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Terms of Service

Last updated: September 23, 2026 (Version 3.1)

HiLo Platform Inc. — d/b/a HiLo Finance

These Terms of Service reflect HiLo Finance's product architecture: in-house real-time chat (no third-party chat vendor), Public Chats for stock/market discussion open to creation by any user, stock and options symbol tagging, Mentor-provided trade ideas with optional SnapTrade brokerage verification, market/options data and news from Massive, Twelve Data, Alpha Vantage, and Benzinga, and mobile (iOS/Android) and desktop (Windows/macOS) applications. Sections 7 and 8 describe Podcasts and Audiorooms, which are included in these Terms in advance of launch and are NOT YET ENABLED on the Platform; HiLo will provide notice before either feature becomes active, and use of those features once enabled will be governed by the terms below (as updated at that time if needed).

1. Acceptance of Terms

By accessing or using the HiLo Finance mobile or desktop application ("App," "Platform," or "Service"), available on iOS, Android, Windows, and macOS, you ("User," "you," or "your") agree to be bound by these Terms of Service ("Terms"). If you do not agree, do not use the App. These Terms constitute a legally binding agreement between you and HiLo Platform Inc., a Delaware corporation doing business as HiLo Finance ("HiLo," "we," "us," or "our").

2. Description of Service

HiLo Finance is a social trading platform that connects retail investors and traders ("Subscribers") with experienced trading mentors ("Mentors") who provide educational content, market analysis, and trading insights, accessible via HiLo's mobile apps (iOS, Android) and desktop apps (Windows, macOS). The Platform facilitates:

  • In-house real-time chat and messaging, including Direct Messages, Mentor channels, and Public Chats
  • Public Chats: stock- and market-focused discussion groups that any eligible user may create or join, with content moderated by group admins and moderators who need not be HiLo staff or Mentors
  • Stock and options symbol tagging within chat messages
  • Stock, options, and cryptocurrency market data via Massive, Twelve Data, and Alpha Vantage, and financial news via Alpha Vantage and Benzinga
  • Subscription payments via Stripe (Web Payment) or via Apple In-App Purchase / Google Play Billing (In-App Payment) on mobile
  • Trade alerts, market analysis, and educational content from Mentors
  • Optional brokerage account connectivity and Mentor trade verification via SnapTrade (operated by Passiv Inc.)
  • Podcasts and Audiorooms (described in Sections 7 and 8) — included in these Terms in advance of launch; not yet enabled

HiLo is a technology platform. HiLo does not provide investment advice of any kind, personalized or otherwise, and is not registered as an investment adviser, broker-dealer, or commodity trading advisor. HiLo does not recommend, endorse, rank, or select Mentors or their content based on trading results, does not guarantee trading results, does not execute trades on your behalf, does not access your brokerage account, and does not hold, custody, or manage your funds or securities. HiLo's only compensation is a platform fee from Mentor subscriptions; HiLo receives no compensation from any broker, issuer, or token project.

3. Not Investment Advice

CONTENT PROVIDED BY MENTORS AND POSTED IN PUBLIC CHATS IS FOR EDUCATIONAL AND INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE PERSONALIZED INVESTMENT ADVICE, SECURITIES RECOMMENDATIONS, OR FINANCIAL PLANNING SERVICES.

  • HiLo is not registered as an investment adviser with the SEC or any state. Mentors are independent and are not registered as investment advisers unless a Mentor's profile expressly says so and identifies the registration.
  • Mentor content and Public Chat discussion, including tagged stock or options symbols, represent personal opinions and educational material only, not verified or endorsed recommendations.
  • You are solely responsible for evaluating and acting upon any information provided through the Platform, including in Public Chats.
  • No guarantee of investment performance is made or implied. Past performance is NOT indicative of future results.
  • Mentor content, including trade alerts, is impersonal. It is published to all of that Mentor's subscribers alike, is not tailored to your financial situation, objectives, or risk tolerance, and is not a solicitation to buy or sell any security. A trade alert describes what that Mentor did or intends to do, not what you should do.
  • A "verified" badge on a trade alert means only that the symbol, side, and date of the alert matched a trade execution record relayed from the Mentor's connected brokerage account within two days of the alert. "Pending" means the check has not yet run, "Unverified" means the Mentor has no connected account, and "Not matched" means no matching execution was found, which may reflect a sync gap, a trade in another account, or a trade that did not happen as posted. A "Trade plan" is a trade the Mentor has not executed. None of these verify the Mentor's profitability, track record, position size, or later exit, and it is not an endorsement or recommendation by HiLo.

Before making any investment decision, conduct your own independent research, consult a licensed financial advisor, tax professional, or attorney, and understand that all investments carry risk, including loss of principal.

4. Eligibility

To use the Platform you must be at least 18 years of age (or the age of majority in your jurisdiction), have the legal capacity to enter into binding contracts, and reside in a jurisdiction where the Service is legally available. You may not use the Platform if you are a resident of a country subject to U.S. embargo, listed on any U.S. government prohibited or restricted party list, or seeking to use the Platform for illegal or fraudulent purposes.

5. User Accounts

5.1 Registration. You must create an account to access Platform features and agree to provide accurate information, maintain the security of your credentials, and accept responsibility for activity under your account.

5.2 Phone verification. We use SMS-based authentication (Twilio Verify). By registering, you consent to receive SMS messages for authentication and confirm the phone number provided belongs to you. We will not send you marketing text messages without your separate express consent.

5.3 Termination. We may suspend or terminate your account for violation of these Terms, fraudulent or illegal activity, providing false information, prolonged inactivity, or at our sole discretion.

6. Public Chats and Community Groups

6.1 Open participation. Public Chats are stock- and market-focused discussion groups that any eligible user may create or join. Participation is subject to each group's rules as set by its admins/moderators, in addition to these Terms.

6.2 Admin and moderator authority. Each Public Chat is controlled by one or more admins or moderators, who may set group-specific posting rules, approve or remove members, and remove content or members that violate group rules or these Terms. Admins and moderators are ordinary users who created or were granted moderator status in that group — they need not be, and generally are not, HiLo employees or Mentors, and act independently of HiLo unless separately identified as HiLo staff.

6.3 HiLo platform-level authority. Independent of any group admin or moderator, HiLo may review, restrict, or remove any Public Chat, its content, or its members at HiLo's sole discretion, including for suspected market manipulation, coordinated inauthentic activity, securities-law violations, or other risk to the Platform or its users.

6.4 Symbol tagging. You may tag stock or options ticker symbols in chat messages. A tag is a user-generated annotation only; it is not verified by HiLo, does not constitute a recommendation, and carries the same educational-only status as other Platform content under Section 3.

6.5 No confidentiality in Public Chats. Content posted in a Public Chat is visible to that group's members and, depending on group settings, may remain visible to members who join later. Do not post anything in a Public Chat you do not want seen by other members.

7. Podcasts (Reserved — Not Yet Enabled)

This Section governs the Podcasts feature, included in these Terms for advance legal review. Podcasts are NOT currently enabled on the Platform; HiLo will provide notice before activation.

7.1 Podcaster content. Users approved as podcasters ("Podcasters") may publish audio episodes, show notes, and artwork, subject to a separate Podcaster Agreement covering content standards, sponsorship disclosure, revenue share, and takedown rights.

7.2 Sponsored content disclosure. Podcasters must clearly disclose any paid or sponsored segment within the episode audio itself, and must not promote unregistered securities offerings or guarantee investment returns, consistent with the Podcaster Agreement.

7.3 Platform ads and revenue share. HiLo may display advertisements on Podcasts listing pages (not during episode playback) and may share a portion of related ad revenue with Podcasters under the Podcaster Agreement.

7.4 Listener acknowledgment. Podcast content is provided by independent Podcasters, is educational/entertainment in nature, and does not constitute investment advice or an endorsement by HiLo, consistent with Section 3.

7.5 Moderation. HiLo may review, restrict, or remove any podcast episode or Podcaster account at its discretion, including for violations of the Podcaster Agreement or these Terms.

8. Audiorooms (Reserved — Not Yet Enabled)

This Section governs the Audiorooms feature (live audio discussions), included in these Terms for advance legal review. Audiorooms are NOT currently enabled on the Platform; HiLo will provide notice before activation.

8.1 Live audio. Audiorooms allow users to host and join live audio discussions. All prohibited-conduct rules in Section 9, and the educational-only status of content described in Section 3, apply equally to speech in Audiorooms.

8.2 Recording and moderation. HiLo may record Audiorooms sessions for content-moderation and compliance purposes and may remove speakers, participants, or end a session at HiLo's or the host's discretion for violations of these Terms. By hosting, speaking in, or joining an Audiorooms session you consent to HiLo recording the session.

8.3 No personalized advice live. Mentors and other speakers in Audiorooms may not provide personalized investment advice inconsistent with Section 3 or the Mentor disclosures, and may not use live audio to coordinate trading activity in violation of Section 9.

9. Mentor Services

9.1 Mentor qualifications. Mentors are independent contractors, not employees of HiLo. HiLo does not verify Mentor credentials or trading performance, other than the limited trade-alert verification described in Section 3, does not endorse any Mentor's strategies, does not guarantee the accuracy of Mentor content, and is not liable for Mentor content or conduct.

9.2 Mentor responsibilities. Mentors agree to comply with applicable securities laws, provide only educational content (not personalized advice, unless properly licensed), disclose material conflicts of interest (including positions in securities they discuss and any intent to trade shortly after posting), and may not repost trade alerts or verification status outside the Platform except as the Mentor Agreement permits, and refrain from market manipulation or fraudulent activity, whether in Mentor channels, Public Chats, or (once enabled) Audiorooms.

9.3 Subscriber responsibilities. By subscribing to a Mentor, you acknowledge that Mentor content is educational, you bear full responsibility for your own trading decisions, and subscription fees are non-refundable (Section 11), except as stated.

9.4 Performance claims. Any trading results, win rates, or profit figures a Mentor posts are self-reported unless marked verified, may be incomplete, and may not reflect losing trades, fees, taxes, slippage, or the Mentor's overall portfolio. Hypothetical, backtested, or model results did not involve real money. Past results are not a guarantee or reliable indicator of future results.

9.4A Connected-account displays and Transparency Score. If a Mentor opts in, HiLo displays that Mentor's connected brokerage holdings, portfolio value, and returns on the Mentor's own profile, showing all positions since the account was connected, as reported by the brokerage. HiLo does not use those figures to rank Mentors, to select who appears in any list, feed, or discovery surface, or in HiLo marketing. HiLo also displays a Transparency Score for each Mentor based on trade-alert verification rate, whether the Mentor holds what they post, posting consistency, and activity. It is not based on trading results and is not an endorsement, a measure of skill, or a prediction. New Mentors with limited data are shown as such.

9.5 Direct Messages with Mentors. Mentors may not give you personalized investment advice, including in Direct Messages or live audio, unless properly licensed and disclosed. Do not ask a Mentor what you should do with your money. Any response is the Mentor's personal opinion, not advice from HiLo.

10. Prohibited Conduct

You agree NOT to, whether in Direct Messages, Mentor channels, Public Chats, or (once enabled) Podcasts or Audiorooms:

  • Violate any applicable law or regulation, or infringe third-party rights
  • Engage in insider trading, market manipulation, coordinated pump-and-dump activity, or securities fraud, including through coordinated symbol tagging or group messaging
  • Hack, scrape, or attempt unauthorized access to the Platform or to other users' accounts
  • Post spam, phishing links, malware, or harassing, threatening, or defamatory content
  • Provide false or misleading information about investment performance, or solicit funds outside the Platform
  • Post a trade alert or recommendation while intending to trade against it (scalping) without disclosing that intent, or share material non-public information
  • Offer, promote, or solicit investment in any securities offering, token sale, or investment contract
  • Impersonate a HiLo employee, Mentor, or group admin/moderator

11. Fees and Payments

11.1 Subscription fees. Mentors set their own subscription pricing. On the HiLo website and where otherwise indicated in the App, subscription fees are processed via Stripe and charged to your payment method on file.

11.2 Payment method choice on mobile. When subscribing from HiLo's iOS or Android app, you will be presented with two payment options: (a) Web Payment — complete your subscription purchase on HiLo's website via Stripe at the standard listed price; or (b) In-App Payment — subscribe directly within the App using Apple's In-App Purchase system or Google Play's billing system, as applicable to your device.

11.3 In-App Payment surcharge. Subscriptions purchased via In-App Payment are priced higher than the standard Web Payment price by an amount equal to Apple's or Google's applicable platform service fee (currently 15% to 30% depending on the app store's program and the subscription's age), which HiLo passes through to cover that fee. The current price for each payment method is displayed before you confirm your purchase.

11.4 In-App Payment processing. If you choose In-App Payment, your purchase, billing, and payment method are handled entirely by Apple or Google under their respective terms (Apple Media Services Terms and Conditions; Google Play Terms of Service), not by HiLo or Stripe. HiLo does not receive or store your payment card details for In-App Payment purchases — only a transaction/receipt identifier and subscription status.

11.5 Billing. Subscriptions renew automatically until canceled, through whichever payment method (Stripe, Apple, or Google) you used to subscribe. By subscribing, you authorize the applicable payment processor to charge your payment method for the fee and applicable taxes. Before you subscribe we will show you the price, the renewal frequency, how to cancel, and any trial terms, and we will send you an acknowledgment of those terms after purchase. A Mentor may change a subscription price; an increase takes effect only at a renewal after at least 30 days' notice to you, and you may cancel before it takes effect.

11.6 Refunds. For Web Payment subscriptions, all fees are non-refundable except at HiLo's discretion for technical billing errors, unauthorized/fraudulent transactions, or extended Platform unavailability (more than 7 consecutive days). For In-App Payment subscriptions, refunds are subject to Apple's or Google's own refund policies and are requested through the applicable app store, not through HiLo.

11.7 Cancellation. You may cancel at any time; cancellation is effective at the end of the current billing period. Web Payment subscriptions can be canceled in the App or by emailing [email protected]. In-App Payment subscriptions must be canceled through your Apple ID or Google Play account settings, as HiLo cannot cancel an app-store subscription on your behalf.

12. Third-Party Services

12.1 Market data and news sources. HiLo's servers source market, options, and news data from the third-party data providers below via API. You do not have a direct account or contractual relationship with these providers, and no personal information about you is sent to them (see Privacy Policy Section 6.1). Data from these sources is provided "as is," may be delayed, and HiLo is not responsible for its accuracy or availability:

  • Massive (Massive.com, Inc.): options market data (quotes, chains, greeks). Reference: massive.com/legal/terms.
  • Twelve Data, Inc.: stock and cryptocurrency price data, quotes, and historical charts. Reference: twelvedata.com/terms.
  • Alpha Vantage: market data and financial news. Data may be delayed up to 15 minutes and is provided without warranty of accuracy or completeness.
  • Benzinga: financial news and market commentary.
  • Federal Reserve Bank of St. Louis (FRED® API), via Alpha Vantage: economic calendar and indicator data. This product uses the FRED® API but is not endorsed or certified by the Federal Reserve Bank of St. Louis. By using the Platform you agree to the FRED® API Terms of Use at fred.stlouisfed.org/docs/api/terms_of_use.html.

12.2 Other third-party services. The Platform also integrates the following third-party services, which do receive certain user data as described in the Privacy Policy. By using the Platform, you agree to be bound by these providers' own terms and privacy policies for the services they provide, and acknowledge HiLo is not responsible for their outages, data practices, or policy changes:

  • Stripe, Inc.: subscription billing and payment processing for Web Payment subscriptions (PCI-DSS Level 1 certified). Terms: stripe.com/legal/consumer.
  • Apple Inc.: In-App Purchase billing for subscriptions purchased on iOS. Terms: apple.com/legal/internet-services/itunes.
  • Google LLC: Google Play Billing for subscriptions purchased on Android. Terms: play.google.com/intl/en-us_us/about/play-terms.
  • Twilio Inc.: SMS-based phone verification. Terms: twilio.com/legal/tos.
  • SnapTrade (Passiv Inc.): optional brokerage connectivity and Mentor trade verification (Mentor-only feature). Terms: snaptrade.com/terms-and-conditions. HiLo does not receive or store brokerage login credentials.
  • Mixpanel, Inc. and Sentry (Functional Software, Inc.): product analytics and error monitoring.
  • MongoDB Atlas (MongoDB, Inc.): managed database hosting for Platform data.
  • Amazon Web Services, Inc.: cloud hosting and caching infrastructure.
  • Cloudflare, Inc. (R2 storage): storage of user-uploaded media (profile pictures, photos, and videos), and podcast audio/file hosting once Podcasts (Section 7) is enabled.
  • xAI, Inc. (Grok): AI features described in Section 13.4, including the HiLo AI Agent. Configured for zero data retention; xAI does not train on or retain Platform content. Terms: x.ai/legal.
  • ElevenLabs, Inc.: synthetic voice audio for the market briefing. Receives briefing text only.

13. Intellectual Property

13.1 Platform ownership. All content, features, and functionality of the Platform, other than content posted by users and Mentors, are owned by HiLo Platform Inc. or its licensors and protected by U.S. and international intellectual property laws.

13.2 Limited license. We grant you a limited, non-exclusive, non-transferable, revocable license to access and use the App, on the mobile and desktop platforms on which it is offered, for personal, non-commercial purposes.

13.3 User content. By posting content on the Platform, including in Public Chats and (once enabled) Podcasts and Audiorooms, you grant HiLo a worldwide, royalty-free, non-exclusive, sublicensable license to host, store, reproduce, adapt for display, and display that content on and through the Platform, and to use it to operate, provide, secure, and improve the Platform, for as long as the content remains on the Platform and afterward only as needed for backups, legal compliance, and Public Chat integrity as described in the Privacy Policy. We will not use the contents of your Direct Messages for marketing. You retain ownership but represent that you have the right to post it and that it does not violate these Terms or third-party rights.

13.4 AI and automated features. HiLo uses automated tools, including machine-learning models, to moderate content, detect fraud and manipulation, tag symbols, and generate displays from Platform content and market data. HiLo does not use your content to train artificial-intelligence models. Content processed by AI features (public chat messages, market data, and questions you ask the HiLo AI Agent) is sent to third-party AI providers listed in Section 12.2 under terms that prohibit them from training on it and from retaining it after processing. The contents of Direct Messages are not processed by AI features. HiLo does not sell or license your content to anyone for model training. Any AI-generated summary, insight, or statistic displayed on the Platform is produced automatically, may be inaccurate, and is not a recommendation. The HiLo AI Agent answers questions about market data, terminology, and reported company information. It is designed not to tell you whether to buy, sell, or hold anything and not to comment on your positions; any output that appears to do so is an error, is not advice from HiLo, and must not be relied on.

13.5 Copyright complaints (DMCA). HiLo respects intellectual property rights and responds to notices of alleged infringement under the Digital Millennium Copyright Act, 17 U.S.C. §512. Our designated agent to receive notifications of claimed infringement is:

Copyright Agent, HiLo Platform Inc.
131 Continental Dr, Suite 305, Newark, DE 19713, United States
Phone: (341) 244-5644
Email: [email protected]

A notice must include: (1) your physical or electronic signature; (2) identification of the copyrighted work claimed to be infringed; (3) identification of the allegedly infringing material and information reasonably sufficient for us to locate it; (4) your name, address, telephone number, and email address; (5) a statement that you have a good-faith belief that the use is not authorized by the copyright owner, its agent, or the law; and (6) a statement that the information in the notice is accurate and, under penalty of perjury, that you are the copyright owner or authorized to act on the owner's behalf. We will remove or disable access to material identified in a valid notice. If your content is removed, you may submit a counter-notification to the agent above as provided in 17 U.S.C. §512(g). We terminate, in appropriate circumstances, the accounts of repeat infringers.

14. Disclaimers and Limitation of Liability

THE PLATFORM, INCLUDING ALL PUBLIC CHAT CONTENT, MENTOR CONTENT, AND THIRD-PARTY MARKET DATA, IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND. TRADING AND INVESTING INVOLVE SUBSTANTIAL RISK OF LOSS, AND YOU ACKNOWLEDGE THAT INVESTMENT DECISIONS ARE MADE AT YOUR SOLE DISCRETION AND RISK.

TO THE FULLEST EXTENT PERMITTED BY LAW, HILO FINANCE SHALL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES, INCLUDING TRADING LOSSES OR LOSSES RESULTING FROM RELIANCE ON MENTOR CONTENT, PUBLIC CHAT CONTENT, OR THIRD-PARTY MARKET DATA. MAXIMUM LIABILITY TO YOU SHALL NOT EXCEED THE GREATER OF $100 USD OR THE AMOUNT YOU PAID TO HILO IN THE 12 MONTHS PRECEDING THE CLAIM.

We are not responsible for the actions of other users, Mentors, or Public Chat admins/moderators, nor for outages or inaccuracies in data from Massive, Twelve Data, Alpha Vantage, Benzinga, SnapTrade, or connected brokerages.

Nothing in these Terms limits liability that cannot be limited under applicable law, including liability for fraud, willful misconduct, or gross negligence, or waives consumer rights under the laws of your state that cannot be waived. Some jurisdictions do not allow the exclusion of certain warranties or damages, so some of the above may not apply to you. Any claim arising out of these Terms or the Platform must be brought within one year after it arises, or it is permanently barred.

15. Indemnification

You agree to indemnify, defend, and hold harmless HiLo Finance from claims, liabilities, damages, or expenses (including reasonable attorneys' fees) arising from your use of the Platform, your violation of these Terms or applicable law, content you post (including in Public Chats and, once enabled, Podcasts or Audiorooms), or trading decisions you make based on Platform content.

16. Dispute Resolution

16.1 Governing law. These Terms are governed by California law, without regard to its conflict-of-laws rules. The Federal Arbitration Act governs this Section 16.

16.2 Informal resolution first. Before starting arbitration or a lawsuit, the party with a claim must send the other a written notice describing the claim and the relief sought (to [email protected], or to the email on your account), and the parties must try in good faith to resolve it for 60 days. Limitations periods are paused during that time. This step is required, and an arbitration or lawsuit filed without it may be dismissed.

16.3 Binding arbitration. Except as provided in Section 16.4, any dispute between you and HiLo relating to these Terms or the Platform will be resolved by binding individual arbitration administered by JAMS under its rules in effect when the claim is filed, including the JAMS Consumer Arbitration Minimum Standards where they apply. The arbitrator, not a court, decides all questions about the scope and enforceability of this Section 16, except that a court decides whether the class action waiver in Section 16.5 is enforceable. The arbitration will take place in the county where you live, by video conference, or in San Francisco, California, at your choice. HiLo will pay all JAMS fees beyond the consumer filing fee set by the JAMS Consumer Arbitration Minimum Standards, and each party pays its own attorneys' fees unless the arbitrator finds a claim or defense frivolous or awards fees under applicable law. Judgment on the award may be entered in any court with jurisdiction.

16.4 Exceptions. Either party may bring an individual claim in small claims court. Either party may seek a court order to protect its intellectual property. If California law gives you a right to seek public injunctive relief that cannot be waived, that request may be decided by a court, but only after the arbitrator has resolved all of your individual claims, and the court proceeding will be stayed until then.

16.5 Class action and jury waiver. You and HiLo each agree to bring claims only in an individual capacity, and not as a plaintiff or class member in any class, consolidated, or representative proceeding. The arbitrator may not consolidate claims or award relief to anyone other than the individual claimant. You and HiLo each waive the right to a jury trial. If a court finds this Section 16.5 unenforceable as to a particular claim, that claim will be decided in court and severed from arbitration, and the rest of Section 16 remains in effect.

16.6 Coordinated filings. If 25 or more arbitration demands raising similar claims are filed against HiLo with the help of the same or coordinated counsel, the demands will be resolved in batches of 25, with one arbitrator assigned per batch and JAMS fees due only for the batch then proceeding. Limitations periods are paused for demands awaiting a batch. The parties agree to work with JAMS to implement this process and, if JAMS cannot, to select another provider that can.

16.7 Opt-out. You may opt out of Sections 16.3 through 16.6 by emailing [email protected] within 30 days after you first accept these Terms, with your username and a statement that you opt out of arbitration. Opting out does not affect any other part of these Terms.

16.8 Changes to this Section. If HiLo changes this Section 16 after you accept these Terms, the change does not apply to any claim for which notice was already given under Section 16.2, and you may reject the change by emailing [email protected] within 30 days after notice, in which case the prior version continues to apply to you. If you reject a change, HiLo may terminate your account.

16.9 Severability. Except as stated in Section 16.5, if any part of this Section 16 is found unenforceable, the rest remains in effect.

17. Privacy

Your use of the Platform is subject to our Privacy Policy, incorporated by reference, which describes our data practices including those related to Public Chats, Mentor SnapTrade connectivity, Podcasts and Audiorooms (once enabled), and third-party data providers.

18. Modifications to Terms

We may modify these Terms at any time. Minor changes are effective immediately; material changes are effective 30 days after notice via email or in-app notification. Continued use after changes take effect constitutes acceptance. Changes to Section 16 are subject to Section 16.8. We may require you to accept updated Terms before continuing to use the Platform.

19. Termination

19.1 By you. You may close your account at any time in the App's account settings or by emailing [email protected]. Deleting the App from your device does not close your account or cancel a subscription; cancel subscriptions as described in Section 11.7. Your data will be deleted within 30 days, except as required by law or as described in the Privacy Policy for Public Chat content.

19.2 By us. We may terminate or suspend your account immediately, without notice, for violation of these Terms, illegal activity, security risk, or legal/regulatory requirements.

20. General Provisions

20.1 Entire agreement. These Terms, the Privacy Policy, and any Mentor-specific or Podcaster-specific agreements constitute the entire agreement between you and HiLo.

20.2 Severability. If a provision is unenforceable, the remaining provisions remain in effect.

20.3 Assignment. You may not assign these Terms without our written consent; we may assign our rights without restriction.

20.4 Force majeure. We are not liable for delays or failures caused by circumstances beyond our reasonable control, including third-party service outages.

20.5 Notice to California users. Under California Civil Code Section 1789.3, California users are entitled to the following notice: the Platform is provided by HiLo Platform Inc., San Jose, California. Complaints or requests for information about pricing may be sent to [email protected]. The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (800) 952-5210.

21. Contact Information

HiLo Platform Inc. (d/b/a HiLo Finance) — San Jose, CA 95118 — United States

Support: [email protected] | Legal: [email protected] | Privacy: [email protected]