your browser. Persistent Cookies remain on your device for a defined period or until manually deleted. The Services use both types. Persistent Cookies will be retained only for as long as necessary to fulfill the purpose for which they were set, as further described in our Privacy Policy.

24.5 Your Cookie Choices and Controls. You have the following options to manage Cookies:

(a) Browser Settings. Most browsers allow you to block or delete Cookies through their settings. Please consult your browser’s help documentation for instructions. Please note that blocking Strictly Necessary Cookies may impair the functionality of the Services or prevent you from accessing certain features.

(b) Opt-Out Tools. You may opt out of interest-based advertising by visiting the Network Advertising Initiative opt-out page at http://www.networkadvertising.org/choices/ or the Digital Advertising Alliance opt-out page at http://www.aboutads.info/choices/. For Google Analytics specifically, you may install the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout.

(c) Do Not Track. Some browsers offer a “Do Not Track” (“DNT”) signal. Because there is no uniform standard for DNT signals, the Services do not currently respond to DNT browser signals. We will update this Section if and when an industry-wide standard is adopted.

24.6 California Residents. If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), may provide you with additional rights with respect to Cookies and the personal information collected through them, including the right to opt out of the “sale” or “sharing” of personal information (which under California law may include certain Cookie-based advertising activities). To exercise these rights, please contact us at support@finapolis.com or refer to our Privacy Policy for additional information. The Company does not sell the personal information of minors under 16 years of age.

24.7 Updates to This Cookie Policy. We may update this Cookie Policy from time to time to reflect changes in our practices, technology, or applicable law. We will indicate the “Last Updated” date at the top of this Agreement. Continued use of the Services after any such update constitutes your acceptance of the revised Cookie Policy.

25.1 Commitment to Accessibility. Finapolis Inc. is committed to ensuring that the Services are accessible to individuals with disabilities. We endeavor to conform to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA published by the World Wide Web Consortium (W3C) to the extent reasonably practicable. Our full Accessibility Statement, which describes our conformance approach, known limitations, and assistive technology compatibility, is available at www.finapolis.com/accessibility (the “Accessibility Statement”).

25.2 Feedback and Accommodation Requests. If you experience any difficulty accessing the Services, encounter an accessibility barrier, or require an accommodation to access content or complete a transaction, please contact us at support@finapolis.com or by mail at Finapolis Inc., 4343 Von Karman Ave. 3rd Floor, Newport Beach, CA 92660, Attn: Accessibility. Please describe the specific barrier you encountered, the assistive technology or browser you are using, and the content or feature you were attempting to access. We will make reasonable efforts to respond within five (5) business days and to provide an accessible alternative where feasible.

25.3 Third-Party Content. The Services may include or link to Third-Party Content (as defined in Section 3) that is not under the Company’s control. We cannot guarantee that third-party websites, feeds, tools, or embedded content meet any particular accessibility standard, and the Company is not responsible for the accessibility of Third-Party Content. We encourage users to contact the relevant third-party providers directly regarding accessibility concerns related to their content.

25.4 Ongoing Improvement. Accessibility is an ongoing effort. We periodically review and test the Services for accessibility compliance and address known barriers as part of our regular development cycle. New features and content are evaluated for accessibility prior to release to the extent practicable. We update our Accessibility Statement when material changes occur in our conformance posture.

By clicking “I agree” you will also be providing your electronic signature that will affirm:

You understand and intend that the Online User Agreement is a legally binding agreement and the equivalent of a signed, written contract;

You will use all Services, and our Web sites generally, in a manner consistent with applicable laws and regulations and in accordance with the terms and conditions of the Terms and any other applicable rules, guidelines or other conditions that govern the use of a particular Service as they may be amended by the Company from time to time; and

You understand, accept, and have received the Online User Agreement and its terms and conditions, and acknowledge and demonstrate that you can access the Online User Agreement and other disclosures on our Web site.

If you do not agree with the terms and conditions in the Online User Agreement, please select “Cancel” below and you will exit the registration process. You should be aware, however, that the use of any of the Services, is subject to the terms and conditions of the Online User Agreement. This Online User Agreement will always be available for your review via a link at the bottom of the Finapolis home page.