Privacy Policy

Ethics

We are committed to following the Codes of Ethics of the Society for Advancing Business Editing and Writing (SABEW). Our content is guided by and upholds the Society for Professional Journalists’ foundations of ethical journalism: being accurate and fair, minimizing harm, acting independently, and being accountable and transparent. We also uphold the Federal Trade Commission (FTC) guidelines on disclosures, where applicable. Beststartup US content is for informational purposes and is not intended to substitute for the advice of a licensed or certified attorney, accountant, financial advisor, or other certified financial professionals.

Editorial Process

Our staff of editors and network of expert contributors write and manage all the articles you find on Beststartup US. We don’t make recommendations for you to buy, sell, or hold securities or investments. We do, however, provide relevant analysis, context, insights, and educational information to help you make smarter, better-informed decisions. Wherever possible we provide examples that help put complex topics and concepts into perspective. Our editorial team is continually evaluating the articles across our site to flag any that contain information that is known to be or is likely to be out-of-date. Such articles are reviewed and updated or, if necessary, completely rewritten, rechecked, and re-edited. Our network of experienced experts, who uphold our process and policies, assist with our updating efforts. Articles that have been updated are date-stamped to reflect this.

Quality Standards

Every article you see has multiple people behind it, continually working to make sure that it is responsible, accurate, understandable, helpful, and reflective of our editorial principles. Our editorial team approves all story ideas independently, and our expert contributors each have deep subject matter expertise in the topics that we assign them. Our team of professional editors, fact checkers, and producers review content to ensure it upholds our values of being empowering, inclusive, unbiased, and accurate. All staff are responsible for disclosing any potential conflicts of interest.

Corrections

Beststartup US is committed to telling readers when an error has appeared, and to correcting it. This transparency applies to small and large mistakes, including news, but only if an error was made at the time of original publication. Corrections will be clearly noted on the page. When our journalism is factually correct, but the language is not as clear or detailed as necessary, the story may be updated without an editor’s note. Please report possible errors to admin@beststartup.us.

Writers

Beststartup US writers are carefully recruited, vetted, and chosen. Some are experienced financial writers, others are experts in particular aspects of finance; many are both. They are selected for their knowledge and their skill at communicating complex topics in clear, accessible, actionable language. Every article’s author or reviewer is listed at the top of the page, to the left of the date, and is linked to their biography, which you can click on to learn more about their credentials, education, professional experience, and social media presence. All writers are required to uphold the editorial guidelines listed above.

Third-Party Content

Third-party content is carefully reviewed by the Beststartup US editorial team to ensure that it is aligned with our policies and standards. Any such content is labeled clearly and conspicuously to notify you of its source.

Advertising Disclosure

Beststartup US accepts advertising, but maintains a strict and clear separation between advertising and editorial content. Special attention is paid to featuring advertising in a way that will not interfere with your reading experience. This relates to both page design and to the number of ads we choose to feature on a page. Beststartup US maintains a distinct separation between advertising and editorial content.

• • All advertising or sponsored content on Beststartup US is clearly and unambiguously distinguished from editorial content through borders or other distinguishing elements and/or identified as an “Ad,” “Advertisement,” “Sponsored” or a similar designation indicating that the content is being provided by or on behalf of the sponsor.

• • All ads on Beststartup US are labeled as an “Ad,” “Advertisement,” “Sponsored” or a similar designation indicating that the content is being provided by or on behalf of the sponsor.

• • All “native” ads or paid content are identified as an “Ad,” “Advertisement,” “Sponsored” or a similar designation indicating that the content is being provided by or on behalf of the sponsor.

• • Editorial content on Beststartup US is not influenced by advertisements unless the content is sponsored content, in which case, the content will be clearly demarcated and identified with the title “Ad,” “Advertisement,” or “Sponsored”, or a similar designation, indicating that the content is being provided by or on behalf of an advertiser or sponsor.

• In some cases, editorial may include links to partners for which Beststartup US receives an affiliate commission (See ‘How We Make Money’ for more details). The placement of these links is not influenced by payment, and editorial reserves the right to change, modify or remove them at any time in order to provide the best experience to users.

How We Make Money

The way that we’re able to offer over 30,000 articles of great content on our website for free is by partnering with advertisers and affiliate partners who are looking to reach consumers. This can take a number of different forms, and we’ll walk through those below. It’s important to note that we maintain strict editorial independence for all of our content, particularly on reviews and recommendations. If a product is great, we’ll tell you even if we don’t have an advertising relationship. If we think a product is bad, we’ll tell you that, even if we DO have an advertising relationship with them. While we do recommend and review products regardless of any advertising relationships, we may not have reviewed every product available in a given category.

Affiliate Links to Advertisers

In some cases we may have an affiliate relationship with a product that we review, and so when you click on an “Open Account” button or sometimes a hyperlink on the product’s name in those cases we may receive compensation either when you click on it it or if you decide to sign up for the product. Whether or not we have an advertiser in place does not change the placement of the button or whether there’s a link for you to go to their website.

Comparison/Rate Tables Featuring Advertisers

On some review/recommendations we may include a comparison table of products that are offers from advertisers. While we do work hard with partners to try and surface the best paid offers possible in these comparison tables, it’s important to note that they are NOT editorially selected. Here’s an example of what that can look like, notice the Advertising Disclosure link in the top right corner:

Display Ads

Some review/recommendations may include display advertising on them, which will be labelled as advertisements and are easily recognized.

Privacy Policy

At Beststartup US, we respect your privacy, and we understand the importance of the information you entrust to us. This Privacy Policy describes our practices concerning the information collected by Beststartup US, (“Beststartup US”, “we”, “us”, “our”) through the use of (i) our Beststartup US website (the “Website”) and (ii) our Beststartup US mobile applications (collectively, the “Services”). This Privacy Policy applies to all personal information we collect or process about you. Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified. Below we describe what information we collect when you use our Services, how we protect that information, how long we retain it, with whom we share it, and what your privacy options are. By using the Services, you consent to our collection and use of your information as described in this Privacy Policy. The Privacy Policy is incorporated by reference into and is made a part of the Terms of Service. We will continue to evaluate this Privacy Policy against new technologies, business practices, and our users’ needs, and may make changes to the Privacy Policy accordingly. Please check this page periodically for updates. If we make any material changes to this Privacy Policy, we will post the updated Privacy Policy here, along with its effective date, and for material changes will notify you by email or by means of a notice on our Website. Your continued use of the Services after our posting of changes to this Privacy Policy means that you agree to be bound by such changes. Our Services are intended for general audiences over the age of 16 years old. We do not knowingly collect information from children under the age of 16 years old. 1. Information We Collect About You We collect personal information about you from a variety of sources, including from you directly (e.g. when you contact us or sign up for an account), information we generate about you in the course of our relationship with you (e.g. data collected from cookies and other similar technologies which is described in our Cookie Policy, and information we collect about you or from other sources, including commercially available sources, such as public databases (where permitted by law). Information You Provide To Us: You may provide personal information to us, if you choose to:

• • submit a help request, a customer services inquiry or other inquiry to us, or fill in any other forms for the purposes of receiving our Services;

• • participate in some of the features accessible via the Services (for example, message boards, games, surveys, polls, promotions, contests, sweepstakes or other incentives);

• • participate in any Services that require registration;

• • enroll in any of our Webinars and/or Courses;

• • sign up to receive any information and/or services from any third party provider or partner using our Website (If you submit information to a third party provider or partner, please note that their use and disclosure of your information is subject to their own privacy policy);

• • contact us about employment opportunities;

• otherwise use the Services in a manner that you have requested.

Depending on which of these or any other Services you use, the personal information you provide may include:

• • personal details (e.g. name, date of birth, professional title, company name, and household income, investment interests, retirement information, information about your educational background);

• • contact details (e.g. phone number, email address, postal address, or mobile number);

• • account details (e.g. user name and password);

• • transaction details (e.g. when you make a purchase or respond to offers);

• • communications (e.g. when you participate or post material in message boards or forums, participate in polls or surveys, write a review or provide a testimonial, or contact us with a question, comment, or request); or

• professional information (e.g. if you are a Financial Advisor participating in our Advisor Insights program, information about your credentials, including, without limitation, broker CRD number, professional website URL, biographical information, licences and designations, and profile picture).

Please be aware, that by posting information to message boards, chat groups, or social networking facilities available via the Services, you will be making this information available to other users of these Services to the public. You should be careful about revealing any sensitive details about yourself. If you purchase Courses through the Beststartup US, please note that we do not currently collect or retain credit card numbers internally. We partner with third party payment providers. All direct payment gateways are required to adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements are intended to promote the secure handling of credit card information. Email Referral: We also have features that allow you to send an email to yourself and/or others about an item on our site. If you choose to use our email referral service, you will be required to provide the e-mail address or addresses that will be used in the notification. Upon form submission, an email will be generated to your recipient(s) inviting them to visit the URL you have recommended. We do not store this information other than for the sole purpose of sending this one-time e-mail. Information Collected Via Automated Technologies and Interactions: When you use the Services, we may automatically collect information via automatic means about your computer or device, your preference settings, your location, and your activities, including:

• • IP address of your computer;

• • Unique mobile device identifiers;

• • Technical information about your computer or mobile device such as type of device, mobile device ID number, screen resolution, web browser information, and operating system or platform;

• • Your preferences and settings (time zone, language, etc.);

• • Internet provider or mobile carrier name;

• • The URL of the last webpage you visited before visiting the Website;

• • Information about your activity on the Services (e.g., your search queries, mis-formatted DNS entries, search results selected, clicks, pages viewed, search history, comments, forms filled out and submitted, how often you use the Services);

• • Information we generate as a result of your use of the Services (e.g. our understanding of your interests as a result of your use of the Services and whether you are a regular or occasional user of the Services); and

• If you are using a mobile device, your mobile device’s geographic location (specific geographic location if you’ve enabled the collection of that information, or general geographic location automatically). Please see the section “Mobile Device Location Information” below for further information.

Third Parties Third-parties who provide us with products and services may also place cookies, ad tags and/or beacons that collect the information outlined above in order to provide us with products and services including:

• • Analytics tools (e.g., Google Analytics) allowing us to analyze the performance of our Services.

• • Service features and functionalities such as those that enable videos to be played and you to connect to your social media accounts.

• Advertisers and ad networks allowing the delivery of targeted advertisements.

These third parties may also collect information about you from other sources and combine it with other information collected about you from third party websites not affiliated with us. For example, advertiser and advertising networks, as well as data analytics companies who service them, may participate in online behavioral advertising and track your activity across various sites and/or devices where they display ads and record your activities, so they can show ads that they consider relevant to you. Do Not Track: Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the Network Advertising Initiative and the Digital Advertising Alliance opt-out links above. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. However, our Cookie Policy provides information and opt-out links to help you control the collection of information about you on our Website. These third parties may also provide us with information about your interactions with their products and services and/or activities on third party websites. For example, use of Service functions that connect to your social media account (e.g., Facebook Connect) may permit us access to your social network profile information, including your first name, last name, gender, birth date, and email address, in accordance with your settings on the social network. If you choose to post information to your social media account via the Services, you will be making this information available to other users of these Services. We encourage you to be careful about revealing any sensitive details about yourself via our Services or otherwise. 2. How We Use Your Personal Information And The Basis On Which We Use It We may use the information we collect from and about you for the following purposes:

• • Identification and authentication: We use your identification information to verify your identity and/or eligibility for our Services when you access and use our Services and to ensure the security of your personal information. This is so we can comply with our obligations to you.

• • Improving our Services: We analyze information about how you use our Services to provide an improved experience for our customers, including product testing, site analytics, and personalizing content to your interests. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Services and improve them.

• • Understanding our users: We also analyze information about our users in order to understand our users (their demographics, what you do on our Services, what features you like, how they use them etc.). It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand our users and improve our Services.

• • Operating the Services: We process your personal information to administer our Services, diagnose technical problems, provide customer support, complete your transactions, and otherwise manage our business. This is so that we can comply with our contractual obligations to you.

• • Communicating with you: We may use your personal information when we communicate with you, for example, if we are sending you communications that you have requested, communications which relate to Services you have purchased or enrolled in, which may be of interest to you in accordance with your preferences if we are providing information about changes to the terms and conditions, if you contact us with questions, or to provide you with customer support. It is in our legitimate interests that we are able to provide you with the appropriate information, responses, and provide you with notices about our Services. Please see the section “Reviewing, changing, or deleting information” for further information about how you can control these communications.

• • Marketing: We may use your personal information to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. It is in our legitimate interest to provide you with more relevant and interesting advertising messages and inform our marketing strategy. We may use automated decision-making to deliver tailored advertisements based on your personal information. Where necessary, we will obtain your consent before sending such marketing messages.

• • Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example, to detect, prevent, and respond to fraud claims, intellectual property infringement claims, or violations of law or our Terms of Use.

• • Complying with our obligations: We may process your personal information in order to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law.

• • Customizing your experience: When you use the Services, we may use your personal information to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests. We may use automated decision-making to customize your experience based on your personal information.

• • Compensating our partners: We may process your personal information for purposes of calculating compensation to be paid to our third-party product/service providers and distributors and to analyze usage across products, services, and distribution partner/channel. It is in our legitimate interest to appropriately determine amounts to be paid to our partners and inform our product roadmap and distribution strategy.

• • Delivering prizes: may use your personal information to deliver prizes in connection with contests and sweepstakes, deliver perks earned in connection with certain incentive programs, or otherwise facilitate the use of our Services.

• In Connection with Webinars and Courses: In addition to the uses described above, if you are enrolled in and/or take any of our Webinars and/or Courses, we may use the registration information you provide, including personally identifiable information, to use through your Account for managing and processing purposes, including but not limited to tracking attendance, progress and completion of Course and/or Webinar. As part of our management and processing of each Course and/or Webinar, we may use this information to proctor exams, projects, and other assessments for each Course and/or Webinar. For example, as part of a Webinar that provides CE credits, we will use certain information collected from you in order to verify your identity or to monitor your performance during the exam to confirm that you are abiding by the rules or requirements for obtaining CE credits. We may share such information that we collect from you when you participate in a Course with the company (if any) and/or lecturer(s) who provided, taught, managed, sponsored, or otherwise oversaw that Webinar or Course, and, where applicable, you will be subject to such third party’s privacy policies; and (ii) that third party may use the personally identifiable information you provide for its own marketing purposes. If you do not want us to share your personal information with these companies, please contact us at infor@Beststartup US.us.

We may also aggregate and de-identify your information in such a way that you may not reasonably be re-identified by us or any other company, and may use this information for any other purpose. 3. How We Share The Information We Collect We will not share the personal information we collect about you with any third party except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared. We will share your information in the following ways:

• • Our suppliers, subcontractors, and business partners: (“service providers”): We may share your data with our services providers and business partners who perform marketing services and other business operations for us for the purposes set forth above. For example, we may partner with companies to process secure payments, fulfill orders, optimize services, serve online behavioral advertising, send newsletters and marketing messages, support email and messaging services, and analyze information. These service providers are required to treat the data in accordance with confidentiality requirements.

• • Service requests: We enable you to request information and/or services from third-party service providers or partners by filling out a registration, information request, or similar service request form for specific services from them (e.g., filling in a sponsored partner’s form to identify your retirement risk profile and/or submitting a request with such information for more information from that partner or another party). When you fill out and submit a service request form through our Website, you consent to our providing your personal information and request to the third-party provider and/or partner. Sharing this information with the party provider and/or partner allows them to contact you using the contact information you provided. Additionally, we have other contractual partners that that utilize their own service provider to supplement our offering, and we share your information with them in order to attempt to provide the services requested.

• • Webinars/Courses: We may share certain information with third parties that enable us to provide you the Webinars and/or Courses. For example, but not as a limitation, our Webinar and Course platforms may be hosted by third parties who will use your information to allow you to access the Webinar and/or Course. We also use third-party payment providers who will use your information to process payment, subject to their own privacy policies. Additionally, for any continuing education eligible Webinar, we will share information provided to us as well as information regarding your completion of such Webinar with the organization issuing continuing education certificates, including without limitation, for the purpose of verifying your eligibility for the continuing education credits. We may also use third party customer service platform providers in order to help us provide customer service capabilities in connection with your use of one or more of our Services, including without limitation the Webinars and/or Courses.

• • Group Companies: We may share your information with our affiliates, which are entities under common ownership or control of our ultimate parent company, IAC/InterActiveCorp for marketing purposes, security, optimization of products and services, and internal reporting. We do this for the purposes set out above.

• • Where required by law: We may disclose your information with law enforcement agencies, courts, other government authorities, or other third parties when we believe in good faith that such disclosure is appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Service for the Services you accessed, and/or to protect the rights and property of Beststartup US, our employees, users, and the public, or to comply with legal or regulatory obligations. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

• • In the context of a transaction: we may share your personal information with potential transaction partners, service providers, advisors and other third parties in connection with the consideration, negotiations, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer or all or a portion of our assets or business. In such an event, we will seek to provide you with commercially reasonable notice, e.g., via email and/or notice on our website, of any change in ownership, incompatible new uses of your personal information, and choices you may have regarding your personal information.

• Advertisers and advertising networks: Advertisers and advertising networks place ads on our Website. These companies may collect information, such as your computer’s IP address, browser information, and mobile device ID as you use our Website and Services. These companies, as well as data analytics companies who service them, may also use cookies, pixel tags, mobile device advertising IDs and other similar technologies to collect this information when you visit our Website (for example, web pages visited), as described in our Cookie Policy. They use the data to enable them to track your activity across various sites where they display ads and record your activities, so they can show ads that they consider relevant to you. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties.

In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US or the Swiss-US Privacy Shield, Beststartup US is potentially liable. 4. Data Retention and Access We will retain your personal data only for as long as necessary for the purposes it was retained, such as to enable you to use the Website and your products or to provide services to you. In some instances, we may retain data for longer periods in order to comply with applicable laws (including those regarding document retention), resolve disputes with any parties, and otherwise as necessary to allow us to conduct our business. All personal data we retain will be subject to this Privacy Policy and our internal retention guidelines. We respect your control over your information and, upon request, we will seek to confirm your identity and whether we hold or are processing information that we have collected from you. You also have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event, we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please email us at admin@beststartup.us. 5. Your Rights and Your Privacy Choices You have certain rights regarding the personal information we hold about you, subject to local law. These may include the rights to access, correct, delete, restrict, or object to our use of, or receive a portable copy in usable electronic format of your personal information. You may also have a right to lodge a complaint with your local data protection or privacy regulator. You also have choices when it comes to the privacy practices described in this Privacy Policy. A few of those choices are set forth below and others are available in our Cookie Policy. Choices relating to the information we collect: We may be required by law to collect certain personal information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent us from providing certain Services or all of the Services to you. Online behavioral advertising: You may opt-out of third-party advertising-related cookies, pixel tags, and web beacons, in which case our advertising should not be targeted to you. You will continue to see advertisements on the Website. However, they will not be tailored to you. You can choose to opt-out through these (and other) websites:

• • Network Advertising Initiative (http://www.networkadvertising.org/)

• • Digital Advertising Alliance (http://www.aboutads.info/consumers)

• Your Online Choices (http://www.youronlinechoices.com/)

Mobile devices: 

• • Advertising: When using a mobile application you may receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. We do not control how the applicable platform operator allows you to control receiving tailored in-application ads; thus, you should contact the platform provider if the above options are no longer available.

• Location Information: When you use one of our location-enabled services (for example, when you access Services from a mobile device), we may need to collect and process information about your specific GPS location (including the latitude, longitude or altitude of your mobile device) and the time the location information was recorded, and we may use that information to customize the Services with location-based information, advertising, and features. Some of these services require your personal data for the feature to work and we associate location data with your device ID and other information we hold about you. You can stop your location information from being collected by disabling this function within the settings available on your device. In connection with currency conversion functionality found on our site (if applicable), “By using our website, you (the visitor) agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a session cookie in your browser (a temporary cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency.”

We encourage you to contact us at the contact information set forth below to update or correct your information if it changes or if the personal information we hold about you is inaccurate. Where you have provided your consent to any use of your personal information, you can withdraw this consent at any time. Please note that we may require additional information from you in order to honor your requests. If you would like to discuss or exercise any rights you may have under law, please contact us at the contact information set forth below. 6. Automated Decisions About You When you use the Services, we may make automated decisions about you based on your personal information in the following circumstances:

• • To deliver personalized offers, discounts, or recommendations based on your shopping history, viewing history, and browsing history, and

• To serve you with ads based on various factors such as the content of the page you are visiting, the information you provide such as your age or gender, your searches, demographic data, user-generated content, and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests.

7. Right to Access, Review, Change or Delete Information To access, review, change, or delete the personal information we have collected from you contact us at admin@beststartup.us Your specific rights regarding access, review, revision, or deletion of your information is dictated by local laws. Legal rights applicable to personal data collected in the EEA. Pursuant to the EU General Data Protection Regulation (Regulation 2016/679) natural persons (called data subjects) are afforded certain rights regarding their personal data, including the right access, correct, delete, restrict or object to our use of, and receive a portable copy in a usable electronic format of your personal information. You also have the right to withdraw any consent that you have previously provided to us and to lodge a complaint with your local data protection or privacy regulator. If you would like to exercise any of the rights outlined above, and the law of your jurisdiction requires us to honor that request, please send your request in writing to the address in the “Contact Us” section below. To assist us in processing your request in a timely manner, please make your request in English if you are able to do so. Your request should include any information relevant to your request, including, without limitation: (i) your name, email, and postal address; (ii) the specific right you are asserting (e.g., removal); and (iii) if you are requesting removal, a brief explanation of why you believe such information should be removed. To help us prevent fraudulent removal requests, please also include a legible copy of a document that verifies your identity. You need not provide a government-issued document; a utility bill or similar mailing will suffice. You may also obscure parts of the document such as identifying numbers so long as the document continues to clearly identify you. If you are making the request on behalf of another person, please indicate your relationship to that person and provide evidence of your authority to make such a request. All requests for removal will be reviewed by Beststartup US’s legal and compliance team and we reserve the right, in compliance with applicable laws, to accept or reject, or make further inquiries regarding, any requests. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 8. How We Protect Your Information We take the security of your information seriously and use appropriate technical and organizational measures to protect your information against unauthorized or unlawful processing and against accidental loss, destruction, or damage. We also limit access to information about you t employees who reasonably need access to it to provide products and services to you, or in order to do their jobs. However, because no security can be 100% effective, we cannot completely guarantee the security of any information we have collected from you. If you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately as described in this Privacy Policy. 9. Retention of Your Information We retain the information we collect about and from you for as long as necessary to fulfill the purpose we collected it for and for the purpose of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for the personal information we process, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, accounting, or reporting requirements. In some circumstances, we may choose to aggregate and de-identify your information in such a way that you may not reasonably be re-identified by us or any other company in which case we may use this information indefinitely without further notice to you. In some circumstances, you can ask us to delete your data: see Right to Access, Review, Change, or Delete Your Information. 10. Use Outside the United States of America The Website and any Beststartup US mobile applications are controlled and offered by Beststartup US, LLC from the United States of America, and, regardless of your place of residence, your use of them is governed by the law of the State of New York, USA. Beststartup US makes no representations that the Website and any Beststartup US mobile applications are appropriate for use in other locations or are legal in all jurisdictions. Those who access or use the Website and any Beststartup US mobile applications from other locations do so at their own risk and are responsible for compliance with local law. You consent to the transfer and processing of your data in the United States of America and any other jurisdiction throughout the world. As a U.S. company, this Privacy Policy is provided in English. 11. Linked Sites and Advertisements The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites. We have relationships with third-party providers to provide content, products, services, and functionality through the Services. Such providers may collect information from you directly, in which case the provider’s privacy policy (which may differ from this Privacy Policy) would apply. If you have any questions regarding the privacy policy of any of our providers, you should contact the provider directly for more information. 12. Notice to Nevada Residents Under Nevada law, Nevada residents may opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we don’t have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please go to NevadaPrivacy@[CLIENT].com to provide your name and email address. We may share your data as explained in this privacy policy, such as to enhance your experiences and our services, and those activities will be unaffected by a Nevada do not sell request. You may also have other choices regarding our data practices as set forth elsewhere in this privacy policy. 13. International Data Transfer If you are receiving the Services from outside the United States, your personal data will be transferred to and stored in our servers in the U.S. By using the Services, you consent to our collection and use of your data as described in this Privacy Policy. Further, if you are receiving the Services from the European Economic Area (the “EEA”) we note that your information may be transferred to, stored, and processed in a country that is not regarded as providing the same level of protection for personal information as the laws of your home country, and may be available to the government of those countries under a lawful order made in those countries. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. We may also transfer data to the U.S. under the Privacy Shield framework which requires them to provide similar protection to personal data shared between the EU and the US. 14. EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework The Website complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union and Switzerland to the United States, respectively. Beststartup US has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Beststartup US’s certification for the Website and mobile applications, please visit https://www.privacyshield.gov. In compliance with the EU-US and Swiss-US Privacy Shield Principles, Beststartup US commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us at the address set forth in the “Contact Us” section below. Beststartup US has further committed to refer unresolved privacy complaints regarding the Website or mobile applications under the EU- US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit the BBB EU PRIVACY SHIELD web site for more information and to file a complaint. Please note that if your complaint is not resolved through the channels listed in this Privacy Policy, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. Beststartup US is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). 15. Contact Us If you have questions or concerns regarding the way in which your personal information has been used, or if you want to opt-out of having your personal information shared with third parties or for any purpose that is materially different than the purpose you shared it with us please send a request to the following address with a preference on how our response to your request should be sent to admin@beststartup.us All requests sent via regular mail must be labeled “Your Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code (your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping). Beststartup US is the controller (as provided under the laws applicable to EEA jurisdictions) responsible for all the personal information we collect and process. We are represented in the EU by our affiliate, IAC Search & Media UK, Ltd., which can be contacted at: admin@beststartup.us If you have questions or concerns regarding the way in which your personal information has been used, or if you want to opt-out of having your personal information shared with third parties or for any purpose that is materially different than the purpose you shared it with us please send a request to the following address with a preference on how our response to your request should be sent to: admin@beststartup.us All requests sent via regular mail must be labeled “Your Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code (your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping). Beststartup US is the controller (as provided under the laws applicable to the EEA jurisdictions) responsible for all the personal information we collect and process. If you have questions or concerns regarding the way in which your personal information collected in the EEA is processed or transferred, please contact us at the address set forth above. We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence. California Privacy Notice Updated February 26, 2020 This California Consumer Act Privacy Notice (“CCPA Notice”) applies to “Personal Information” (PI) of “Consumers” as defined by the California Consumer Privacy Act (“CCPA”). We collect and share the following categories of PI from the corresponding sources and for the corresponding purposes set forth in the table below.

Category of Personal Information	Sources of Personal Information	Purposes for Collection	Categories of Third Parties with whom Personal Information is Shared	Purposes of Third Parties Receiving PI
1. Identifiers and Personal Records (e.g., email address, name, address, IP address, credit card number)	Directly from you; your devices; Vendors	Performing Services; Processing and managing interactions and transactions; Quality Assurance; security; debugging; marketing	Vendors which assist us in providing services and running our internal business operations (“Vendors”); Data Analytics Partners; Corporate affiliates	Performing Services on our behalf; managing interactions and transactions; Quality assurance; security; debugging
2.  Customer Acct. Details/Commercial Information (e.g., details of your use of our service)	You; your devices; Vendors	Performing Services; Research and development; quality assurance; security; debugging; and marketing	Data Analytics Partners; Vendors; Corporate affiliates	Performing Services on our behalf; research and development; quality assurance; security; and debugging
3. Internet Usage Information (e.g., information regarding your interaction with our services)	You; your devices; Data Analytics Partners; Vendors	Performing Services; Research and development; quality assurance; security; debugging; and marketing	Data Analytics Partners; Advertising Networks; Vendors; Corporate affiliates	Performing Services on our behalf; research and development; quality assurance; security; and debugging
4. Inferences (e.g., your preferences, likelihood of interest in certain of our services)	Data Analytics Partners; Vendors; Advertising Networks	Research and development; quality assurance; and marketing	Data Analytics Partners; Vendors; Advertising Networks; Corporate affiliates	Performing Services on our behalf; research and development; quality assurance; marketing

In addition, we may collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy. We do not knowingly “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third-party cookies and tracking devices associated with our websites and mobile apps may constitute a “sale” of your PI as defined by the CCPA. You can exercise control over browser-based cookies by adjusting the settings on your browser. Further, you can learn more about your choices regarding certain kinds of online interest-based advertising with the Digital Advertising Alliance or the Network Advertising Initiative. We do not represent that these third-party tools, programs or statements are complete or accurate. Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you, so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate. California Consumers have the right to exercise privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”).  In order to verify your identity, we will send you an email to the email address that you provide to us, and you must take action as described in our email. This will enable us to verify that the person who made the request controls and has access to the email address associated with the request. We will check our systems for the email address that you provide, and any information associated with such email address. If you provide us with an email address that has not been used to interact with us, then we will not be able to verify your identity. In other words, the only reasonable method by which we may verify the identity of individuals is if we have an email address on file that was provided to us in relation to our services. We will be unable to fulfill your request if we cannot verify your identity. Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response. We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request if your request is excessive, repetitive, unfounded, or overly burdensome. To make a request according to your rights to know or to request the deletion of your PI set forth below, where you will find a description of the process we use to verify your request and any information that we will need to confirm your identity.  For your specific pieces of information, as required by the CCPA, we will apply heightened verification standards, which may include a request to provide further information. You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

• • The categories of PI we have collected about you.

• • The categories of sources from which we collected your PI.

• • The business or commercial purposes for our collecting or selling your PI.

• • The categories of third parties to whom we have shared your PI.

• • The specific pieces of PI we have collected about you.
    • A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred. A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain: The categories of your PI we have sold.

• • The categories of third parties to which we sold PI, by categories of PI sold for each third party.

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request. Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you. You may alternatively exercise more limited control of your PI by instead exercising one of the following more limited opt-outs, including unsubscribing from email newsletters. We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data.  In addition, we may offer you financial incentives for the collection, sale and retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly. Cookie Policy We use cookies, pixel tags, web beacons, mobile device IDs and similar files or technologies to collect and store the information we automatically collect about your computer, device, and Service usage. We use the term “cookies” in this policy to refer to cookies and all such similar technologies that collect information automatically when you are using our Services. If you do not accept the use of these cookies, please disable them using the instructions in this cookie policy. In this Cookies Policy, we use the term Beststartup US (and “we”, “us” and “our”) to refer Beststartup US. What is a cookie? Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are widely used in order to make websites work, or to work more efficiently, as well as to provide information to the owners of the site Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies may tell us, for example, whether you have visited our Services before or whether you are a new visitor. They can also help to ensure that adverts you see online are more relevant to you and your interests. There are two broad categories of cookies:

• • First party cookies, served directly by us to your computer or mobile device.

• Third party cookies, which are served by a third party on our behalf. We use third party cookies for functionality, performance / analytics, advertising, and social media purposes.

Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are ‘permanent cookies’, meaning that they survive after your browser is closed. They can be used by websites to recognize your computer when you open your browser and browse the Internet again. How do we use cookies? We use cookies to:

• • track traffic flow and patterns of travel in connection with our Services;

• • understand the total number of visitors to our sites on an ongoing basis and the types of internet browsers (e.g. Chrome, Safari or Internet Explorer), operating systems (e.g. Windows or MacOS), and screen resolutions used by our visitors;

• • monitor the performance of our Services and to continually improve them;

• • customize and enhance your online experience; and

• enable Beststartup US and third-party advertising both on and off this website.

We also use a third party, such as comScore, parse.ly, and Google Analytics to gather general information about how people use our website for the purposes of website optimization and analytics. What types of cookies do we use? The types of cookies used by us and our partners in connection with the Services can be classified into one of five categories, namely ‘essential website cookies’, ‘functionality cookies’, ‘analytics and performance cookies’, ‘advertising cookies’, and ‘ social media cookies’. We’ve set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.

Types of Cookie
Type of cookie	What it does	How to block
Cookies necessary for essential website purposes	These cookies are essential to provide you with services available through this website and to use some of its features.	Please see the instructions set out in ‘How to control or delete cookies’ below.
Functionality Cookies	Functionality cookies record information about choices you’ve made and allow us to tailor the website to you. These cookies mean that when you continue to use or come back to the Services, we can provide you with our services as you have asked for them to be provided. For example, these cookies allow us to offer store accessibility options.	Please see the instructions set out in ‘How to control or delete cookies’ below.
Performance / Analytics Cookies	We use performance/analytics cookies to analyze how the website is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the website. For example, these cookies allow us to:Better understand our website visitors so that we can improve how we present our content;Test different design ideas for particular pages, such as our homepage;Collect information about site visitors such as where they are located and what browsers they are using;Determine the number of unique users of the website;Improve the website by measuring any errors that occur; andConduct research and diagnostics to improve product offerings.	To see an overview of privacy at Google and how to opt out of certain Google practices, visit Google’s Privacy Policy. Please also see the instructions set out in ‘How to control or delete cookies’ below.
Advertising and Tracking Cookies	As you use our website, you will notice that it features advertising. We allow third party advertising companies to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the web. These cookies are anonymous — they store information about the content you are browsing, but not about who you are.Cookies also allow us and third parties to know whether you’ve seen an ad or a type of ad, and how long it has been since you’ve last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.	All the ad companies or networks that we work with have their own privacy policies and offer a mechanism for users to opt out tracking and behavioral targeting available through the ad itself or through the opt out mechanisms listed in the ‘How to control or delete cookies’ section below.
Social Media Cookies	On some pages of our website, third parties that provide applications through our website may set their own anonymous cookies in order to track the success of their applications or customize applications for you. For example, when you share an article using a social media sharing button on our website (e.g., Facebook, Twitter, or Google Plus), the social network that has created the button will record that you have done this. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by Beststartup US. Some pages of our website may also contain embedded content, such as video content from YouTube, and these sites may set their own cookies.	Please see the instructions set out in ‘How to control or delete cookies’ below.

How to control or delete cookies You have the right to choose whether or not to accept cookies and we have explained how you can exercise this right below. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our websites.

• • Most browsers allow you to change your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser.

• If you only want to limit third party advertising cookies, you can turn such cookies off by using self-regulatory programs such as Your Online Choices, Network Advertising Initiative, or Digital Advertising Alliance.

If you are in the European Union you can manage your cookie settings by clicking on the link below: Cookie Settings Need More Information? If you would like to find out more about cookies and their use on the Internet, you may find the following links useful:

• • All About Cookies

• youronlinechoices.com

Cookies that have been set in the past If you have disabled one or more Cookies, we may still use information collected from cookies prior to your disabled preference being set, however, we will stop using the disabled cookie to collect any further information. Contact us If you have any questions or comments about this cookies policy, or privacy matters generally, please contact us via email here or the address provided below: admin@beststartup.us Terms of Use Updated March 14, 2019 Welcome to the www.Beststartup US.us website (“Site”) operated by Beststartup US, LLC. By visiting and using this Site you will be accepting these Terms of Use (“TOU“). The TOU governs your access to and use of the Site and any of the Services we provide through the Site (together the “Services”). Please read them carefully and if you disagree with the TOU in any way, then do not use this Site or any of the Services. Beststartup US reserves the right to post changes to the TOU on this Site at any time. If we make any material changes to this TOU, we will post the updated TOU here, along with its effective date, and notify you by email or by means of a notice on our Site. If any TOU changes are not acceptable, you must stop your use of this Site. In these TOU, “Beststartup US” and “we” refer to Beststartup US, LLC, and “User” or “you” refer to each visitor to this Site. If you subscribe to any Services offered through this Site, you may also be subject to additional terms and conditions (“Terms of Service” or “TOS“) applicable to such Services, which will be brought to your attention at that time. Sites and Services We do not guarantee that access to or use of this Site or any Services will be uninterrupted or error free, and Beststartup US shall not be liable for any feature not being accessible or for any unavailability of its Site and Services. The Site and its features may be expanded, limited or modified at any time by Beststartup US to meet the needs of its Users, or for technical or other reasons, without advance notice or reason. We may also in our sole discretion, and at any time, discontinue providing, temporarily or permanently, any or all of the Site or Services, without notice. To access some of the content or features of the Site or its Services, Users may need to enhance or update the hardware or software in their computer systems. Beststartup US assumes no responsibility for any failure to access the Site or any Services, partially or fully, whether due to the User’s system, the Internet network or any other cause. Minors We do not provide information or services to minors, and if you are under 18, and at least 13 years of age, you may only use this Site and/or the Services with the active involvement of a parent, guardian or other supervising adult. You may not use this Site if you are under 13 years of age. No Individual Investment Advice This Site does not provide individual or customized legal, tax, accounting, or investment services. Since each individual’s situation is unique, a qualified professional should be consulted before making financial decisions. Message Web Site Content Limitations We make no guarantees as to the accuracy, thoroughness or quality of the information on this Site or through the Services, which is provided only on an “AS-IS” and “AS AVAILABLE” basis at User’s sole risk. This information may be provide by third parties and Beststartup US shall not be responsible or liable for any errors, omissions or inaccuracies in the Site content. The information and investment, accounting, or legal strategies provided at this Site are neither comprehensive nor appropriate for every individual. Some of the information is relevant only in Canada or the U.S., and may not be relevant to or compliant with the laws, regulations or other legal requirements of other countries. It is your responsibility to determine whether, how and to what extent your intended use of the information and Services will be technically and legally possible in the areas of the world where you intend to use them. You are advised to verify any information before using it for any personal, financial, accounting, legal, or business purpose. In addition, the opinions and views expressed in any article on this Site are solely those of the author(s) of the article and do not reflect the opinions of Beststartup US or its management. The Site content and services may be modified at any time by us, without advance notice or reason, and Beststartup US shall have no obligation to notify you of any corrections or changes to any Site content. License to Use Site Content We grant you a limited personal use license to access, display, download, format and print portions of this Site content solely for your own personal non-commercial use, provided that the content is not modified and all proprietary notices are kept intact. You may not reproduce, publish, translate, merge, sell, rent, distribute the content, or create a derivative work of the content on any other website or as part of any educational, training or reference materials. You may not frame or utilize framing techniques to enclose any content on this Site. Please note that, if you purchase any Courses (as defined herein) through the Beststartup US Academy that purchase is subject to specific license rights provided for in the Beststartup US Academy section of this TOU (below). Third Party Content Any testimonials, opinions, advice, product or service offers, or other information or content made available on or through this Site by third parties (“Third Party Content”) are solely those of their respective providers and not of Beststartup US which does not guarantee the accuracy, completeness, reliability or usefulness of Third Party Content. It is the responsibility of the User to evaluate Third Party Content and Beststartup US shall not be liable for any damage or loss caused by Users’ reliance on or other use of Third Party Content. Content Posted by Users To the extent we enable you to, and you choose to post or share any content or materials, including, without limitation, through the AI Service (e.g. questions) or through the Beststartup US Academy Service (e.g., quizzes, homework, projects, etc.) (“User Content”) you will be: (a) granting Beststartup US a fully transferable, sub-licensable (with rights to sublicense, including, without limitation, through multiple tiers) to display, perform, reproduce, modify, transfer, distribute and create derivative works from the User Content and to associate your public profile information (if any) with such User Content, in any media formats and through any channels (whether now known or hereafter developed) and waiving any moral rights in favor of Beststartup US with respect to such use of the User Content; (b) granting Beststartup US a perpetual, world-wide, royalty-free, fully paid-up, non-exclusive license to allow your materials to be edited and displayed by Beststartup US on its Site, and accessed by Users, for the purposes and on the terms as set out in these TOU; (c) agreeing to indemnify and hold harmless Beststartup US and its Users from any claim or demand made by any third party due to or arising out of your User Content; and (d) representing that you own or otherwise have the right to post the User Content, that the User Content is accurate, that use of the User Content on the Site does not violate any laws, and that the materials will not cause injury to any person, including without limitation to the intellectual property, personal or privacy rights of others. Beststartup US shall have the right to use your name in connection with your posted User Content. Beststartup US reserves the right to remove or modify any User Content for any reason, including without limitation, if we believe it violates these TOU. If you choose to post any User Content and interact with other users, if applicable, please be respectful of other users and use common sense when posting comments. Remember that anything you post online may be perpetually available and is not confidential or private. Do not post anything you would not be comfortable sharing or being made public. Beststartup US Widgets Beststartup US may, in its sole discretion, provide certain widgets subject to this TOU (the “Widgets”). By accessing and using any Widget (including copying any Widget html code), you agree to be bound by the following:

• • You may only display the Widget(s) on a website you own and operate;

• • You may not modify any Widget including without limitation that you may not change any code, obscure or disable any element of any Widget, tag links to Beststartup US with a “no follow” attribute or similar mechanism;

• • You agree not to make any representations or warranties (express or implied) about Beststartup US or the Site;

• • You may not suggest or imply any affiliation with, sponsorship, or endorsement by Beststartup US;

• • You may not place the Widget on any site that contains any content that is in any way unlawful, harmful, obscene, harassing, or racially, ethnically, or otherwise objectionable. Additionally, you may not place the Widget on any site that infringes any Beststartup US intellectual property or other rights, or violates any applicable law;

• • Beststartup US grants you a non-transferable, non-exclusive, revocable right to download/display the Widget solely in accordance with the terms of TOU (ii) solely in connection with the Widget, to use our logos, trademarks, trade names and other intellectual property contained in the Widget. This TOU does not grant you any right in any Beststartup US code, content, logos or trademarks beyond the limited permission to display the Widget granted herein.

• Beststartup US reserves the right at any time to terminate or modify your permission to display the Widget. The Widgets are subject to change from time to time in our sole discretion. We may cease to return content from the Widget at any time in our sole discretion.

Account Creation General. Some of the Services offered by Beststartup US require you to create an account. When you create an account, you agree that you have the authority to create that account and that all information you provide will be true, accurate, current, and complete. You are solely responsible for keeping your login information (e.g., user ID and password) accurate, secure, and confidential. You are also responsible for any activity resulting from use of your login information. You agree to immediately inform us if you suspect that your login information has been comprised. We are not liable to you for any losses or damages you incur resulting from unauthorized use of your login information. Social Sign in. If you login or sign in using social networking functionality, e.g., Facebook, you agree to abide by the applicable social network’s terms and conditions. Advisor Insights – for Users Beststartup US may offer certain services, including, for example, Beststartup US’s Advisor Insights service (the “AI Service”), which allow users to engage in one or another manner with a network of third party experts and advisors (including by submitting proposed questions to be posed to financial planning and personal finance professionals). Your use of and reliance on such services, if any, is entirely at your own risk, and you are solely responsible for complying with this TOU at all times. Your submissions (including any public profile information associated with such submission) and any associated responses from our advisor network, all of which materials constitute Third Party Content under this TOU, may be displayed in publicly viewable forums. Submission of a question does not guarantee a response will be provided. Please note that we also enable you to follow individual advisors by clicking on the “follow” button on an advisor’s Beststartup US profile page and providing your email address. If you choose to follow any advisor, you agree to receive weekly recaps of the advisors content via an email newsletter. You may unsubscribe from receiving an advisor newsletter at any time by clicking the opt-out link in any email communication from us and/or by accessing the “Manage Subscriptions” page on our Site. Please also see our “Communications” section below for more information on how we may communicate with you regarding the AI Service and other services we offer. IMPORTANT: No Client Relationship; No Privilege. By answering questions, advisors do not intend to form, and do not form an advisor-client, planner-client, or any other direct privileged or professional relationship with any user of the Site. Please keep in mind that laws, regulations, other governing authorities, standards, practices and procedures that apply to your particular question may differ depending on your location. Additionally, none of the Third Party Content will be treated as private or confidential, nor is it protected by attorney-client, or any other privilege, and it may be read, collected, and used by Beststartup US and others. Search engines may index your questions, answers, and other Third Party Content to allow such content to appear in search engine results (e.g. if someone does a search on google.com or another search engine, your questions, answers, and other Third Party Content on our Site that relate to the search may appear in the search results list with links to your questions, answers, and other Third Party Content). PLEASE NOTE: Beststartup US does not provide tax, accounting, legal, investment, or financial services. The information available through Beststartup US’s AI Service is provided by third parties and solely for informational purposes on an “as is” basis at user’s sole risk. The information is not meant to be, and should not be construed as advice or used for investment, financial planning, legal, accounting, or tax purposes. Beststartup US makes no guarantees as to the accurateness, quality, or completeness of the information and Beststartup US shall not be responsible or liable for any errors, omissions, inaccuracies in the information or for any user’s reliance on the information. User is solely responsible for verifying the information as being appropriate for user’s personal use, including without limitation, seeking the advice of a qualified professional regarding any specific financial, legal, accounting, or tax questions a user may have. While Beststartup US may edit questions provided by users for grammar, punctuation, profanity, and question title length, Beststartup US is not involved in the questions and answers between advisors and users, does not endorse any particular financial, legal, accounting, or tax professionals that provide answers via the AI Service, and is not responsible for any claims made by any advisor. Beststartup US is not endorsed by or affiliated with any state/provincial/territorial bar association or other legal or accounting membership organization or association, tax authorities, or agencies or associations, or the Financial Industry Regulatory Authority (FINRA) in the U.S., the Investment Industry Regulatory Organization of Canada (IIROC) or any other financial regulatory authority, agency, or association. POSTS ARE NOT CONFIDENTIAL. The Advisor Insights is a forum-based service and any information and materials you submit in connection with your profile and/or any questions you pose to any one of the advisors via the AI Service may be displayed in publicly viewable forums. Advisor Insights – for Advisors Participation in the AI Service as an advisor involves a vetting and approval process. Acceptance into the AI Service is at Beststartup US’s sole discretion and may be based on such factors as licenses/registrations, designations, assets under management, SEC/FINRA or IIROC disclosures, applicable state/provincial/territorial regulator information, federal/state/provincial/territorial agencies in connection with tax and/or accounting licensing boards and/or agencies, and other considerations deemed relevant by Beststartup US in its sole discretion. By applying to the AI Service, you are representing and warranting to the accuracy and completeness of all information provided to Beststartup US during and after the application process. If accepted into the AI Service, you agree to promptly notify Beststartup US if any information previously provided becomes incorrect or otherwise obsolete. Participation in the AI Service requires, at a minimum, that you maintain your status as a registered financial advisor. You shall be solely responsible for ensuring ongoing compliance with all registration requirements and any obligations imposed by applicable regulators and/or your employer. Should you lose your status as a registered financial advisor, or if there has been any other material change to your profile or the information submitted as part of the application process (including if you become subject to any legal or regulatory action, proceeding or sanctions), you agree to immediately cease participating in the AI Service, and to promptly notify Beststartup US so that your profile may be suspended or removed. By applying for and/or participating in the AI Service, you acknowledge that the purpose of the AI Service is to be a source of general information and education for Beststartup US’s users at large and, accordingly, while answers you publish through the AI Service may include analysis of different options and considerations given the facts indicated by the questioners, answers may not include a recommendation that the questioner take a specific course of action. Specifically,

• For financial advisors, your answers must not (i) recommend or promote specific securities, funds, or other investments, (ii) advertise or promote your specific qualifications, experience, or past performance, or (iii) directly solicit Beststartup USers as clients.

Your participation in the AI Service is specifically to allow you to provide answers to questions posed through the AI Service. Beststartup US does not answer AI Service questions itself, nor does it provide tax, investment, financial, tax, accounting, or legal services. Beststartup US is under no obligation to review, edit or verify the usefulness, reliability, completeness or accuracy of any answers you publish through the AI Service, and Beststartup US expressly disclaims any and all liability in connection with your answers or other submissions through the AI Service, for which you shall be solely liable. Beststartup US does, however, reserve its right to remove any answer or other content from the AI Service or the Beststartup US website generally, in its sole discretion, and with or without advance notice. By publishing an answer to an AI Service question, you are attesting to such answer’s veracity, completeness and accurateness, as well as having all necessary rights to publish such answer. By submitting an answer you additionally grant Beststartup US a worldwide, non-exclusive, irrevocable, royalty-free right and license (with rights to sublicense, including, without limitation, through multiple tiers) to display, perform, reproduce, modify as to format or appearance but not substance, transfer and distribute such content (with or without your associated public profile information), in any media formats and through any channels (whether now known or hereafter developed). In addition, by submitting an answer, you waive all moral rights in such content in favor of Beststartup US. You agree to not post the identical answer on any website other than your own personal or professional website, and social media platforms. In addition to participating in the AI Service by providing answers to users’ questions, you will also have the opportunity to contribute other content for inclusion on our website, including without limitation, articles. All such additional submissions are in our discretion and are subject to this TOU. By submitting any such content, you grant Beststartup US a worldwide, non-exclusive, irrevocable, royalty-free right and license (with rights to sublicense, including, without limitation, through multiple tiers) to display, perform, reproduce, modify as to format or appearance but not substance, transfer and distribute such content (with or without your associated public profile information), in any media formats and through any channels (whether now known or hereafter developed). In addition, by submitting such content, you waive all moral rights in such content in favor of Beststartup US. You agree to not post the identical content on any competing website. You agree to indemnify and hold Beststartup US harmless from and against any claims arising out of or related to your participation in the AI Service, including those alleging that any answer or other content you submit to or publish through the AI Service, or your participation in the AI Service, violates any law or regulation or infringes or otherwise violates any intellectual property or other proprietary right of any person or entity. You are not entitled to or eligible for any compensation or benefits with respect to your participation in the AI Service. Your participation in the AI Service is solely in your discretion. You are, and at all times shall be, an independent contractor, and nothing in this TOU is intended or should be construed to create a partnership, joint or co-venture, franchise, agency or employer-employee relationship between Beststartup US and you. You will take no position with respect to or on any tax return or application for benefits, or in any proceeding directly or indirectly involving Beststartup US that is inconsistent with your being an independent contractor (and not an employee) of Beststartup US. You are not the agent of Beststartup US and you are not authorized, and must not represent to any third party that you are authorized to make any commitment, assume any obligation, undertake any liability or otherwise act on behalf of Beststartup US. This TOU, and our relationship, is a commercial, arm’s-length relationship and does not create any special or fiduciary relationship. In your capacity as an independent contractor, you agree that you: (i) determine, in your sole discretion and judgement, the time, mode, manner, method and means used by you in your participation in the AI Service; (ii) have the right to control how such participation is to be performed; (iii) may accept or choose not to participate in the AI Service; and (iv) are free to accept work from persons, firms and other third parties other than Beststartup US. If, notwithstanding the foregoing, you are reclassified as an employee of Beststartup US, or any affiliate of Beststartup US, by the U.S. Internal Revenue Service, the U.S. Department of Labor, the Canada Revenue Agency or any other federal, state/provincial/territorial or foreign agency as the result of any administrative or judicial proceeding, you agree that you will not, as the result of such reclassification, be entitled to or eligible for, on either a prospective or retrospective basis, any compensation or employee benefits under any plans or programs established or maintained by Beststartup US. Webinars In the event that Beststartup US makes general education and/or continuing education webinars available to financial advisors or others (each a “Webinar” and together “Webinars”), the below applies in addition to the rest of the terms of this TOU. You understand and agree to receiving communications from Beststartup US and/or providers of these Webinars, including as set forth in the “Communications” section of this TOU. Beststartup US reserves the right at any time and for any reason and without notice to you, to change, modify, suspend, or cancel access to and/or any and all of the Webinars and/or services related to the Webinars, in whole or part.

• • Continuing Education. Beststartup US may offer continuing education Webinars that are Certified Financial Planner Board of Standards Inc. (“CFP Board”) and/or Investments & Wealth Institute® (“IWI”) approved. Beststartup US will identify which Webinars are approved for such credit on the landing page(s) for each Webinar. You understand and agree that Beststartup US may be required to share information regarding your participation in and/or completion of such certified program to the CFP Board and/or IWI in order for you to be eligible for and/or receive continuing education credits.

• General Education. Beststartup US may offer Webinars that are for general education and are not approved for any credit by any professional or state/provincial/territorial board or organization or by any educational institution.

For Informational Purposes Only. Each Webinar and any content or materials provided in connection with any Webinar is for informational purposes only. Information may not be applicable for each state/province/territory and/or jurisdiction. Beststartup US cannot guarantee that any information provided in a Webinar will be accurate, complete, and/or current at all times. We make no representations or warranties regarding the quality of the Webinar content, related materials, or any instructor. All Webinar content is owned by or licensed to Beststartup US and/or its licensed content providers, and all such rights are reserved. You may not reproduce, upload, transmit, distribute, publicly display, sell, publish, copy, or otherwise use the Webinar, and/or any content or materials provided in connection with any Webinar for any commercial purpose without Beststartup US’s express written consent. The appearance of any instructor in any Webinar is not and shall not be deemed an endorsement or recommendation of that instructor by Beststartup US and the views expressed in any Webinar are those of the instructor and not Beststartup US. Beststartup US online courses General. Beststartup US offers online information courses, workshops, classes and other educational programs relating to the world of finance to you for a fee (“Course(s)”) through its Beststartup US Academy services. For clarity, the Beststartup US Academy is included as part of the Services offered by Beststartup US. Beststartup US may also offer you the ability to engage in communication with fellow users taking the Courses. This TOU, including this section specifically on Beststartup US Academy, govern your purchase, use and/or access to any Course. You must login to your account to sign up for a Course. Beststartup USes third party services to provide the platform for the Courses as well as for payment processing and those third parties may have access to your information for the purposes of providing the Course Services. Please note that we may communicate with you as set forth in the “Communications” section of this TOU in connection with the provision of the Beststartup US Academy and/or other Beststartup US services. Informational Purposes Only. These Courses are offered for information purposes only. Neither Beststartup US, nor any person providing instruction in any Course, is providing you legal, accounting, investment or financial advice. You are solely responsible for confirming the accuracy and appropriateness of the information for your own uses with your tax, finance, or legal advisor. Beststartup US’s provision of any Course or the appearance of any specific person instructing any Course is not a recommendation by Beststartup US of that Course, the content contained therein or the person providing instruction. We do not employ any instructors and are not responsible or liable to you for any interactions between you and any instructor or any other user of the Services. We make no representations or warranties as to the quality of any Course or instructor. No Academic Credit. Beststartup US is not an accredited educational institution. Your participation in, or completion of, any Course does not confer any academic credit. Nothing in this TOU or otherwise through the Services or on our Site, enrolls you in any educational institution or in any course offered by any such institution. Payment. Each Course, bundle of Courses, or subscription package (the “Online Course Offering”) is offered for certain price as listed on the relevant landing page. All fees are in U.S. dollars. To purchase an Online Course Offering you must provide one or more Payment Methods. You represent and warrant that you are authorized to use any and all Payment Method(s) you use to purchase an Online Course Offering. You agree to pay for all Beststartup US products and services that you purchase, and agree that we may charge your selected payment method through our third party payment processor for any such payments. If your payment method fails, we may collect fees owed or use other collection methods. We may also suspend or terminate your access to our Services. For some Payment Methods, the issuer may also charge you certain fees, such as foreign transaction fees or other fees relating to the processing of your Payment Method. Local tax charges may vary depending on the Payment Method used. Check with your provider for details. “Payment Method” means a current, valid, accepted method of payment as may be updated from time to time and which may include payment through your account with a third party). We use a secure third party payment processor(s) for the Online Course Offering. These payment processors accept payment methods as detailed on the payment page. Information that you supply to our payment processors is not stored or controlled by us and is subject to the third-party payment processors’ privacy policy and terms and conditions. To the extent allowed under applicable law, we disclaim all liability with regard to any problems you have with any third party payment processors.Refunds. For individually purchased Courses, Beststartup US will provide a full refund in limited circumstances where the user has viewed less than 50% of the applicable Course, and such request for refund occurs within 30 days of the purchase date. For Courses purchased as part of a bundle, Beststartup US will provide a full refund in limited circumstances where the user has viewed less than 50% of all content in the bundle and such request for refund occurs within 30 days of the purchase date. For subscription purchases, Beststartup US will provide refunds in accordance with the Subscription section below. In order to request a refund, user must contact Beststartup US.  Taxes. If you elect to access or use Services that involve payment of a fee, then you agree to pay that fee and all taxes associated with such access or use, including, if applicable, any sales tax Beststartup US believes in good faith that it is required to collect Beststartup US may collect taxes (e.g., sales tax or VAT) on any transaction where it reasonably believes that tax collection is required. Where Beststartup US believes in good faith that VAT collection is required for any Course, VAT will be calculated and added once your billing information is provided. You will indemnify and hold Beststartup US harmless against any and all claims by any tax authority for any underpayment of VAT, and any penalties and/or interest thereon. Beststartup US is unable to provide you with tax advice and you should consult your own tax advisor. Compliance with Laws. You agree to comply with all applicable laws in connection with your purchasing and/or viewing of any Course. Further, access to our Courses from certain territories is prohibited. You agree that you will not violate any data export laws in connection with your purchase and/or viewing of the Courses if you reside outside the United States. Course Ownership. We and our licensors own all right, title and interest in and to the Course(s) and related materials. We and/or third party licensors either own or have all necessary rights in and to the content contained in any Course (e.g., lectures, video lessons, quizzes, presentation materials, assignments, images, text, displays, documents, audio and/or video clips, HTML, etc.). The foregoing includes any and all copyrights, trademarks, or other proprietary rights under applicable law. Nothing contained in this TOU or in any Course conveys to you any ownership or other proprietary right except as otherwise set forth herein. Any Beststartup US logos and/or trademarks that appear in any Course are our property and may not be used without our express written consent. All other trademarks, service marks and logos used in connection with any Course, with or without attribution, are the trademarks, services, or logos of their respective owners and may not be used without their express written consent. Your Use of the Courses. Subject to your compliance with this TOU and any other guidelines or policies we include through the Services, Beststartup US grants you a limited, non-transferable, non-sublicenseable, non-exclusive, revocable license to make non-commercial, personal use of the Courses you purchase. Purchase of a Course only entitles you to the view the Course, and is not a purchase of the software or content included in the Course. Except as set forth below, Beststartup US reserves the right to terminate your access to the Site at any time for any reason or no reason at all, with or without notice to you. Unless you have, as determined in our sole discretion, violated this TOU, such termination will not terminate your right to view any Courses you have already purchased. You may not transfer your account to any other person or use anyone else’s account. Except as otherwise expressly permitted in this TOU, you are prohibited from and may not copy, sell, re-sell, display, reproduce, publish, modify, creative derivative works from, transfer, distribute, or commercially exploit the Courses and/or any related materials; and Beststartup US reserves the right to pursue legal action against you in connection with any unauthorized use of the Courses, the related materials, or your violation of this TOU, whether at law or equity. Subject to your satisfactory completion of a Course, as determined by Beststartup US in its sole discretion, Beststartup US may provide you with a certificate of accomplishment upon conclusion of the applicable Course. You acknowledge that any such certificate merely indicates completion of a Course and is not affiliated with any college, university, company, or other certifying institution, and does not stand in the place of a course taken at any academic institution and does not convey academic credit or certification for any such academic institution and neither Beststartup US nor any instructor has any obligation to you to assist you in obtaining any such credit or certification. Indemnification. You agree to indemnify and hold Beststartup US harmless from and against any claims arising out of or related to your use of the Beststartup US Academy Service, including without limitation, for your violation of any law or regulation or if your use infringes or otherwise violates any intellectual property or other proprietary right of Beststartup US or any person or entity. Modification and/or Termination of Courses. We reserve the right to at any time, modify or discontinue, temporarily or permanently any one of the Courses or the Beststartup US Academy in whole or part. You agree that we are not liable to you or any third party for any such modifications, suspension, or termination of any or all Courses. Nothing in this TOU shall be construed to obligate us to maintain and/or support any of the online Course services, in whole or part, during the term of this TOU or thereafter. Subscription Services Subscription Services: Beststartup US may offer certain paid subscription services in certain regions. If you enroll in any Beststartup US paid subscription service, your subscription will continue month-to-month until terminated. You agree that your account will be subject to this automatic renewal feature. Billing: Unless you cancel your subscription(s) before your monthly billing date, you authorize us to charge your next month’s subscription fee to your Payment Method. You also authorize Beststartup US to charge you for any sales or similar taxes that may be imposed on your subscription payments. Such fees will be charged on the calendar day corresponding to the commencement of your subscription. Payment Methods and Subscriptions: In order to enroll in an Beststartup US paid subscription service you must provide one or more Payment Methods. We may update your Payment Method using information provided to us by our payment processors. Following an update, you authorize us to continue to charge the applicable Payment Method(s). You agree to promptly update all information to keep your Payment Methods current, complete, and accurate (such as change in billing address, card number, or expiration date), and you must promptly notify Beststartup US if your Payment Method is canceled (or if you lose your credit card or it is stolen), or if you become aware of a potential breach of security (such as an unauthorized disclosure or use of your name or Account password). Changes may be made by visiting your Learned Dashboard at academy.Beststartup US.com and submitting an updated payment method which will be received by our payment processor. You authorize us to charge any Payment Method associated with your account in case your primary Payment Method is declined or no longer available to us for payment of your subscription fee. You remain responsible for all unpaid amounts. If any payment it not successfully settled due to expiration, insufficient funds, or otherwise, and you do not cancel your account, we may terminate your access to the service until we have successfully charged a valid Payment Method. If you initiate a chargeback or otherwise reverse a payment made with your Payment Method, Beststartup US may in its discretion terminate your account immediately. If Beststartup US successfully disputes the reversal, and the reversed funds are returned, you are not entitled to a refund or to have your account or subscription reinstated. Refunds and Cancellations: If you cancel your subscription and request a refund within the first 30 days of your subscription, we will refund your initial payment. Thereafter you can cancel your subscription at any time, and you will continue to have access to the subscription service through the end of your monthly billing period. To the extent permitted by the applicable law, payments are non-refundable and we do not provide refunds or credits for any partial-month subscription periods or unwatched Beststartup US content. Notwithstanding the forgoing, if you cancel within 3 business days of signing up for a paid subscription, we will refund your full subscription fee; however, we may charge you (or withhold from your refund) the prorated value of the subscription service used by you and your account during this 3-business day period. Price and Subscription Plan Changes: We may change the subscription plans available and / or the price of our service from time-to-time, provided that any price changes will apply to you no earlier than 30 days following notice to you. We may offer several different subscription plans, including special promotional plans and some plans may have different terms and conditions, which will be provided to you at sign-up or through other communications to you. Virtual Cash and Virtual Securities If you register for the Site’s Stock Market Game, you may accrue virtual cash and securities (“Virtual Assets”) that may be used and virtually spent in the Site environment. Virtual Assets are a limited license right, distributed at our discretion, and have no monetary value. You may not sell, transfer or trade Virtual Assets, except as permitted on the Site in accordance with the rules of the Stock Market Game, which we may change at any time at our sole discretion. You shall not acquire any ownership right to Virtual Assets. We may terminate your license right and withdraw or discontinue any Virtual Asset, or may remove your right to use any particular Virtual Asset at any time for any reason, with or without notice to you. Incentives, Rewards, Discounts and Other Promotional Offers Beststartup US may offer incentives, offers, promotions, discounts, sweepstakes, or contests in connection with its Services. In the case of sweepstakes or contests, you will be provided separate terms and conditions that must be agreed to in order to be eligible for participation in any sweepstakes and/or contests. In connection with any incentives, rewards, or similar programs (For example, but not limited to, the Advisor Insights incentives program for financial advisor users and discount codes for Beststartup US Academy), any such program is issued at Beststartup US’s sole discretion and cannot be transferred, bartered or sold or used for a purchase where payment is made using payment information (e.g., a credit card number or PayPal account). Any such incentives and/or programs are not a payment instrument; they are issued without any exchange of money or value from you and you have no vested property right or interest in the incentives. Beststartup US reserves the right to cancel or revoke any incentives or programs, or your participation therein, for any reason or no reason whatsoever, including, without limitation, if it determines in its sole discretion that you have violated these terms, the terms specific to any rewards, incentive, or other program, or the rest of this TOU. Beststartup US reserves the right in its sole discretion at any time and without prior notice to you, to add to, remove or otherwise change the terms applicable to the issuance and use of any incentive, offers, promotions or other similar program. Beststartup US may, at its sole discretion, offer discounts to Beststartup US Academy courses. Such discounts are not applicable toward past purchases and cannot be combined with any other offers or promotions. Discounts apply toward the purchase price of an Beststartup US Academy course, only, and cannot be applied toward taxes or other fees. Discounts offered by Beststartup US have no cash value, and are nontransferable. No cash/credit back. Each discount code may only be used once, and only one discount code may be used per purchase. Beststartup US reserves the right to modify or discontinue accepting any discount code or other discount at any time without notice. Void where prohibited by law. In the event of any violation of this TOU or other terms of any discount offered by Beststartup US, Beststartup US shall be entitled to suspend and/or revoke access to your Beststartup US Academy account. Broker Reviews In the event that Beststartup US makes available reviews of online brokers (each a “Review” and together the “Reviews”), the below applies in addition to the rest of the terms of these TOU. You understand and agree to receiving communications from Beststartup US, including as set forth in the “Communications” section of this TOU. Beststartup US reserves the right at any time and for any reason and without notice to you, to change, modify, suspend, or cancel access to and/or any and all of the Reviews. For Informational Purposes Only. Each Review is provided for informational purposes only. Information may not be applicable for each state/province/territory and/or jurisdiction. Beststartup US cannot guarantee that any information provided in a Review will be accurate, complete, and/or current. We make no representations or warranties regarding the quality of the Review content. You may not reproduce, upload, transmit, distribute, publicly display, sell, publish, copy, or otherwise use the Review, and/or any content or materials provided in connection with any Review for any commercial purpose without Beststartup US’s express written consent. The publication by Beststartup US of any Review is not and shall not be deemed an endorsement or recommendation of that broker by Beststartup US and the views expressed in any Review are those of the Reviewer and not Beststartup US. The information contained in a Review may be different from the information provided when you visit the website of a financial institution, service provider or specific product. When evaluating online brokers, please review the online broker’s own terms and conditions. We do not make any warranties or representations regarding the quotes, fees, terms, rates, coverage or services offered or made available by online brokers. We do not guarantee that quotes, fees, terms, rates, coverage or services offered by online brokers are the best available. We are not involved with and are not responsible for any fee arrangement that you may enter into with any online broker or other service provider. You hereby release us of any and all losses, costs, damages or claims in connection with, arising from or related to your use of a service provider’s products or services. Beststartup US may receive compensation from online brokers when a user applies or gets approved for a financial product through our Website. Compensation may influence which products and brokers we review and write about, and whether products appear on our Website. The Website does not purport to feature every online broker or financial product available on the market. Exam Preparation Materials In the event that Beststartup US makes available study guides and other exam preparation information, including study guides and/or links to such materials on third party sites (collectively the “Exam Prep”), the below applies in addition to the rest of the terms of these TOU. You understand and agree to receiving communications from Beststartup US, including as set forth in the “Communications” section of this TOU. Beststartup US reserves the right at any time and for any reason and without notice to you, to change, modify, suspend, or cancel access to and/or any and all of the Exam Prep material. All Exam Prep material and information available on Beststartup US or third party sites linked-to through Beststartup US are for informational purposes only. Exam content review, methods of study, tips and sample questions are only recommendations, and use of this material does not guarantee passing any exam. While Beststartup US has made reasonable efforts to provide current and accurate information, Beststartup US will not be held liable for any unintentional errors or omissions that may be found. Beststartup US is not affiliated, approved, or endorsed by FINRA, the NFA, NAASA, the CFA Institute, CMT Association, GARP, IIROC or the IRA. Viruses Beststartup US does not guarantee that files available for downloading through its Site will be free of infection or viruses or other code that may have contaminating or destructive properties. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for integrity, security and accuracy of data input and output, and for maintaining a means external to the Site for the reconstruction of any lost data. Advertisers Are Not Endorsed Though we seek to partner with quality companies, we are not responsible for the claims or representations made by advertisers and sponsors. Beststartup US does not review, endorse or recommend the products or services of any company mentioned on our Site. We will not be liable in any way for damages of any kind resulting out of the misuse of any personal information or data submitted by you to an advertiser or sponsor. Links As a convenience to Users, the Site and Services may provide links to other sites or resources. Because we do not review and have no control over such sites and resources, Beststartup US shall not be responsible or liable for use of or reliance on any content, products, services or information at such sites or resources. Inclusion of any links does not imply any endorsement, affiliation, approval, association or sponsorship by Beststartup US of the linked websites, resources, their operators or owners. When you select a link, you may be leaving our Site. The information available on third parties websites may have certain restrictions on its use or distribution which differ from this TOU. Prohibited Conduct The following activities are strictly prohibited:

• • Posting unsolicited or unauthorized advertising, promotional materials, junk mail, spam, chain letters, pyramid schemes, or any other form of solicitation (“Spamming”);

• • Postings for any unlawful or fraudulent purpose (including links);

• • Posting of personal information (for yourself or anyone else);

• • Posting materials containing viruses or other malicious or destructive code;

• • Posting of offensive content including profanity, obscenity, racist or pornographic material;

• • Engaging in any activities that are defamatory, violate the personal privacy rights of others, or infringe any person’s rights, including but not limited to, collecting and distributing information about Internet users without their permission, except as permitted by applicable law;

• • Posting any content that is unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libelous, hateful, degrading to others on the basis of gender, race, class, ethnicity, national origin, religion, sexual preference, disability or other classification or otherwise objectionable in any way;

• • Copying, modifying, creating a derivative work of, reverse engineer, reverse assemble or otherwise attempt to discover any source code of the Site or Services;

• • Removing or obscuring the copyright notice or other notices displayed in connection with the content accessible through the Site or Services;

• • Interfering with or disrupting the Site functionalities, Services, or servers and networks connected to Site, or disobeying any requirements, procedures, policies, or regulations of networks connected directly or indirectly to the Site;

• • Modifying the Site or Services in any manner or form, or using modified versions of the Site or Services, including (without limitation) for the purpose of obtaining unauthorized access to the Site or Services;

• • Reproducing, printing, caching, storing, or distributing content retrieved from the Site or Services in any way not authorized by this TOU or for any commercial use without the prior written permission of Beststartup US;

• • Selling, assigning, sublicensing, or otherwise transferring any right in the Services or content accessible through the Site;

• • Accessing the Site or Services by any means other than through the interface that is provided by Beststartup US;

• • Using the Site or Services to violate any law (whether local, state/provincial/territorial, national, or international), whether or not intentionally;

• • Impersonating any person or entity, or falsely stating or otherwise misrepresenting your affiliation with any person or entity;

• • Manipulating identifiers in order to disguise the origin of any question, answer or comment you post on the Site;

• • Engaging in “screen scraping,” “database scraping,”; and/or

• Facilitating violations of this TOU or the Privacy Policy.

Privacy This Site may collect personal information from some Users. Please review our Privacy Policy to understand what information we collect and store, how that information is used, how we may share that information, and your rights in connection with your personal information. The Privacy Policy is incorporated by reference and made a part of this TOU. Communications When you visit our Site, use any of our Services, or send us an email, you expressly indicate your consent to electronically receive any and all communications, notices, and our disclosures that we may provide in connection with your use of the Site and/or Services, including, without limitation, e-mail, in-app, and in-website chat communications. All agreements, notices and communications that we provide to you by email will satisfy all legal requirements that they be in writing and delivered to you. Beststartup US will have the right to disclose any email sent by a User, or any objectionable material, to comply with legal process or to protect the rights or property of Beststartup US, its customers, suppliers and Users. Any such notices may also include emails with promotional, marketing, and advertising information and recommendations that we believe may be of interest to you, in accordance with applicable law. Consistent with federal CAN-SPAM or anti-spam laws, if you do not wish to receive commercial emails, you may unsubscribe following the instructions on any email, excepting that we may still send you administrative and transactional notices, including, without limitation, information about your Account, confirmation of your registration for Courses, information about your progress, or other services that may be necessary to provide you with any one of the Services. If you provide your telephone number to us when you register for an Account or use other Beststartup US Services on the Site, you expressly consent to receive autodialed or prerecorded calls and text messages from Beststartup US at that number. If a telephone number is a mobile telephone number, you hereby consent to receive SMS or text messages at that number. We may place such calls or texts to (i) notify you about your account and any use thereof; (ii) provide you with services associated with the Online Courses, Webinars, etc.; (iii) troubleshoot problems with your account; (iv) resolve disputes; (v) contact you with offers and promotions; or (vii) as otherwise necessary to service your account or enforce these TOU, our policies, applicable law, or any other agreement we may have with you. We will not share your phone number with third parties for their purposes without your consent. We may share your phone numbers with our Affiliates or with our service providers, such as customer support, billing or collections companies, who we have contracted with to assist us in pursuing our rights or performing our obligations under these TOU, our policies, applicable law, or any other agreement we may have with you. You agree these parties may also contact you using autodialed or prerecorded calls and text messages, as authorized by us to carry out the purposes we have identified above, and not for their own purposes. Standard telephone minute and text charges may apply. You understand and consent that we may, in our discretion, monitor or record telephone conversations you or anyone acting on your behalf has with us or our agents for quality control and training purposes or for our own protection. You acknowledge and understand that, while your communications with us may be overheard, monitored, or recorded, not all telephone lines or calls may be recorded by us, and we do not guarantee that recordings of any particular telephone calls will be retained or retrievable. Feedback We welcome all feedback, ideas, inventions, materials, and suggestions (“Feedback”) from our Users regarding our Services. You understand and agree that Beststartup US does not waive any rights to use similar and/or related Feedback previously or contemporaneously known to it, whether developed by its employees, contractors, obtained from other sources, or submitted by other Users. Further, by submitting any Feedback, you grant us the right to use the Feedback without any restrictions on the use of such Feedback or any compensation to you. Proprietary Rights The Beststartup US Site and its content are protected by copyright, trademark, and other proprietary laws. See our Copyright Notice. Reporting Copyright Infringement. Beststartup US takes claims of copyright infringement seriously. We will respond to notices of alleged copyright infringement that comply with applicable law. For U.S. users, if you believe any materials accessible on or from the Site infringes your copyright, you may request removal of those materials (or access to them) from the Site by submitting written notification to our Copyright Agent (designated below). In accordance with the Digital Millennium Copyright Act (17 U.S.C. § 512) (“DMCA“), the written notice (the “DMCA Notice“) must include substantially the following:

• • Your physical or electronic signature.

• • Identification of the copyrighted work you believe to have been infringed, or, if the claim involves multiple works on the website, a representative list of such works.

• • Identification of the material you believe to be infringing in a sufficiently precise manner to allow us to locate that material.

• • Adequate information by which we can contact you (including your name, postal address, telephone number, and, if available, e-mail address).

• • A statement that you have a good faith belief that use of the copyrighted material is not authorized by the copyright owner, its agent, or the law.

• • A statement that the information in the written notice is accurate.

• A statement, under penalty of perjury, that you are authorized to act on behalf of the copyright owner.

You may submit your DMCA Notice to the address below: admin@beststartup.us. If you fail to comply with all of the requirements of Section 512(c)(3) of the DMCA, your DMCA Notice may not be effective. Please be aware that if you knowingly materially misrepresent that material or activity on this website is infringing your copyright, you may be held liable for damages (including costs and attorneys’ fees) under Section 512(f) of the DMCA. Repeat Infringers. It is our policy in appropriate circumstances to disable access to this Site and/or terminate the accounts of users who are repeat infringers of these TOU. Subscription Services Although Beststartup US offers services in many parts of the world, certain Beststartup US services may not be available in or suitable for certain countries or locales. We reserve the right to discontinue or to make changes to, our Site and any of our Services at any time without advance notice. DISCLAIMER OF WARRANTIES THE SITE AND SERVICES ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY. NO CONTENT ON OUR SITE IS INTENDED TO CONSTITUTE PROFESSIONAL ADVICE, WHETHER MEDICAL, FINANCIAL, LEGAL OR OTHERWISE. YOUR USE OF THE SITE, THE WIDGETS AND SERVICES IS AT YOUR SOLE RISK. THE SITE, THE WIDGETS AND SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. BESTSTARTUP US MAKES NO REPRESENTATION OR WARRANTY THAT THE SITE, THE WIDGETS OR SERVICES WILL MEET YOUR REQUIREMENTS, OR WILL BE UNINTERRUPTED, SECURE, CURRENT OR ERROR-FREE, OR THAT THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SITE, THE WIDGETS, AND SERVICES WILL BE ACCURATE, TIMELY, USEFUL OR RELIABLE. TO THE GREATEST EXTENT PERMITTED BY LAW, BESTSTARTUP US DISCLAIMS ALL WARRANTIES, REPRESENTATIONS AND CONDITIONS OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES AND CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT, WITH RESPECT TO THE USE OF THE WIDGETS THE SITE, AND ITS SERVICES, OR THE ACCURACY, COMPLETENESS, TIMELINESS OR CURRENTNESS OF ITS CONTENT, IN ANY WAY AND FOR ANY PURPOSE. EXCLUSION OF CONSEQUENTIAL DAMAGES IN NO EVENT WILL BESTSTARTUP US BE LIABLE FOR ANY INCIDENTAL, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR INDIRECT DAMAGES ARISING OUT OF THE USE OF OR INABILITY TO USE THE WIDGETS THIS WEBSITE OR ANY OF ITS SERVICES OR CONTENT, OR LOSS OF DATA, EVEN IF BESTSTARTUP US HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND WHETHER BASED ON CONTRACT, TORT, NEGLIGENCE, PRODUCT LIABILITY, STRICT LIABILITY OR OTHERWISE. EXCLUSION OF LIMITATIONS AND DISCLAIMERS BECAUSE SOME JURISDICTIONS, SUCH AS NEW JERSEY, RESTRICT OR DO NOT ALLOW THE DISCLAIMER OF WARRANTIES, OR THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, IN SUCH JURISDICTIONS BESTSTARTUP US’S LIABILITY IS LIMITED TO THE GREATEST EXTENT PERMITTED BY LAW. General This TOU, and any applicable TOS, constitute the entire agreement between each User and Beststartup US governing the User’s access to and use of the Site and its Services, and supersede all prior agreements regarding its subject matter. The TOU shall be governed by the laws of the State of New York without giving effect to any principles of conflicts of laws. Each User hereby attorns and agrees to the non-exclusive jurisdiction of the courts of the New York, New York. The failure by a User or Beststartup US to exercise any right or to enforce any provision of this TOU shall not constitute a waiver of such right or provision. If any provision of this TOU is found by a court of competent jurisdiction to be invalid or unenforceable, the court shall give effect to the intentions reflected in the provision to the degree possible, and the other provisions of this TOU will remain in full force and effect. The parties have agreed that this contract and all related documents be drafted in English. Les parties aux présentes ont demandé et convenu que le présent contrat et tout document y afférent soient rédigés en anglais.