Last Updated March 25, 2025 Welcome to Qodeo! Thanks for using the Qodeo services (including its website, and mobile and web-based applications, and any other tools, products, or services provided by Qodeo that link to or reference these Terms or Privacy Policy) (collectively, the “Services”). The Services are provided by Qodeo, Inc., a Delaware corporation (“Qodeo”, “we,” “our,” or “us”), with an address at 1216 Broadway, Fl. 2 New York, NY 10023, U.S.A.

Part I: Qodeo^TM – Democratizing Venture^TM Terms of Service

By using our Services, you are agreeing to these Terms of Service (“Terms”). Please read them carefully.  Our Services are very diverse, so sometimes additional terms or product requirements (including age requirements) may apply. If additional terms or conditions are available with or applicable to the relevant Services, then those additional terms become part of your agreement with us if you use those Services.  By accessing or using the Services, you intend and agree to be legally bound by these Terms.  You may wish to print or save a local copy of the Terms for your records. YOU ACKNOWLEDGE AND AGREE THAT THESE TERMS OF SERVICE LIMIT OUR LIABILITY AND THAT YOU ARE RELEASING US FROM VARIOUS CLAIMS IN SECTIONS 9 AND 10 OF PART IBELOW. THESE TERMS ALSO CONTAIN A BINDING ARBITRATION PROVISION IN SECTION 15 OF PART I THAT AFFECT YOUR RIGHTS UNDER THESE TERMS WITH RESPECT TO THE SERVICES. WE DO NOT PROVIDE INVESTMENT ADVICE. DO NOT RELY SOLELY ON OUR SERVICES TO MAKE INVESTMENT DECISIONS. ALWAYS CONSULT WITH A QUALIFIED PROFESSTIONAL. QODEO, ITS OFFICERS, MEMBERS, EMPLOYEES, AND AGENTS SHALL HAVE NO RESPONSIBILITY WHATSOEVER FOR ANY ERROR OR INACCURACY IN ANY INFORMATION MADE AVAILABLE BY THE SERVICES OR FOR ANY INVESTMENTS OR OTHER DECISIONS YOU MAKE AS A RESULT OF USING THE SERVICES OR THE INFORMATION PROVIDED THEREIN.  YOU UNDERSTAND AND ACKNOWLEDGE THAT YOU ARE SOLELY RESPONSIBLE FOR CONDUCTING ANY NECESSARY DUE DILIGENCE REGARDING ANY DETERMINATION YOU MAKE TO INVEST OR NOT INVEST IN ANY GIVEN BUSINESS. WE EXPRESSLY DISCLAIM ANY LIABILITY RELATED TO ANY FAILURES AND/OR LOSSES YOU MAY INCUR AS A RESULT OF ANY INVESTMENT YOU MAKE, OR CHOOSE NOT TO MAKE, IN ANY BUSINESS OR INDIVIDUAL WITH WHOM YOU CONNECT OR INTERACT WITH VIA THE SERVICES. THE SERVICES DO NOT PROVIDE ANY STATEMENT OF THE ACTUAL OR PROJECTED FINANCIAL CONDITION OR A REVENUE FORECAST OF ANY BUSINESS OR INDIVIDUAL, AND ARE NOT INTENDED TO SERVE AS A SUBSTITUTE FOR FINANCIAL OR OTHER PROFESSIONAL ADVICE.  WE ARE NOT RESPONSIBLE FOR YOUR USE OF THE INFORMATION PROVIDED BY THE SERVICES.   YOU UNDERSTAND AND AGREE THAT QODEO DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES AND ALL LIABILITY WITH RESPECT TO THE INFORMATION PROVIDED BY THE SERVICES, INCLUDING FOR ANY ERRORS, INACCURACY OR INCOMPLETENESS.

1. Using our Services

You must follow any policies made available to you within the Services, including our Privacy Policy in Part II below. Don’t misuse our Services.  For example, don’t interfere with our Services, try to access them using a method other than the interface and the instructions that we provide, or extensively or automatically copy any content from the Services (in other words, no scraping). You may use our Services as permitted by law, including applicable export and re-export control laws and regulations. We may suspend or stop providing our Services to you if you do not comply with our terms or policies, if we are investigating suspected misconduct, or for any other reason. Using our Services does not give you ownership of any intellectual property rights in our Services or the content you access through them (“Content”). You may not use Content, except as permitted in these Terms, by its owner, or as otherwise permitted by law. These Terms do not grant you the right to use any branding or logos used in our Services, including the Qodeo name and logo. Don’t remove, obscure, or alter any legal notices displayed in or along with our Services. Our Services display some Content that is not our own.  For example, some Content belongs to our advertisers, other third parties, or other users (collectively, “Third Party Content”) or is Your Content (as defined in Section 5 of Part I below).  We are not responsible for, and you waive all of our liability with respect to, Third Party Content or Your Content.  Third Party Content and Your Content is the sole responsibility of the individual or entity that makes it available via the Services. We may review Third Party Content or Your Content to determine whether it is illegal or violates our policies, and we may remove or refuse to display Third Party Content or Your Content that we believe violates our policies or the law. But we do not generally review content beforehand, and we are not obligated to do so. In connection with your use of the Services, we may send you service announcements, administrative messages, and other information. You may opt out of our marketing emails by clicking on the “unsubscribe” link in marketing e-mails or disabling notifications in the Services’ settings. Please be aware that there may be a brief period before we are able to process your opt-out. Some of our Services are available on mobile devices, which may cause you to incur data charges with your wireless provider.  Please be aware that we have no control over these charges, and if you do not wish to be charged, you should stop using the mobile features (as applicable).

2. Your Qodeo Account

You may need an account in order to use the Services. If you create your own account, you agree that all registration information you give us will be accurate and current.  If your account has been assigned to you by an administrator, such as your employer or educational institution, different or additional terms may apply and your administrator may be able to access or disable your account.  You will timely notify us of any changes to any of the foregoing information.  You are responsible for controlling access to any PCs, mobile devices, or other end points that you allow to store your Services password, or on which you enable a “Remember Me” or similar functionality (“Activated Device”). Accordingly, you agree that you will be solely responsible for all activities that occur under your Services accounts, including the activities of any individual with whom you share your Services account or an Activated Device. To protect your account, keep your password confidential. You are responsible for the activity that happens on or through your account.  If you learn of any unauthorized use of your password, please contact us at our contact page. Each Qodeo account may only be used by one individual.  You understand and acknowledge that you may not share your account with anyone else and that doing so constitutes a material violation of these Terms for which we may suspend or terminate your account at any time without notice to you.

3. Payment

In order to access the Services, you may need to purchase a subscription (the “Subscription”).  For more information regarding Subscription pricing, please click here.  You agree to pay all amounts owed to us for the Services under any terms, policies or other written or electronic agreement we may have in place.  We may require you to maintain valid credit card or other payment account information with us in order to receive the Services, and if so, you hereby authorize us to charge your credit card or other payment account for the Services.  There are no refunds for any cancellation of a Subscription during the current billing cycle.  At the end of the current billing cycle, your Subscription will automatically renew unless you provide us with written notice via the form on our contact page of your intent to not renew your Subscription at least thirty (30) days prior to the end of the then current billing cycle.  If a payment cannot be charged to your credit card or if a charge is canceled for any reason, or if you fail to maintain valid, up-to-date payment information or to keep your payments current, we reserve the right to immediately either suspend or terminate your access and account immediately without notice, thereby terminating these Terms.  Any failure to maintain valid, up-to-date payment information with us or to keep your payments current will constitute a material breach of these terms, for which we may suspend or terminate your access to the Services immediately without notice.  Interest will be charged on all unpaid delinquent amounts at the rate of 1.5% per month or the highest rate permitted by applicable law, whichever is lesser.  You agree to reimburse us for all collection agency fees, attorneys’ fees and other costs we may incur to collect delinquent amounts you owe to us.

4. Privacy and Feedback

Our Privacy Policy in Part II explains how we treat your personal information and protect your privacy when you use our Services. By using our Services, you agree that we can collect, use, and share data from you as described in our privacy policy. We are not responsible for any information or Content that you share with others via your use of the Services.  You assume all privacy, security, and other risks associated with providing any information, including personally identifiable information, to other users of the Service. As between you and Qodeo, you understand and agree that Qodeo shall own all proprietary and intellectual property rights in and to the information generated by your use of the Services, and that we may use such data for any lawful business purpose without restriction. If you submit feedback or suggestions about our Services, you agree that we may use your feedback or suggestions without obligation to you.

5. Content You Submit or Share

You may submit, upload, and share videos, pictures, text and other content to or through the Services (“Your Content”), and in doing so you must follow these Terms and the rules and policies referenced in these Terms. You retain ownership of any intellectual property rights that you hold in Your Content. In short, what belongs to you stays yours. When you upload, submit, or otherwise share Your Content to or through our Services, you give us (and those we work with) a royalty-free, worldwide license in perpetuity (subject to any applicable privacy laws) to use, host, store, reproduce, modify, create derivative works (such as those resulting from translations, adaptations or other changes we make so that Your Content works better with our Services), communicate, publish, publicly perform, publicly display and distribute Your Content. The rights you grant in this license are for the limited purpose of operating, promoting, and improving our Services, and to develop new ones. This license continues even if you stop using our Services.  Make sure you have the necessary rights to grant us this license for any content that you submit to our Services. We may publicly display your profile information, posts, and actions you take on the Services, including displaying in ads and other commercial content. You may request that we delete any of Your Content that you submit to the Services by contacting us at https://app.qodeo.com/contact.  To the extent within our control, we’ll remove Your Content from public display and mark it for future deletion if permitted by applicable law; however, it may persist in backup or residual copies for a reasonable period of time (but will not be available to other users through the Services).  For purposes of clarification, once you submit or share Your Content with others via the Services (e.g., other users or third parties), we no longer have control over those portions of Your Content and will not be able to delete it or prevent them from using it. You agree that you will not use the Services to:

• Violate any law or a third-party’s rights;
• Submit excessive or unsolicited commercial messages or spam any users;
• Submit malicious content or viruses;
• Solicit other people’s login information, credit card numbers, or other sensitive information;
• Harass or bully other users; or
• Post content that is hate speech, threatening or pornographic, that incites violence or that contains nudity or graphic or gratuitous violence.

6. INTELLECTUAL PROPERTY PROTECTION

As we ask others to respect our intellectual property rights, we respect the intellectual property rights of others, and require our users and customers to do so.  If you are a copyright owner or its agent and believe that any content residing on or accessible through the Services infringes upon your copyrights, you may submit a notification under the Digital Millennium Copyright Act (“DMCA”) by providing our Copyright Agent (the “Designated Agent”) with the following information in writing (see 17 U.S.C § 512(c)(3) for further detail):

• Identification of the work or material being infringed.
• Identification of the material that is claimed to be infringing, including its location, with sufficient detail so that we are capable of finding it and verifying its existence.
• Contact information for the notifying party (the “Notifying Party”), including name, address, telephone number, and email address.
• A statement that the Notifying Party has a good faith belief that the material is not authorized by the copyright owner, its agent or law.
• A statement made under penalty of perjury that the information provided in the notice is accurate and that the Notifying Party is authorized to make the complaint on behalf of the copyright owner.
• A physical or electronic signature of a person authorized to act on behalf of the owner of the copyright that has been allegedly infringed.

Please also note that the information provided in a notice of copyright infringement may be forwarded to the user who posted the allegedly infringing content. After removing material in response to a valid DMCA notice, we will notify the user responsible for the allegedly infringing material that we have removed or disabled access to the material. We will terminate, under appropriate circumstances, users who are repeat copyright infringers, and we reserve the right, in our sole discretion, to terminate any user for actual or apparent copyright infringement. If you believe you are the wrongful subject of a DMCA notification, you may file a counter-notification with us by providing the following information to the Designated Agent at the address below:

• The specific URLs of material that we have removed or to which we have disabled access.
• Your name, address, telephone number, and email address.
• A statement that you consent to the jurisdiction of U.S. District Court for the Southern District of New York, and that you will accept service of process from the person who provided the original DMCA notification or an agent of such person.
• The following statement: “I swear, under penalty of perjury, that I have a good faith belief that the material was removed or disabled as a result of a mistake or misidentification of the material to be removed or disabled.”
• Your signature.

Upon receipt of a valid counter-notification, we will forward it to Notifying Party who submitted the original DMCA notification. The original Notifying Party (or the copyright holder he or she represents) will then have ten (10) days to notify us that he or she has filed legal action relating to the allegedly infringing material.  If we do not receive any such notification within ten (10) days, we may restore the material to the Services. The contact information for our Designated Agent is: Qodeo, Inc. Attention:  Copyright Agent 1216 Broadway, Fl. 2 New York, NY 10023, U.S.A. Contact:  https://app.qodeo.com/contact If you believe that any of your intellectual property rights other than copyrights have been infringed, please contact us at https://app.qodeo.com/contact.  We reserve the right, in our sole and absolute discretion, to suspend or terminate any user who infringes the intellectual property rights of Qodeo or others, and/or to remove, delete, edit or disable access to such person’s content.   You agree that we have no liability for any action taken under this section.

7. About Software in our Services

You may be required to download software (such as a mobile or desktop app) to use the Services or certain features of the Services, and the Services may enable you to access software running on our (or our vendors’) servers (collectively, “Software”).  You agree that we retain the ownership of all rights, title, and interest in and to the Software. Certain Software may update automatically on your device once a new version or feature is available, and you consent to such automatic updating. Qodeo gives you a worldwide, royalty-free, non-assignable, and non-exclusive limited license to use the Software to access the Services.  This license is for the sole purpose of enabling you to use and enjoy the benefit of the Services as provided by us, in the manner permitted by these Terms.  You may not copy, modify, distribute, sell, or lease any part of our Services or Software, nor may you reverse engineer or attempt to extract the source code of the Services or Software, unless laws prohibit those restrictions or you have our written permission. There may be software programs contained within certain Software that have been licensed to us by third parties. The term “Software” as used herein shall refer to this third-party software except where the term “Software” is used in the context of our ownership. The same terms and conditions, including all limitations and restrictions, set forth in these Terms apply to each third-party software program contained in the Software. You acknowledge and agree that any third-party components are owned by their applicable licensors. We do not make any representations or warranties about the operation or availability of such third-party software. Neither we, nor our licensors, shall be liable for any unavailability or removal of such third-party software. We are not responsible for any communications to or from such licensors, or for the collection or use of information by such licensors. You consent to the communications enabled and/or performed by such third-party software, including automatic updating of the third-party software without further notice. You agree that such third-party software licensors are intended third-party beneficiaries under these Terms.

8. Modifying and Terminating our Services

We are constantly changing and improving our Services. We may add or remove functionalities or features, and we may suspend or stop a Service altogether, at any time, without any notice or liability. You can stop using our Services at any time, although we’ll be sorry to see you go. We may also stop providing Services to you, or add or create new limits to our Services, at any time. Sections 8 – 15 of Part I will survive termination or expiration of these Terms indefinitely.

9. Our Warranties and Disclaimers

OTHER THAN AS EXPRESSLY SET OUT IN THESE TERMS, NEITHER QODEO NOR ITS LICENSORS, SUPPLIERS, ADVERTISERS, OR DISTRIBUTORS MAKE ANY SPECIFIC PROMISES ABOUT THE SERVICES. FOR EXAMPLE, WE DON’T MAKE ANY COMMITMENTS ABOUT THE CONTENT WITHIN THE SERVICES, THE SPECIFIC FUNCTIONS OF THE SERVICES, OR THE RELIABILITY OR AVAILABILITY OF THE SERVICES, OR THE ABILITY OF THE SERVICES TO MEET YOUR NEEDS.  WE ALSO DO NOT MAKE ANY WARRANTIES OR COMMITMENT RELATING TO NON-INFRINGEMENT, FREEDOM FROM VIRUSES OR OTHER HARMFUL CODE, OR ERROR-FREE OR UNINTERRUPTED OPERATIONS IN CONNECTION WITH THE SERVICES.  WE PROVIDE THE SERVICES AND ALL INFORMATION PROVIDED THROUGH THE SERVICES “AS-IS.” SOME JURISDICTIONS PROVIDE FOR CERTAIN WARRANTIES, LIKE THE IMPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. TO THE EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES. YOU AND YOUR HEIRS, SUCCESSORS, AND ASSIGNS HEREBY FOREVER IRREVOCABLY RELEASE, DISCHARGE, AND HOLD HARMLESS US, OUR AFFILIATES, AND OUR AND THEIR SUCCESSORS AND ASSIGNS, AND OUR AND THEIR OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS  (COLLECTIVELY, “RELEASED PARTIES”) FROM, AND AGREE NOT TO SUE ANY RELEASED PARTY FOR, ANY LIABILITIES, CLAIMS, OBLIGATIONS, SUITS, ACTIONS, DEMANDS, EXPENSES, AND DAMAGES WHATSOEVER (COLLECTIVELY, “LIABILITIES”) THAT YOU MAY HAVE AGAINST ANY RELEASED PARTY WHETHER EXISTING NOW OR IN THE FUTURE, WHETHER KNOWN OR UNKNOWN, ARISING OUT OF OR IN CONNECTION WITH YOUR OR A THIRD PARTY’S CONDUCT RELATED TO USE OF THE SERVICES. YOU UNDERSTAND AND ACKNOWLEDGE THAT THE FOREGOING SENTENCE RELEASES AND DISCHARGES ALL LIABILITIES, WHETHER OR NOT THEY ARE CURRENTLY KNOWN TO YOU, AND YOU WAIVE YOUR RIGHTS UNDER CALIFORNIA CIVIL CODE SECTION 1542. YOU UNDERSTAND THE MEANING OF CALIFORNIA CIVIL CODE SECTION 1542, WHICH READS AS FOLLOWS: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, AND THAT, IF KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.” BY AGREEING TO THESE TERMS AND THIS WAIVER, YOU ASSUME ALL RISK ARISING FROM YET UNKNOWN CLAIMS.

10. Liability for our Services

TO THE EXTENT NOT PROHIBITED BY LAW, QODEO (AND ITS OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS) AND OUR LICENSORS, SUPPLIERS, ADVERTISERS, AND DISTRIBUTORS, WILL NOT BE RESPONSIBLE FOR LOST PROFITS, REVENUES, OR DATA, FINANCIAL LOSSES OR INDIRECT, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES. TO THE EXTENT NOT PROHIBITED BY LAW, THE TOTAL LIABILITY OF QODEO (AND ITS OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS) AND OUR LICENSORS, SUPPLIERS, ADVERTISERS, AND DISTRIBUTORS, FOR ANY AND ALL CLAIMS UNDER THESE TERMS OR RELATING TO YOUR USE OF THE SERVICES, INCLUDING FOR ANY IMPLIED WARRANTIES, IS LIMITED TO THE AMOUNT YOU PAID US TO USE THE SERVICES (OR, IF WE CHOOSE, TO SUPPLY YOU THE SERVICES AGAIN). IN ALL CASES RELATING TO PROVIDING YOU THE SERVICES, QODEO (AND ITS OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS) AND ITS LICENSORS, SUPPLIERS, ADVERTISERS, AND DISTRIBUTORS, WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE THAT IS NOT REASONABLY FORESEEABLE OR THAT IS DUE TO EVENTS OUTSIDE OF OUR REASONABLE CONTROL, SUCH AS WARS, CRIMINAL ACTIVITIES, STORMS, DELAYS (INCLUDING, BUT NOT LIMITED TO, DELAYS SHIPPING THE PRODUCTS, OR FAILURES OR DELAYS OF COMMON CARRIERS), PUBLIC HEALTH EMERGENCY, NATURAL DISASTERS, ACTS OF GOVERNMENT, SUPPLY INTERRUPTIONS, OR TELECOMMUNICATION OR INTERNET FAILURES.

11. Business/Employer Uses of our Services

If you are using our Services on behalf of a business or employer, you are accepting these Terms on their behalf, and that business or employer agrees to be bound by these Terms.

12. Indemnification

You hereby agree to indemnify, defend, and hold harmless Qodeo, its affiliated companies, and its and their predecessors, successors, and assigns, and its and their respective directors, officers, employees, agents, representatives, partners, and contractors from and against all claims, losses, expenses, damages and costs (including, but not limited to, reasonable attorneys’ fees), resulting from or arising out of your actual or alleged breach of these Terms, any Content you provide through the Services, or your use or misuse of the Services.  However, you will not be responsible for claims, damages, and costs which are found by a court of competent jurisdiction to have arisen solely from our violation of applicable law.

13. About these Terms

We may modify these Terms or any additional terms that apply to a Service for any reason, for example, to reflect changes to the law or changes to our Services. You should look at the Terms regularly and the “Last Updated” date at the beginning of these Terms.  We’ll use reasonable efforts to give you notice of these modifications, such as posting notice of modifications to these Terms on this web page, through the Services, or via email.   By continuing to use the Services after we make these modifications, you agree that you will be subject to the modified Terms.  If you do not agree to the modified terms for a Service, you should discontinue your use of that Service. If there is a conflict between these Terms and any additional terms for a Service, the additional terms will control for that conflict. These Terms control the relationship between Qodeo and you. They do not create any third-party beneficiary rights (except in the limited case of Section 14 of Part I).  If you do not comply with these Terms, and we don’t take action right away, this doesn’t mean that we are giving up any rights that we may have (such as taking action in the future).  If it turns out that a particular term is not enforceable, this will not affect any other terms. The laws of the United States and the State of New York, excluding New York’s conflict of laws rules, will apply to any disputes arising out of or relating to these terms or the Services. You may not assign or delegate your rights or obligations relating to these terms or your account for the Services without our prior written consent.  We may assign these terms or assign or delegate any of our rights or obligations at any time. For information about how to contact Qodeo, please visit our contact page.

14. Third Party Terms

You agree that in addition to these Terms, your use of our mobile app is subject to the usage rules set forth in Apple’s App Store terms of service, if you download our app from the App Store, or in Google’s Play terms of service, if you download the app from Google Play, or any other third party platform, developer or distributor end-user license agreement and/or terms and conditions by which you agree to be bound when you download our mobile app or otherwise access the Services. Without limiting the generality of the foregoing, if you downloaded our mobile app from Apple, you and Qodeo acknowledge and agree to the following:  This agreement is concluded between you and Qodeo only, and not with Apple Inc. (“Apple”). The mobile app downloaded from Apple may only be used on Apple hardware products. Qodeo, not Apple, is solely responsible for the app and the content thereof. Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the app. To the maximum extent permitted by applicable law, Apple will have no warranty obligation whatsoever with respect to the app, and any other claims, losses, liabilities, damages, costs or expenses attributable to any failure to conform to any warranty will be Qodeo’s sole responsibility.  Qodeo, not Apple, is responsible for addressing any claims by you or any third party relating to the app or your possession and/or use of the app, including, but not limited to: (i) product liability claims; (ii) any claim that the app fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection or similar legislation.  In the event of any third-party claim that the app or your possession and use of the app infringes that third party’s intellectual property rights, Apple will have no responsibility for the investigation, defense, settlement and discharge of any such intellectual property infringement claim.  You represent and warrant that (i) you are not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a “terrorist supporting” country; and (ii) you are not listed on any U.S. Government list of prohibited or restricted parties.  Apple, and Apple’s subsidiaries, are third party beneficiaries of this agreement, and upon your acceptance of the terms and conditions of the agreement, Apple will have the right (and will be deemed to have accepted the right) to enforce the agreement against you as a third-party beneficiary thereof.]

15. Binding Arbitration

Without limiting your waiver and release in Section 9 of Part I, you agree to the following:

1. Purpose. Any and all Disputes (as defined below) involving you and Qodeo will be resolved through individual arbitration. In arbitration, there is no judge or jury and there is less discovery and appellate review than in court. This Section 15 of Part I (the “Arbitration Provision”) shall be broadly interpreted. Notwithstanding anything to the contrary in these Terms, this Section 15 of Part I does not apply to an action by either party to enjoin the infringement or misuse of its intellectual property rights, including copyright, trademark, patent or trade secret rights.
2. Definitions. The term “Dispute” means any claim or controversy related to the Services, including but not limited to any and all: (1) claims for relief and theories of liability, whether based in contract, tort, fraud, negligence, statute, regulation, ordinance, or otherwise; (2) claims that arose before these Terms or any prior agreement; (3) claims that arise after the expiration or termination of these Terms; and (4) claims that are currently the subject of purported class action litigation in which you are not a member of a certified class. As used in this Arbitration Provision, “Qodeo” means Qodeo, Inc. and any of its predecessors, successors, assigns, parents, subsidiaries and affiliated companies and each of their respective officers, directors, employees and agents, and “you” means you and any users or beneficiaries of your access to the Services.
3. Initiation of Arbitration Proceeding/Selection of Arbitrator. The party initiating the arbitration proceeding may open a case with JAMS, formerly Judicial Arbitration and Mediation Services, Inc., (“JAMS”) by visiting its website (www.jamsadr.com) or calling its toll-free number (1-800-352-5267). You may deliver any required or desired notice to Qodeo by mail to 1216 Broadway, Fl. 2 New York, NY 10023, U.S.A.
4. Right to Sue in Small Claims Court. Notwithstanding anything in this Arbitration Provision to the contrary, either you or Qodeo may bring an individual action in a small claims court in the area where you access the Services if the claim is not aggregated with the claim of any other person and if the amount in controversy is properly within the jurisdiction of the small claims court.
5. Arbitration Procedures. This Arbitration Provision shall be governed by the Federal Arbitration Act. Arbitrations shall be administered by JAMS pursuant to its Comprehensive Arbitration Rules and Procedures (the “JAMS Rules”) as modified by the version of this Arbitration Provision that is in effect when you notify Qodeo about your Dispute. You can obtain the JAMS Rules from the JAMS by visiting its website (www.jamsadr.com) or calling its toll-free number (1-800-352-5267). If there is a conflict between this Arbitration Provision and the rest of these Terms, this Arbitration Provision shall govern. If there is a conflict between this Arbitration Provision and the JAMS rules, this Arbitration Provision shall govern. If JAMS will not administer a proceeding under this Arbitration Provision as written, the parties shall agree on a substitute arbitration organization. If the parties cannot agree, the parties shall mutually petition a court of appropriate jurisdiction to appoint an arbitration organization that will administer a proceeding under this Arbitration Provision as written applying the JAMS Rules. A single arbitrator will resolve the Dispute. Unless you and Qodeo agree otherwise, any arbitration hearing will take place in New York, NY. The arbitrator will honor claims of privilege recognized by law and will take reasonable steps to protect customer account information and other confidential or proprietary information. The arbitrator shall issue a reasoned written decision that explains the arbitrator’s essential findings and conclusions. The arbitrator’s award may be entered in any court having jurisdiction over the parties only if necessary for purposes of enforcing the arbitrator’s award. An arbitrator’s award that has been fully satisfied shall not be entered in any court.
6. Waiver of Class Actions and Collective Relief. THERE SHALL BE NO RIGHT OR AUTHORITY FOR ANY CLAIMS TO BE ARBITRATED OR LITIGATED ON A CLASS ACTION, JOINT OR CONSOLIDATED BASIS OR ON BASES INVOLVING CLAIMS BROUGHT IN A PURPORTED REPRESENTATIVE CAPACITY ON BEHALF OF THE GENERAL PUBLIC (SUCH AS A PRIVATE ATTORNEY GENERAL), OTHER SUBSCRIBERS OR USERS, OR OTHER PERSONS. THE ARBITRATOR MAY AWARD RELIEF ONLY IN FAVOR OF THE INDIVIDUAL PARTY SEEKING RELIEF AND ONLY TO THE EXTENT NECESSARY TO PROVIDE RELIEF WARRANTED BY THAT INDIVIDUAL PARTY’S CLAIM. THE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE PERSON’S CLAIMS, AND MAY NOT OTHERWISE PRESIDE OVER ANY FORM OF A REPRESENTATIVE OR CLASS PROCEEDING.
7. Arbitration Fees and Costs. If your claim seeks more than $75,000 in the aggregate, the payment of the JAMS fees and costs will be governed by the JAMS Rules. If your claims seek less than $75,000 in the aggregate, the payment of the JAMS fees and costs will be Qodeo’s responsibility. However, if the arbitrator finds that your Dispute was frivolous or brought for an improper purpose (as measured by the standards set forth in Federal Rule of Civil Procedure 11(b)), the payment of the JAMS’s fees and costs shall be governed by the JAMS Rules and you shall reimburse Qodeo for all fees and costs that were your obligation to pay under the JAMS Rules. You may hire an attorney to represent you in arbitration. You are responsible for your attorneys’ fees and additional costs and may only recover your attorneys’ fees and costs in the arbitration to the extent that you could in court if the arbitration is decided in your favor. Notwithstanding anything in this Arbitration Provision to the contrary, Qodeo will pay all fees and costs that it is required by law to pay.
8. Severability and Waiver of Jury Trial. If any part of subsection (f) of this Arbitration Provision is found to be illegal or unenforceable, the entire Arbitration provision will be unenforceable and the Dispute will be decided by a court. WHETHER IN COURT OR IN ARBITRATION, YOU AND QODEO AGREE TO WAIVE THE RIGHT TO A TRIAL BY JURY TO THE FULLEST EXTENT ALLOWED BY LAW. If any other clause in this Arbitration Provision is found to be illegal or unenforceable, that clause will be severed from this Arbitration Provision and the remainder of this Arbitration Provision will be given full force and effect.
9. Continuation. This Arbitration Provision will survive the termination or expiration of these Terms.

Part II: Qodeo^TM – Democratizing Venture^TM Privacy Policy

Last updated: March 25, 2025 Thank you for using Qodeo.  We are committed to protecting your privacy and, for that reason, we have adopted this Privacy Policy to explain our data collection, use, and disclosure practices for the Qodeo Services (including the qodeo.com website, and mobile and web-based applications, and any other tools, products, or services provided by Qodeo that link to or reference this Privacy Policy). If you reside in a country in the European Economic Area or in Switzerland, please review our Privacy Notice for European Residents below to learn more about your privacy rights. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice for European Residents, the Privacy Notice for European Residents will prevail with respect to European Residents (as defined below) only. This Privacy Policy applies to information Qodeo collects through the Services, as well as other information provided to us online or offline by third parties, when we associate that information with customers or users of the Services; however, it does not apply to ifnformation collected from our employees, contractors, or vendors.  It also does not apply to information that you ask us to share with third parties or that is collected by certain other third parties whose software or services are featured or included in the Services (as further described below). This Privacy Policy describes, among other things:

• Personal and other information we collect about you;
• How we use your information;
• How we may share your information with third parties; and
• Your choices regarding the personal information we collect about you.

1. Consent

By accessing or using the Services, you consent to this Privacy Policy.  If you do not agree with this Privacy Policy, please do not access or use the Services.  Information gathered through the Services may be transferred, used, and stored in the United States or in other countries where our service providers or we are located.  If you use the Services, you agree to the transfer, use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Services or Qodeo are deemed to occur in the United States, where our servers are located.

2. Collection of Your Personal and Other Information

When you register for or use our Services, we collect Personal Information.  By “Personal Information” we mean information that can identify or reasonably be linked to an individual, such as:

• Names;
• Personal or business addresses;
• Email addresses;
• Phone numbers;
• Social media profile information;
• Information about your role(s) with your current and previous employer(s); and
• Information contained in any image, photograph or profile you submit to us.

You may choose not to provide Personal Information, (subject to the controls offered by your mobile device’s operating system), but this may prevent you from receiving certain features of the Services. We also collect non-Personal Information relating to the Services, that is, information that does not personally identify an individual.  The non-Personal Information we collect includes how you interact with the Services, information generally collected or “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the Services. Examples of the non-Personal Information we collect are:

• The pages of our website that you viewed during a visit or the features of the Qodeo mobile app you use;
• What information, content or advertisements you view or interact with using the Services;
• Language preferences;
• The city and state in which you are located (but not your precise geographic location); and
• Unique identifiers that are not connected and cannot reasonably be connected to your identity.

We will not use non-Personal Information to try to identify you, and if we associate any non-Personal Information with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather Personal Information and non-Personal Information. Information collected by the Services may be collected by us or one of the third parties we utilize in providing the Services (as further described below).

3. Use of Your Information

We may use the information we collect to:

• Assist us in providing, maintaining, and protecting the Services;
• To create matches via the Services;
• Set up, maintain, and protect accounts to use the Services;
• Improve our online operations;
• Provide customer service;
• Communicate with you, such as provide you with account- or transaction-related communications, or other newsletters, RSS feeds, and/or other communications relating to the Services;
• Send or display offers and other content that is customized to your interests or preferences;
• Perform research and analysis aimed at improving our products and services and developing new products or services; and
• Manage and maintain the systems that provide the Services.

As between you and Qodeo, you understand and agree that all information we gather by and through your use of the Services is owned by Qodeo, and that we may use the data we collect based on your use for any lawful business purpose without restriction.

4. Disclosure of Your Information

We may disclose your Personal Information to third parties as described below. We may disclose Personal Information to provide the Services, or when you authorize or instruct us to do so, for example, when you use the Services to submit content or profile information. We may also disclose Personal Information and non-Personal Information to Service Providers.  By “Service Providers” we mean companies, agents, contractors, service providers, or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, and conducting audits).   When we use a Service Provider, we require that the Service Provider use and disclose the Personal Information received from us only to provide their services to us or as required by applicable law. We may also disclose Personal Information and non-Personal Information to Online Tool Providers.  By “Online Tool Provider” we mean a licensor of software that we include in, or use with, the Services, including an API or SDK, that provides a specialized function or service to us and that requires the transmission of Personal Information and/or non-Personal Information to the Online Tool Provider.  Online Tool Providers may have the right to use Personal Information and non-Personal Information about you for their own business purposes.  Use and disclosure of Personal Information and non-Personal Information by an Online Tool Provider is described in its privacy policy.  See Section 5 of Part II below for some of the key Online Tool Providers we use. We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the Terms of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) submit insurance claims, cooperate with insurance investigations, and fulfil insurance subrogation activities, (e) prevent a crime or protect national security, or (f) detect, prevent or otherwise address fraud, security or technical issues. Finally, we reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the Services, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example, via email or by posting notice on our website. Lastly, we may also disclose non-Personal Information, aggregated with information about our other users, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

5. Cookies and Automatic Information Gathering Technologies

Every time you use the Services (e.g., access a Service webpage, or navigate to a specific location within the Service mobile app), we collect Personal Information and non-Personal Information (discussed above in Section 2 of Part II) regarding that use.  For example, to improve our Services, we collect how, when, and which parts of the Services or their features you use, which social media platforms you connect to the Services, and when, how, and what you post to the social media platforms through the Service app.  Also, we may use your device’s unique identifier (UDID) or other unique identifiers to assist us in collecting and analyzing this data. To assist us in collecting and storing this non-Personal Information, we may employ a variety of technologies, including “Cookies,” local browser storage, and “web beacons,” “pixels,” or “tags.”  A “Cookie” is a small amount of data a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website.  A web beacon, pixel or tag is a small, usually-transparent image placed on a web page that allows the operator of that image, which may be the operator of the website you visit or a third party, to read or write a Cookie. Your operating system and web browser may allow you to erase information stored in Cookies and local browser storage. But if you do so, you may be forced to login to the Services again, and you may lose some preferences or settings.  You may also be able to set your browser to refuse all website storage or to indicate when it is permitted, but some features of our Services may not function properly without it. We may use Cookies to keep you logged in, save your preferences for the Services, and to collect information about how you use our Services. More information about managing Cookies is available here. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser. An Online Tool Provider may collect information automatically, in which case Personal Information and non-Personal Information it receives are subject to the Online Tool Provider’s privacy policy.  Some Online Tool Providers may allow you to opt out of certain collection and/or uses of your information.  You can read more here: Google Analytics

6. Transparency and Choice; Do Not Track Signals

You may request access to your Personal Information by contacting us via our contact form. We will try to locate and provide you with your Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request.   But, in either case, we may need to retain it for legal reasons or for legitimate business purposes. You may also remove any content that you post to the Services using the deletion or removal options within the Services.  However, we (and you) are not able to control information that you have already shared with other users or made available to third parties through the Services. If you need further assistance with removing any content you posted through the Services, you can contact us at https://app.qodeo.com/contact. Removal of your posted content may not ensure complete or comprehensive removal from our computer systems. We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information.  In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.   We may also require you to verify your identity to our satisfaction before providing you with access to Personal Information. Please be aware that if you request us to delete your Personal Information, you may not be able to continue to use the Services.  Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements. We may use third-party service providers that collect information for interest-based advertising purposes (advertisements that are tailored to your likely interests, based on categories in which you have shown an interest).  To learn more about these third parties and the choices they offer users, please visit the Network Advertising Initiative’s choices page or the Digital Advertising Alliance’s choices page.  If you are reading this Privacy Policy from a mobile device, you can learn more about the DAA’s mobile choices program here. We support the development and implementation of a standard “do not track” browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized “do not track” feature is released, we intend to adhere to the browser settings accordingly. You can opt out of receiving marketing e-mails from us by clicking on the “unsubscribe” link in the e-mails.  Please note that it may take up to ten (10) business days for your opt-out request to be processed.  Also, even if you opt out of marketing e-mails, we may continue to send you certain account-related e-mails, such as notices about your account and confirmations of transactions you have requested.

7. Certain State Residents

You may have heard of the certain state laws in the  United States which provide certain rights to certain state residents in connection with their Personal Information.  Our Services are not currently subject to any such state laws providing rights in connection with Personal Information.  However, we do provide notice and transparency about our collection and use of Personal Information as described in Privacy Policy.

8. Residents of Canada

If you have an objection to the use of your Personal Information as described in this Privacy Policy, you may file a complaint via our contact form.  We will attempt to accommodate your objection or complaint, but you understand that, to the extent you object to our processing of Personal Information that is necessary for us to provide the Services to you, certain features and functionalities of the Services may no longer be available to you.  Nothing in this Privacy Policy prejudices your rights to file a complaint with the Office of the Privacy Commissioner of Canada, and/or with any other applicable data protection authorities.

9. Residents of Nevada

We do not sell your Personal Information.  However, you may contact us with questions via our contact form.

10. Children

The Services are not intended for users under 18 years of age.  We do not knowingly collect Personal Information from users under 18 years of age.  We do not authorize users under 18 years of age to use the Services.

11. Information Security

We utilize reasonable information security measures to safeguard your Personal Information against unauthorized access, modification, or destruction.  For example, we utilize Secure Socket Layer (SSL), Transport Layer Security (TLS), or similar encryption technology when sensitive data is transmitted over the Internet, and use firewalls to help prevent external access into our network.  However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure.  Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security. We restrict access to Personal Information in our possession to our employees, Service Providers, and Online Tool Providers who need to know that information in order to operate, develop, improve or support our Services.

12. Third Party Websites

Please note that the Services may link or integrate with third-party sites, services or apps.   We are not responsible for the privacy or security policies or practices or the content of such third parties.  Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how they collect, use, share and protect your information.

13. Changes to this Policy

We may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on this page. You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed.  If we make any material changes to this Privacy Policy, we will notify you by reasonable means, which may be by e-mail or posting a notice of the changes on our website or through the Services’ mobile app prior to the changes becoming effective.  We encourage you to check this Privacy Policy from time to time.  IF YOU DO NOT AGREE TO CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES (WHICH IS THE “LAST UPDATED” DATE OF THIS PRIVACY POLICY).

14. Questions

To ask questions about our Privacy Policy or to lodge a complaint, contact us via our contact form. PRIVACY NOTICE FOR EUROPEAN RESIDENTS If you reside in a country in the European Economic Area, the United Kingdom, or Switzerland (a “European Resident”), then information we collect from you may be subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “EU GDPR”), or the equivalent laws of the United Kingdom and Switzerland (collectively, “Data Protection Laws”), and the following additional information is provided for your benefit.  For purposes of this Privacy Notice for European Residents, in addition to the meaning set forth in Section 2 of the Privacy Policy above, “Personal Information” shall also include “personal data” as that term is defined by the GPDR, as well as “personal data” or similar terminology as defined by other applicable Data Protection Laws. The controller of the Personal Information collected through the Services is: Global Venture 100 Limited t/a Qodeo UK Companies House registration number 02991369 UHY Hacker Young, Quadrant House, 4 Thomas More Square London, E1W 1YW, United Kingdom We are a registered data controller with the Information Commissioner’s Office (ICO). Our registration number is: Z3293830. If you use the Services, you acknowledge that your Personal Information is being processed pursuant to the lawful bases described below, and you specifically consent to your Personal Information gathered through the Services being transferred, used, and stored in the United States or other third party countries which do not have local privacy laws that are equivalent to the Data Protection Laws.  You acknowledge and agree that the local laws in such countries may be materially different from, and provide for a lesser degree of protection regarding your Personal Information (including, but not limited to, with respect to governmental and law enforcement agencies’ ability to access your Personal Information under certain conditions) than, Data Protection Laws.

1. Personal Information

We may collect and process the following data about you:

• Information you give us. You may give us information about yourself by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site and our services, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site. This information could include your name, address, e-mail address, phone number, personal description, photograph and data or information related to you and your workplace, employer or organization, including career and educational background.
• Information we collect about you. Each time you visit our site, we may automatically collect the following information:

– technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; – information about your visit, including the full uniform resource locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; and phone numbers used to call our customer service number.

• Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide, if you have consented to this. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

2. Your Rights

You have the following rights under applicable Data Protection Laws:

• You have the right to know why we collect your Personal Information, how and why it is processed by us, and what our legal bases for such processing are.
• Right of access: You have the right to access your Personal Information.
• Right to rectification and deletion: you have the right to supplement or correct the Personal Information we’ve collected about you, or to direct us to delete your Personal Information.
• If you give us your consent to process your Personal Information, you have the right to revoke that consent.
• Right to data portability: you have the right to request that we transfer all your Personal Information to another controller in a reasonably understandable format.
• Right to object: you may object to our processing of your Personal Information.  We will make commercially reasonable efforts to comply with your objection, unless there are legally permissible reasons why we can or must continue to process your Personal Information.

3. Lawful Bases for Processing

Under European law, companies must have a legal basis to process data. You have particular rights available to you depending on which legal basis we use, and we’ve explained these above. You always have the right to request access to, rectification of, and erasure of your data under applicable Data Protection Laws.  To exercise your rights, please contact us at https://app.qodeo.com/contact. Pursuant to a contract with you: We may process data as necessary to perform our contracts with you.  We describe the contractual services for which this data processing is necessary throughout this Privacy Policy and in our Terms provided in Part I above.  The main uses of your data necessary to provide our contractual services are described in the Use of Your Information section of the Privacy Policy: We’ll use the Personal Information we have to provide the Services and as otherwise described in our Privacy Policy if you choose not to provide certain data, the quality of your experience using the Services may be negatively impacted. When we process data you provide to us as necessary to perform our contracts with you, you have the right to receive a portable copy of it (meaning to receive a copy of your data in a structured, commonly used and machine-readable format) under applicable Data Protection Laws. To exercise your rights, please contact us at https://app.qodeo.com/contact. The other legal bases we rely on in certain instances when processing your data are: Your Consent: We may process your Personal Information on the lawful basis of consent.

• Information you allow us to receive through the device-based settings when you enable them (such as access to your GPS location), so we can provide the features and services described when you enable the settings.
• Disclosures to certain third-parties, including third-party advertisers, as described below in the “Disclosure of Your Information” section.

When we process data you provide to us based on your consent, you have the right to withdraw your consent at any time and to receive a portable copy of the data you provide to us, under applicable Data Protection Laws. To exercise your rights, please contact us at https://app.qodeo.com/contact. Your Consent: We may process your Personal Information where our legitimate interests, or the legitimate interests of a third party, are not outweighed by your interests or fundamental rights and freedoms. The legitimate interests for our processing of Personal Information are to:

• Assist us in providing, maintaining, and protecting the Services;
• Set up, maintain, and protect accounts to use the Services;
• Improve our online operations;
• Provide customer service;
• Communicate with you, such as provide you with account- or transaction-related communications, or other newsletters, RSS feeds, and/or other communications relating to the Services;
• Send or display offers and other content that is customized to your interests or preferences;
• Perform research and analysis aimed at improving our products and services and developing new products or services;
• Manage and maintain the systems that provide the Services
• Prevent and address fraud, unauthorized use of the Services, violations of our Terms and policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or products), our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm; and
• Operate of our day-to-day business and planning, including executing strategic corporate transactions, such as mergers.

You have the right to object to, and seek restriction of, such processing; to exercise your rights, please contact us at https://app.qodeo.com/contact. We will consider several factors when assessing an objection to our processing in furtherance of Qodeo’s legitimate interests, including: our users’ reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. Compliance with a legal obligation:

• We need to process your Personal Information when applicable law requires it, including, for example, if there is a valid legal request for certain data.

4. Disclosures of Your Information

“Processors” means our Service Providers and their respective service providers. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may also disclose your Personal Information, (as well as non-Personal Information, without the same restrictions that apply to your Personal Information) to our Processors who we engage to perform certain functions for us, or on our behalf (including, but not limited to, processing of payments, provision of data storage, hosting of our website, marketing of our products and services, conducting audits, and performing web analytics). A list of our Processors and a description of the services that they perform for us follows.  We establish data processing agreements that govern our Processors’ use of your Personal Information, but our Processors’ use of your Personal Information may also be subject to the Processors’ own privacy policies.  See links to our Processors’ privacy policies below. Google Analytics Stripe Mailchimp New Relic Constant Contact Nimble Eventbrite Cloudflare

5. Retention of Your Information

We retain each category of your Personal Information for no longer than is reasonably necessary for one or more of the above lawful bases for processing, subject to your right to request we delete your Personal Information. Due to the nature of the services, it is not possible to predict the length of time that we intend to retain your Personal Information. Instead, we use the following criteria to determine whether it remains reasonably necessary to retain your Personal Information for one or more disclosed lawful bases for processing:

• the amount, nature, and sensitivity of the personal data
• the potential risk of harm from unauthorised use or disclosure of your personal data
• the purposes for which we process your personal data and whether we can achieve those purposes through other means
• the applicable legal requirements.

When we determine that it is no longer reasonably necessary to retain your Personal Information for one or more disclosed lawful bases for processing based on the above criteria, we will delete your Personal Information.

6. Questions and Complaints

If you have any questions or complaints regarding our use of your Personal Information, please contact us at https://app.qodeo.com/contact.  You also have the right to submit a complaint to your applicable Data Protection Authority.