AURANSER MASTER USER AGREEMENT

Version 2.5 | Effective August 1, 2026

IMPORTANT NOTICES

About Auranser

Auranser Inc. is a Delaware Public Benefit Corporation and SEC-registered investment adviser (CRD# 340833 / SEC# 801-136163). Auranser is not a bank and does not hold deposits or extend credit. Auranser provides the technology platform, financial education, engagement tracking, budget tools, community features, market intelligence, and investment advisory services. Securities custody is provided by Alpaca Securities LLC (FINRA/SIPC member). Advisory Services are available to eligible Auranser Plus subscribers who execute an Investment Advisory Agreement. You are not required to use Advisory Services to access Platform Services. Auranser's fiduciary duty under the Investment Advisers Act arises by operation of law when an advisory relationship is formed.

Future Services

We may offer additional services in the future, including deposit accounts, credit products, and services for users under 18. If we do, we will provide you with applicable agreements, disclosures, and privacy notices before those services become available.

TABLE OF CONTENTS

1. Agreement to Terms
2. Eligibility and Account Types
3. Account Opening and Verification
4. Your Auranser Account
5. Security and Access
6. Fees and Pricing
7. Communications and Notices
8. Privacy and Data Usage
9. Intellectual Property
10. Prohibited Uses
11. Account Suspension and Termination
12. Limitation of Liability
13. Dispute Resolution and Arbitration
14. General Provisions
15. Contact Information

Acknowledgment and Acceptance

Appendix A: Definitions

1. AGREEMENT TO TERMS

1.1 Acceptance of Terms

This Master User Agreement (“Agreement”) is a legal contract between you and Auranser Inc. (“Auranser,” “we,” “us,” or “our”). By creating an Auranser account, downloading our mobile application, or using any of our services, you agree to be bound by:

• This Master User Agreement
• Our Privacy Policy
• All applicable Product Supplements, including:
  • Investment Advisory Agreement (if or when you use Advisory Services)
  • Educational Services Terms (if or when separate terms for learning content are offered)
• All applicable Feature Supplements for specific services (behavioral engagement score, etc.)

These documents collectively form the “Agreements” governing your relationship with Auranser.

Before using Advisory Services, you will receive and acknowledge the following SEC disclosures: Form CRS (Client Relationship Summary) and the Wrap Fee Program Brochure (Form ADV Part 2A, Appendix 1). These are informational disclosures, not binding agreements. The Form CRS is an SEC-required plain-language summary of our advisory services, fees, conflicts of interest, and your relationship with us, available at auranser.com/crs or by emailing compliance@auranser.com. The Wrap Fee Program Brochure provides detailed information about our advisory business, fees, conflicts, disciplinary history, and investment strategies, delivered to advisory clients in lieu of a standard Form ADV Part 2A brochure, available at www.adviserinfo.sec.gov (CRD# 340833) or by requesting a copy from compliance@auranser.com. You are not required to use Advisory Services to access Platform Services or educational features.

1.2 Agreement Hierarchy

If there is a conflict between documents:

1. Product-specific Supplements control over this Master User Agreement for that specific product
2. Feature-specific terms control over product terms for that specific feature
3. This Master User Agreement controls for general platform access and services not covered by specific supplements
4. Federal and state law controls over all agreements

1.3 Electronic Signatures and Records (E-SIGN Act Consent)

By agreeing to these terms electronically, you consent to conduct transactions and receive disclosures, notices, and other communications electronically in accordance with the federal Electronic Signatures in Global and National Commerce Act (E-SIGN Act).

Before you consent:

• Hardware/Software Requirements: You need a device with internet access, a current web browser with JavaScript and cookies enabled (Chrome, Firefox, Safari, or Edge recommended), and the ability to view PDF files. For mobile access, iOS 14+ or Android 10+ is required.

• Confirming Your Access: By consenting, you confirm that you can access, open, and retain the agreements, disclosures, and notices provided to you in electronic form (including PDF documents) on your device.

• Right to Paper Copies: You may request paper copies of agreements and disclosures by contacting support@auranser.com; up to four routine paper requests per year are provided at no charge, and paper copies of regulatory disclosures are always free.

• Withdrawal of Consent: You may withdraw your consent to receive electronic communications at any time by contacting us. Withdrawal of consent will not affect the legal validity of communications sent before withdrawal. Some services may require electronic communications and withdrawal may limit your ability to use those services.

• Updating Contact Information: You are responsible for keeping your email address and mobile phone number current. Changes can be made in Settings > Profile > Contact Information.

By clicking “I Agree” or using our services, you confirm:

• You have read and understand these hardware and software requirements

• You can access and retain electronic records

• You consent to receiving all communications electronically

• You will maintain current contact information

1.4 Changes to Terms

We may modify this Agreement or any Product Supplement at any time. We will provide notice of material changes:

• At least 30 days in advance for changes that reduce your rights or increase your obligations

• Through email to your registered email address

• Through in-app notification

• By posting the updated agreement with a new “Last Updated” date

Shortened Notice (Limited Exceptions Only): We will provide less than 30 days’ notice only in the following circumstances:

(i) Legally Required Changes: When a federal or state law, regulation, or court order requires a specific change and mandates an effective date that leaves fewer than 30 days for notice. We will provide notice as soon as commercially practicable and will identify the specific legal requirement in the notice.

(ii) Security or Fraud Mitigation: When immediate changes are necessary to protect user accounts from active security threats or fraud. We will provide notice of security-driven changes as promptly as commercially practicable after implementing the change, explaining the nature of the threat and the protective measure taken.

(iii) Favorable Changes Only: When changes exclusively benefit users without increasing obligations or reducing rights (e.g., additional feature access). Effective immediately upon posting.

Prohibition on Shortened Notice for Adverse Changes: We will NOT provide less than 30 days’ notice for changes that increase fees, reduce features, expand our rights, limit your remedies, or otherwise reduce your rights or increase your obligations, unless the change falls under exception (i) or (ii) above.

Your continued use of Auranser services after the effective date of changes constitutes acceptance. If you do not agree to changes, you must close your account before the effective date (or within 30 days of receiving notice if shorter notice was provided under exceptions (i) or (ii), with no early termination fee).

2. ELIGIBILITY AND ACCOUNT TYPES

2.1 General Eligibility Requirements

To use Auranser services, you must:

• Be at least 18 years of age

• Be a natural person (not a business entity)

• Be a U.S. resident with a valid U.S. address

• Provide a valid Social Security Number or Individual Taxpayer Identification Number when you enroll in Advisory Services or other financial services that require identity verification

• Have a valid email address and U.S. mobile phone number

• Not be subject to U.S. economic sanctions or foreign asset control regulations

• Not be listed on the OFAC Specially Designated Nationals list or other prohibited parties lists

You may not use Auranser services if:

• You have previously had an Auranser account terminated for cause

• You are prohibited by court order from opening financial accounts

• You have engaged in fraudulent activity with Auranser or our partners

If you are in active bankruptcy proceedings, certain services (such as advisory enrollment) may be restricted.

2.2 Account Ownership and Joint Accounts

• Individual Ownership: All Auranser accounts are individual accounts. We do not offer traditional joint accounts.

• Trusted Contact: You may designate a trusted contact (age 18+) whom Auranser or the Custodian may contact about your account, as permitted under FINRA Rule 4512. A trusted contact cannot access your account or execute transactions.

• No Business Accounts: Auranser accounts are for personal use only. We do not currently offer business or commercial accounts.

2.3 State-Specific Restrictions

Certain Auranser services may not be available in all states due to licensing or regulatory restrictions. We will notify you during account setup if your state has specific limitations. Current state-specific restrictions are listed at auranser.com/state-availability.

3. ACCOUNT OPENING AND VERIFICATION

3.1 Account Opening and Verification

To create an account, provide your name, email, phone number, and date of birth, and create a password. When you enroll in Advisory Services or other financial services, we verify your identity (in coordination with our custodian, which performs required customer-identification screening for brokerage accounts) using your Social Security Number or ITIN, government-issued photo ID, and address and phone verification, consistent with Bank Secrecy Act customer-identification principles. You may also link an external bank account for account funding.

See our Consumer Privacy Policy §5 and §7A for the complete categories of personal information we collect, the sources, and the purposes for which we use it. Employment, income, and financial-profile information are collected when you open an Investment Advisory or brokerage account for suitability and Know-Your-Customer purposes. Where you enable biometric authentication, the biometric data itself is processed on your device by your operating system and is not collected by or transmitted to Auranser.

We may require additional verification at any time, including when automated verification is unsuccessful, we detect unusual activity, or as required by law. If we cannot verify your identity, we will explain the reasons for denial where lawful and practicable, you have the right to request manual review, and any deposited funds will be returned to the source account.

Maryland Data Minimization (Maryland Online Data Privacy Act): For users with Maryland addresses, we collect personal data only to the extent reasonably necessary to provide requested services or comply with law, as required by the Maryland Online Data Privacy Act. Questions about Maryland minimization rights: privacy@auranser.com.

3.2 Sanctions and Prohibited Parties Screening

We are required by law to screen all applicants against:

• Office of Foreign Assets Control (OFAC) lists

• Specially Designated Nationals (SDN) list

• Other U.S. government prohibited parties lists

If you are identified on any prohibited parties list, we cannot open an account for you or provide services. We will notify you of the denial and provide information on how to challenge incorrect matches with the relevant government agency.

3.3 Identity Verification

For Platform account opening, Auranser verifies your identity using the information you provide during registration (see §3.1). No credit inquiry is required for Platform Services.

3.4 Enrichment Score: Classification and Prohibited Uses

Classification. The Enrichment Score is a gamified engagement metric visible to you in the app. Auranser personnel and systems access the score for the permitted uses described below. The score is not shared with other users, employers, lenders, or any third party (other than service providers acting on our behalf under contractual data-protection obligations). It is not a “consumer report” under the Fair Credit Reporting Act. Because the score is used solely for personalization and feature access and produces no legal or similarly significant effect, it generally does not trigger consumer profiling opt-out rights under applicable state privacy or AI laws. See our Privacy Policy §9A for the complete state privacy rights that apply to Auranser's data processing activities.

Credit Decision Prohibition. The score is not a credit score, is not reported to credit bureaus, and is not used to approve or deny credit applications, set interest rates, or determine credit limits. If Auranser introduces credit products in the future, the Enrichment Score will not be used as a factor in any credit decision, including underwriting, adverse action, account review, or collections. Auranser does not use prohibited attributes under ECOA and Regulation B as inputs to the score.

Permitted Uses. The score may be used for engagement tracking, gamification perks and non-financial feature ordering, personalization of educational recommendations, customer support prioritization (not denial of support), and platform analytics.

Enforcement. This prohibition on credit use is a binding commitment. You may also file a complaint with the Consumer Financial Protection Bureau (see §14.14).

4. YOUR AURANSER ACCOUNT

4.1 Account Credentials

You will create a unique username and password during registration. You are responsible for maintaining the confidentiality of your login credentials. Auranser will never ask for your password via email, phone, or text. We recommend enabling multi-factor authentication (MFA), which may be required for sensitive account actions.

4.2 Account Security

You agree to use strong, unique passwords, keep your contact information and devices secure, review account activity regularly, and report unauthorized transactions promptly. We use industry-standard encryption and monitoring, and will notify you of suspicious activity. If you believe your account has been compromised, change your password immediately and contact us at support@auranser.com or 888-311-9964.

4.3 Authorized Users and Delegates

For Independent Adult Accounts:

• You may designate a trusted contact (age 18+) as described in Section 2.2

• You may update or remove your trusted contact designation at any time

Prohibited Delegation:

• You may not authorize anyone to act on your behalf to execute transactions, except as expressly provided in the Investment Advisory Agreement (including Advisor's investment authority under IAA § 2.1, standing letters of authorization under IAA § 4.1(d), and the authority of a legal representative under IAA § 11.5)

• Each user must have their own account and credentials

• Sharing credentials is a violation of this Agreement and may result in account termination

4.4 Account Statements

Your account information and activity are available through your account dashboard, and your securities custodian provides account statements for your investment account. You may request paper copies of agreements and disclosures by contacting support@auranser.com; up to four routine paper requests per year are provided at no charge, and paper copies of regulatory disclosures are always free. You must review statements promptly and report errors or unauthorized transactions within 60 days of statement date. We may limit our liability for errors not reported within this timeframe, except to the extent Regulation E, the Securities Investor Protection Act, or other applicable law provides greater protection or a different error-resolution timeframe, which controls where applicable.

4.5 Keeping Your Information Current

You must notify us within 10 business days of any change to your address, email, phone number, legal name, employment status, or tax residency. You are responsible for any issues arising from outdated contact information.

4.6 Account Dormancy and Inactivity

An account is dormant if there are no customer-initiated logins or transactions for 12 consecutive months and we are unable to contact you. Before declaring dormancy, we will use reasonable efforts to contact you as required by applicable unclaimed-property law. Dormant accounts are restricted to view-only access. The Platform Access Fee continues during dormancy until you cancel your subscription; for Advisory accounts, the advisory fee also continues as described below. To reactivate, contact support@auranser.com, verify your identity, and accept any Agreement updates. An account in deployed status under Section 14.16 is not treated as dormant during the documented deployment period.

Advisory Accounts: Dormancy does not suspend advisory services or advisory-fee accrual. Under non-discretionary management, rebalancing proposals cannot execute without your approval and will not occur during dormancy; if discretionary management is offered and you have elected it, automated rebalancing continues. Dormancy alone does not trigger the cancellation cascade in IAA §5.1A(b). Refunds of any prepaid annual Platform Access Fee are addressed in Section 6.5.

Escheatment: After the period required by your state’s unclaimed-property law (typically 3-5 years), unclaimed property may be remitted to your state. Auranser does not currently hold customer funds; securities in your investment account are held by the Custodian (Alpaca Securities LLC), and escheatment of those securities is handled by the Custodian under applicable law. You can reclaim escheated property by contacting your state’s unclaimed property office.

5. SECURITY AND ACCESS

5.1 Security Program

We maintain administrative, technical, and physical safeguards designed to protect your personal and financial information, consistent with industry standards and applicable law (including the GLBA Safeguards Rule and SEC Regulation S-P). No method of electronic transmission or storage is completely secure; we cannot guarantee absolute security. See our Privacy Policy §14 for details.

5.2 Device Requirements

Supported devices and system requirements are described in Section 1.3 (Hardware/Software Requirements). Devices must not be jailbroken or rooted. We may restrict access from devices showing signs of compromise.

5.3 Unauthorized Access and Error Resolution

Report Unauthorized Activity Immediately:

If you believe your Platform account has been accessed without authorization, or if you notice any suspicious activity:

1. Contact us:

• Phone: 888-311-9964

• Email: support@auranser.com

• In-app: through the app

2. Provide details: Date, nature of the unauthorized access, and any actions taken on your account
3. Follow up in writing: If initially reported by phone

Our Investigation Process:

We will investigate reports of unauthorized access and notify you of findings promptly.

5.4 Your Liability for Unauthorized Transactions

Securities-account carve-out. For your investment advisory/brokerage account, unauthorized activity is governed by your separate customer agreement with the Custodian (Alpaca Securities LLC) and by applicable securities law, including the Securities Investor Protection Act (SIPA) and applicable FINRA rules, which control over this Section to the extent they provide greater protection or a different allocation of liability. Nothing in this Section shifts to you any loss from unauthorized securities transactions except as permitted by that customer agreement and applicable securities law.

Otherwise, you are responsible for unauthorized transactions if:

• You shared your credentials or device access with others

• You failed to maintain reasonable security on your device

• You failed to report unauthorized transactions within required timeframes

• You failed to report lost or stolen credentials or devices promptly

• The transaction resulted from your gross negligence or intentional misconduct

We are not liable for losses resulting from:

• Unauthorized use that occurs before you report the loss, to the extent the loss results from one of the circumstances listed above

• Your failure to follow security procedures outlined in this Agreement

• Circumstances genuinely beyond our control (excluding any failure of systems we were required to maintain consistent with industry standards, as provided in §12.2)

• Your violation of this Agreement

Except to the extent Regulation E, Regulation Z / TILA, the Securities Investor Protection Act, or other applicable law provides greater protection, which controls where applicable.

5.5 System Availability and Technical Requirements

Service Availability:

• We strive to keep the Platform available but cannot guarantee uninterrupted service

• Planned maintenance will be scheduled during off-peak hours when possible

• Emergency maintenance may occur without advance notice

Service Interruptions: We are not liable for losses resulting from scheduled or emergency maintenance, force majeure events (see §14.6), third-party service provider failures, telecommunications failures, or your device or software issues.

Technical Support: Contact support@auranser.com or 888-311-9964.

6. FEES AND PRICING

6.1 Subscription Tiers and Platform Access Fee

Auranser offers a Free tier and Auranser Plus ($9.99/month or $99.99/year). Auranser Plus is required for connected accounts, automation, live trading, and Advisory Services eligibility. Advisory Services carry a separate Investment Advisory Fee (see Section 6.3). The Platform Access Fee is billed through our payment processor to the payment method on file and is never deducted from your brokerage or investment account.

6.2 Enrichment Score Governance

The Enrichment Score is governed by Section 3.4. Methodology may change without advance notice since the score is used for engagement purposes only. You may view factors in your profile and dispute calculation errors based on incorrect underlying data by contacting privacy@auranser.com. We will investigate and respond promptly. Methodology disputes (disagreement with factor weights) are not subject to the dispute process. You may escalate unresolved disputes to compliance@auranser.com with subject line “Enrichment Score Escalation” for further review. Auranser's determination on further review is final for internal dispute resolution; your remedies beyond that are in Section 13. Nothing limits your right to file a regulatory complaint (§14.14). The score does not use prohibited attributes (race, color, religion, national origin, sex, marital status, age, or receipt of public assistance) as inputs.

6.3 Investment Account Fees

If you open an advisory account, you pay an advisory (wrap) fee in addition to the Platform Access Fee. Because the Platform Access Fee is a fixed dollar amount, total program cost as a percentage of assets is higher for smaller balances. See the Fee Schedule for the combined-cost illustration. You are not required to use Advisory Services to access Platform Services. Complete fee disclosures are in the Investment Advisory Agreement (Article 5), the Wrap Fee Program Brochure (www.adviserinfo.sec.gov, CRD# 340833), and Form CRS.

6.4 Fee Disclosure and Changes

Fee Schedule:

• Complete fee schedule available at auranser.com/fees

• Current fee schedule available at auranser.com/fees and in your account

• Changes to fee schedule require 30 days advance notice

Notice of Fee Changes:

• Email and at least one additional channel (such as in-app notification)

• Posted updated fee schedule 30 days before effective date

• Your continued use of services after the effective date constitutes acceptance, except that, if you have an active Advisory Account, an increase to the Investment Advisory Fee requires affirmative consent (Investment Advisory Agreement §5.3) and an increase to the Platform Access Fee takes effect no earlier than 30 days after notice, and you may terminate your subscription without penalty before the effective date; if you continue your subscription after the effective date, the increased Platform Access Fee applies

How to Avoid Fee Changes:

• You may close your account without fee before fee changes take effect

• See Section 11 for account closure procedures

Non-Response (Advisory Fee Increases): If you have an active Advisory Account and do not affirmatively accept or decline an increase to the Investment Advisory Fee within sixty (60) days of notice, the existing fee remains in effect, and Auranser may terminate advisory services upon thirty (30) days' additional written notice under IAA §11.2(b). See the Investment Advisory Agreement for parallel provisions.

6.5 Fee Reversals and Refunds

Fee Disputes:

• You may dispute any fee charged to your account

• Contact support@auranser.com within 60 days of the fee

• Provide explanation of why you believe the fee was incorrect

• We will investigate and respond promptly

Refunds:

We will promptly refund fees after investigation confirms the error, including if:

• The fee resulted from our error

• The fee resulted from system malfunction

• The fee was charged to the wrong account

We will not refund fees for:

• Services you voluntarily requested (e.g., expedited processing)

• Fees incurred due to your violation of this Agreement

• Third-party fees passed through from service providers

• Fees more than 60 days old (unless due to our error)

Prepaid Annual Platform Access Fee. If Auranser terminates your account (including after dormancy), any prepaid annual Platform Access Fee is refunded pro rata. If you cancel voluntarily, your subscription remains active through the end of the paid period, without a pro-rata refund.

Nothing in this Section 6.5 limits any refund expressly provided elsewhere in the Agreements (including Sections 11.1 and 14.16, and Investment Advisory Agreement §5.1A).

7. COMMUNICATIONS AND NOTICES

7.1 How We Communicate With You

Electronic Communications (Primary Method):

• Email to your registered email address

• Push notifications through the mobile app

• In-app messages and alerts

• SMS/text messages to your registered mobile phone

SMS Terms: By providing your mobile phone number, you consent to receive transactional and security-related text messages from Auranser (or our service providers on our behalf). Message frequency varies. Message and data rates may apply. You may opt out of non-security SMS at any time by replying STOP; reply HELP for assistance. Opting out of security SMS may require contacting support@auranser.com. We do not send marketing text messages unless you separately opt in. See your mobile carrier for applicable messaging terms.

Postal Mail (Backup Method):

• Sent to your address of record

• Used for legally required notices when electronic delivery fails

• Used when you request paper copies

Our Website:

• Important notices posted at auranser.com/notices

• Legal documents and policies posted at auranser.com/legal

7.2 Legally Required Communications

Certain communications will be sent electronically unless you request paper delivery:

• Account statements

• Privacy notices

• Terms and conditions updates

• Tax forms (also available for download)

We may also send postal mail (or use a print-mail service on our behalf) for:

• Notices of account closure, where email delivery cannot be confirmed

• Communications where email delivery has repeatedly failed

• When required by law

7.3 Communications From You to Us

To contact us:

• Email: support@auranser.com (general inquiries, disputes, fraud reporting)

• Phone: 888-311-9964

• In-app: through the app

• Mail: Auranser Inc., Attn: Customer Service, 3160 Hwy 21, STE 103-873, Fort Mill, SC 29715

Written Notice Requirements:

Certain communications must be sent in writing to be effective:

• Account closure requests

• Arbitration opt-out (through the opt-out form at auranser.com/legal/arbitration-opt-out, by email per Section 13.7, or by mail to the address below)

• Formal disputes or legal claims

• Consent withdrawal (for electronic communications)

Send written notices to:

Auranser Inc.

Attn: Legal Department

3160 Hwy 21, STE 103-873, Fort Mill, SC 29715

7.4 Marketing Communications

You may opt in to marketing communications (product updates, educational content, referral opportunities, partner offers) and manage preferences at any time in your account settings or by using the unsubscribe link in marketing emails. Transactional, security, and legally required communications cannot be opted out of. We do not sell your contact information to third parties.

8. PRIVACY AND DATA USAGE

8.1 Our Privacy Commitments

See our Privacy Policy, available at auranser.com/privacy and reviewed during account opening, for complete details on how we collect, use, and protect your information and your rights regarding your data.

8.2 Information We Collect and How We Use It

To provide the platform and comply with law, we collect information you provide (such as registration and identity details, financial information, and communications), information collected automatically (such as device, log, location, and usage data), and information from third parties (such as identity-verification and account-aggregation services). We use it to provide and improve the services, prevent fraud, comply with legal and regulatory requirements, personalize your experience, and communicate with you. The complete categories of personal information we collect, the sources, and the purposes are described in our Consumer Privacy Policy §5 and §7A (CCPA/CPRA disclosure), which is incorporated into this Agreement by reference and provided to you at account opening.

8.3 Information Sharing

See our Privacy Policy. We share information only as described in Consumer Privacy Policy §8, including with service providers, our securities custodian (Alpaca Securities LLC), and as required by law. The complete categories of recipients and the purposes of sharing are set out in Consumer Privacy Policy §8, incorporated into this Agreement by reference.

8.4 Data Retention

Retention. We retain your information only as long as needed for the purposes described in this Agreement and to satisfy legal, regulatory, tax, and recordkeeping obligations. The complete retention schedule by data category, including the SEC advisory-records retention period, BSA/AML and tax periods, and the treatment of behavioral-score data, is set out in our Consumer Privacy Policy §13, incorporated into this Agreement by reference.

Your deletion right. You may request deletion of your data (subject to legal-retention requirements) by emailing privacy@auranser.com or through your account settings; we will verify your identity, respond within the time required by law, and confirm what was deleted and the legal basis for any retention. Some data must be retained (for example, KYC/CIP, advisory records, and audit logs required by GLBA, BSA/AML, SEC, and tax rules), and behavioral-score input data is retained only in de-identified form after a verified deletion request, as described in Consumer Privacy Policy §13. A request to delete data necessary to provide your account, or to delete your account, will close your account and terminate all active services; for an advisory account this is processed as a termination of the Investment Advisory Agreement under IAA §11.2(a), after which your securities remain in your name at the Custodian for you to transfer or liquidate. To prevent abuse, where Auranser has a good-faith basis to suspect deletion abuse it may decline to re-open an account for a reasonable period after deletion; this is a discretionary, fraud-based hold and not an automatic bar on re-opening.

8.5 Your Privacy Rights

All users have the right to access, correct, and request deletion of their information (subject to legal retention), to opt out of marketing, and to file a complaint with us or a regulator. Residents of states with comprehensive privacy laws have additional rights, including rights to know, to opt out of sale, sharing, targeted advertising, and profiling that produces legal or similarly significant effects, to limit use of sensitive personal information, to data portability, to non-discrimination, and to appeal. The complete state-by-state rights and the California, Colorado, Connecticut, Florida, Maryland, Minnesota, and Virginia specifics are set out in our Consumer Privacy Policy §9A and §11, incorporated into this Agreement by reference.

To exercise privacy rights: email privacy@auranser.com, call 888-311-9964, use Settings > Privacy, or write Auranser Inc., Attn: Privacy Officer, 3160 Hwy 21, STE 103-873, Fort Mill, SC 29715. We must verify your identity before fulfilling a request.

8.6 Children’s Privacy

Auranser offers accounts only to adults age 18 and older and does not knowingly collect personal information from anyone under 18.

8.7 Data Security Incidents

If we experience a data breach, we will notify affected users as required by applicable law. Our Incident Response Program, including breach classification, notification content and timing, and regulator notifications, is described in our Consumer Privacy Policy §15, incorporated into this Agreement by reference. If you suspect unauthorized access to your account, see Section 5.3 for immediate steps.

9. INTELLECTUAL PROPERTY

9.1 Auranser Intellectual Property

Ownership:

Auranser owns all rights, title, and interest in:

• The Auranser mobile app and website

• The Auranser name, logo, and branding

• All software, algorithms, and technology used to provide services

• All content, text, graphics, user interfaces, and designs

• Behavioral engagement score methodology and calculation algorithms

• Financial education curriculum and materials

• Patents, trademarks, copyrights, and trade secrets

Protected by:

• U.S. and international copyright laws

• Common law trademark rights

• Patent rights, to the extent applicable

• Trade secret protection

• Contractual restrictions

9.2 License to Use Auranser Services

We grant you a limited, non-exclusive, non-transferable, revocable license to:

• Access and use the Auranser mobile app and website

• Use our services for personal, non-commercial purposes

• Download and use educational content for your personal financial education

You may not:

• Modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, software, products, or services obtained from Auranser

• Reverse engineer, decompile, disassemble, or otherwise attempt to discover the source code of the Auranser platform or score algorithms

• Use any robot, spider, scraper, or other automated means to access Auranser services

• Frame or mirror any content from Auranser platforms

• Remove any copyright, trademark, or proprietary notices

• Use Auranser intellectual property for commercial purposes without written permission

9.3 User-Generated Content

You retain ownership of:

• Photos you upload (profile pictures, receipts, etc.)

• Comments or feedback you provide

• Financial goals and notes you create

By providing content to Auranser, you grant us a worldwide, non-exclusive, royalty-free, perpetual (except that, upon a verified deletion request under §8.4, this license terminates as to identifiable user content, subject to the retention exceptions in §8.4) license to:

• Store and display your content as necessary to provide services

• Use aggregated, de-identified data for product improvement and research

• Use feedback and suggestions to improve our services (without attribution or compensation)

You represent and warrant that:

• You own or have rights to any content you upload

• Your content does not violate any third-party rights

• Your content does not contain illegal, offensive, or inappropriate material

We may remove content that:

• Violates this Agreement or any applicable law

• Infringes third-party intellectual property rights

• Contains malware or malicious code

• We reasonably determine violates our acceptable-use and community standards or applicable law, under our review process

9.4 Third-Party Content and Links

Auranser may provide:

• Links to third-party websites or services

• Educational content from third-party providers

• Integration with third-party financial services

We do not:

• Endorse or control third-party content

• Guarantee accuracy or reliability of third-party information

• Assume responsibility for third-party services or policies

When using third-party services through Auranser:

• You are subject to their terms and conditions

• You are subject to their privacy policies

• We are not responsible for their actions or security practices

• We may receive compensation for referring you to partners

9.5 Trademarks

Auranser™ and associated marks may not be used without our written consent, except to reference our services factually. All third-party marks are property of their respective owners.

9.6 Score Portability

The Enrichment Score methodology is proprietary. You have the right to access and export the underlying data (behavioral-factor summary, financial-behavior data in commonly used machine-readable formats, and historical score values) under Consumer Privacy Policy §9, consistent with your data-portability rights.

10. PROHIBITED USES

10.1 General Prohibitions

You agree not to use Auranser services to:

Engage in illegal activity:

• Money laundering or structuring transactions to avoid reporting requirements

• Terrorist financing

• Fraud or identity theft

• Illegal gambling

• Purchase of illegal goods or services

• Violation of economic sanctions or export controls

• Any activity that violates federal, state, or local law

Harm Auranser or others:

• Impersonate any person or entity

• Transmit viruses, malware, or harmful code

• Attempt unauthorized access to our systems (hacking, password mining, etc.)

• Interfere with the proper working of our services

• Use services in a manner that could damage, disable, overburden, or impair our infrastructure

• Circumvent security features or user authentication measures

Abuse our services:

• Open multiple accounts to circumvent restrictions

• Use accounts for business or commercial purposes (personal use only)

• Sell, rent, or transfer your account to another person

• Share your account credentials

• Create accounts using false, misleading, or stolen information

• Engage in wash trading or market manipulation (investment accounts)

• Artificially inflate the score through gaming or manipulation

10.2 Consequences of Prohibited Use

If you engage in prohibited activity, we may:

• Immediately suspend or freeze your account

• Terminate your account and close all products

• Report activity to law enforcement or regulatory authorities

• Withhold amounts otherwise payable to you by Auranser pending investigation

• Seek legal remedies including damages

Account closure for prohibited activity:

• We will provide written notice of closure and reason (except in cases of fraud or legal investigation)

• Any amounts otherwise payable to you by Auranser will be returned after deduction of amounts you owe

• For securities accounts, Auranser's advisory authority ends on closure and your securities remain at the Custodian in an account in your name, as described in Section 11.1 and the Investment Advisory Agreement.

• You may be prohibited from opening future Auranser accounts

10.3 Reporting Prohibited Activity

Report suspected prohibited activity to support@auranser.com or 888-311-9964. We do not retaliate against users who report in good faith.

11. ACCOUNT SUSPENSION AND TERMINATION

11.1 Your Right to Close Your Account

You may close your account at any time, for any reason, without penalty, by contacting support@auranser.com or calling 888-311-9964. Your closure request is effective when you submit it, and final closure completes once any outstanding balances or fees are settled. Account closure is free.

Advisory Services accounts: Closing your account terminates the Investment Advisory Agreement under IAA §11.2(a). Advisory fees are prorated through termination; your securities remain at the Custodian in your name. Transfer, liquidation, and fee-settlement mechanics are governed by the IAA. You may alternatively elect the subscription-cancellation wind-down in IAA §5.1A(b).

Death or incapacity: Upon receipt of notice with satisfactory proof of authority, your account will be closed. Platform Access Fee billing stops as of the date of death or incapacity; amounts billed for periods after that date will be refunded. Your legal representative may obtain records under §8.4 and §8.5.

After account closure:

• All account access is terminated

• Transaction history available by request for 60 days

• We retain records as required by law (generally at least 5 years; see the retention schedule in our Consumer Privacy Policy §13)

• You remain responsible for any transactions or obligations incurred before closure

11.2 Our Right to Suspend Your Account

We may temporarily suspend your account if:

• We suspect unauthorized access or fraud

• We detect unusual or suspicious activity

• Your account is subject to legal holds (court orders, garnishments)

• You have outstanding obligations or chargebacks

• We need to conduct a security review

• Your identity verification is incomplete or outdated

• We believe your account may be used for prohibited activity

• Technical issues require temporary suspension

During suspension:

• You cannot execute new transactions

• Existing obligations continue (subscriptions)

• You can contact us to resolve the suspension

How we notify you:

• Immediate notification via email and/or SMS

• In-app message explaining reason for suspension (if safe to do so)

• For fraud-related suspensions, we will attempt to contact you by phone, automated voice system, or other direct channel

Resolving a suspension:

• Contact support@auranser.com or call 888-311-9964

• Provide requested verification or information

• Address the issue that caused suspension

• Account restored promptly after resolution

11.3 Our Right to Terminate Your Account

We may terminate your account if:

• You violate this Agreement or any Product Supplement

• You provide false, misleading, or stolen information

• You engage in prohibited activities

• You have adverse account history (repeated chargebacks, fraud, etc.)

• You fail to respond to verification requests

• Your account remains dormant for extended period

• You become ineligible for services (sanctions list placement, legal prohibitions)

• We determine, in our discretion, that continuing the relationship is not feasible or advisable. You may request a written explanation within 30 days of termination, except to the extent disclosure of the reason is prohibited by law, including the Bank Secrecy Act's suspicious-activity-report confidentiality provisions. See Section 11.5 for review

Termination notice:

• Standard termination: We will provide at least 30 days’ advance written notice to your email address of record (and by mail where email delivery cannot be confirmed), stating the reason for termination where lawful and practicable, except to the extent disclosure of the reason is prohibited by law, including the Bank Secrecy Act's suspicious-activity-report confidentiality provisions

• Immediate termination (without 30-day notice) only for:

• Confirmed fraud or criminal activity affecting your account or our systems

• Court order, law enforcement directive, or regulatory requirement compelling closure

• Placement on OFAC sanctions list or other legally mandated prohibition

• Imminent threat to the safety or security of other users or our systems

After termination:

• All account access is immediately revoked

• Pending transactions will be completed or cancelled

• If you hold an investment account, Auranser's advisory authority ends on termination and your securities remain at the Custodian in an account in your name, as described in Section 11.1 and the Investment Advisory Agreement.

• You may request transaction history within 60 days of termination

Amounts owed after termination:

• We may pursue collection, including through third-party collection agencies

• You remain liable for fees and collection costs

Prohibition on new accounts:

• If terminated for cause, you may be prohibited from opening new Auranser accounts

• Future applications may be denied

11.4 Effect of Termination on Agreements

Upon termination:

• This Master User Agreement terminates

• All Product Supplements terminate

• You remain bound by:

• Outstanding payment obligations

• Confidentiality provisions

• Arbitration agreement (see § 13.9 for its survival and temporal scope)

• Intellectual property restrictions

• Indemnification obligations

• Any provisions stated to survive termination

Survival of provisions:

Even after termination, the following provisions remain in effect:

• Sections 8 (Privacy), 9 (Intellectual Property), 10 (Prohibited Uses), 12 (Limitation of Liability), 13 (Arbitration), and 14 (General Provisions)

11.5 Administrative Review

If you believe an action on your account was taken in error, contact support@auranser.com; Auranser will review and respond in writing. During the review period, we will maintain access to your account, including the ability to withdraw or transfer assets held at the Custodian, except where withdrawal is prohibited by law, regulatory directive, or court order, or where Auranser reasonably believes the assets are the proceeds of fraud or unlawful activity.

12. LIMITATION OF LIABILITY

Advisory services carve-out. The warranty disclaimers in §12.1 and the exclusion of indirect or consequential damages in §12.2 do not apply to investment advisory services, which are governed exclusively by Article 12 of the Investment Advisory Agreement; and nothing in this Article 12 waives any right under the Investment Advisers Act of 1940 that cannot be waived by agreement. The custody and SIPC disclosures in §12.3 and the indemnification terms in §12.4 (including their limitations) apply according to their terms.

12.1 No Warranty Disclaimer

AURANSER SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO:

• Warranties of merchantability or fitness for a particular purpose

• Warranties of title or non-infringement

• Warranties that services will be uninterrupted, timely, secure, or error-free

• Warranties regarding results or accuracy of information

• Warranties that defects will be corrected

• Warranties that data transmission will be secure or uncorrupted

• Warranties that services are free from viruses or harmful components

• Warranties regarding third-party services or content

Some jurisdictions do not allow exclusion of implied warranties, so some of the above exclusions may not apply to you. You may have additional rights that vary by jurisdiction.

12.2 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, AURANSER, ITS PARENT COMPANY, SUBSIDIARIES, AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, PARTNERS, AND LICENSORS (COLLECTIVELY, “AURANSER PARTIES”) SHALL NOT BE LIABLE TO YOU FOR:

Indirect or Consequential Damages:

• Loss of profits, revenue, or business opportunity

• Loss of data or information

• Loss of goodwill or reputation

• Cost of substitute services

• Personal or emotional distress (except as required by law for intentional infliction of emotional distress claims)

• Consequential, incidental, indirect, exemplary, or punitive damages (except where prohibited by law from limiting punitive damages)

Even if:

• Auranser has been advised of the possibility of such damages

• Such damages are foreseeable

• A remedy fails of its essential purpose

Our Liability for Direct Damages Is Limited As Follows:

(a) Investment Advisory Services; see Investment Advisory Agreement:

Investment advisory services are governed exclusively by the Investment Advisory Agreement (Article 12: Limitation of Liability). This Master User Agreement does not limit, modify, supplement, or restate the liability terms applicable to investment advisory services. Any conflict between this Section 12.2 and the Investment Advisory Agreement shall be resolved in favor of the Investment Advisory Agreement.

For clarity: “Investment advisory services” include portfolio management, investment recommendations, asset allocation advice, any discretionary trading authority (if and when elected under IAA §2.1(b)), and any other service provided under the Investment Advisory Agreement or subject to our fiduciary duty under the Investment Advisers Act of 1940.

(b) Non-Advisory Services:

For services NOT governed by the Investment Advisory Agreement, our liability for direct damages is limited as follows:

• Subscription Platform Services: the total amount you paid for subscription services in the 12 months prior to the claim

• Technology Platform Services (app access, authentication, data security, identity verification): the total amount you paid to Auranser in the 12 months prior to the claim

Overlap. If a single incident falls within more than one category above (for example, an authentication or data-security failure affecting a subscriber), the category with the higher applicable cap controls, and the caps are not cumulative.

(c) Willful Misconduct and Consumer Protection Law Violations (No Cap):

The limitations in subsection (b) do NOT apply to losses caused by:

• Auranser’s intentional misconduct, fraud, or willful violation of law

• Gross negligence or reckless disregard for your rights

• Rights and claims that cannot be limited or excluded under applicable law, including non-waivable rights under the Investment Advisers Act of 1940 and applicable securities laws

• Security breaches caused by failure to implement industry-standard security measures that Auranser was legally required to implement

In such cases, you may recover your full documented actual damages as determined by arbitration or court judgment, subject to the applicable exceptions in Section 13.

We are not liable for losses caused by:

• Your violation of this Agreement

• Your gross negligence or intentional misconduct

• Unauthorized access resulting from your intentional disclosure of account credentials to third parties

• Third-party actions (including our service providers’ failures), except where we failed to exercise reasonable care in selecting or monitoring the service provider

• Force majeure events (natural disasters, acts of war, terrorism, pandemic, governmental emergency orders) that prevent performance despite reasonable efforts

• Government actions or legal process requiring us to freeze, seize, or report your account

• Failure of telecommunications or electronic systems beyond our control, provided we have implemented redundant systems consistent with industry standards

• Your device or software problems that are not caused by Auranser’s software or integrations

• Loss or theft of your device, provided we have implemented account recovery mechanisms consistent with industry standards

State Law Variations:

Some states do not allow certain limitations on liability, exclusion of consequential damages, or limitations on duration of implied warranties. If you are a resident of such a state, some of the above limitations may not apply to you, and you may have additional rights under state law. See Section 14.5 (Severability); if any provision is found unenforceable, the remainder of this Agreement remains in effect.

12.3 Service Provider and Third-Party Liability

Third-Party Service Providers:

• We use third parties to provide certain services (securities custody, data aggregation, identity verification, and, if applicable, payment processing, card networks, etc.)

• We are not responsible for actions or failures of third-party providers

• Your recourse for third-party failures may be directly with the provider

• We will assist in resolving disputes with third parties where reasonable

Securities Custody:

• Securities held by Alpaca Securities LLC are protected by SIPC protection up to $500,000, including up to $250,000 for cash claims. SIPC is not insurance and does not protect against a decline in the market value of securities.

• Auranser does not enroll your investment account in any securities lending program; if introduced, terms and disclosures will be provided first. See the Investment Advisory Agreement and your customer agreement with the Custodian for custody protections

• See Investment Advisory Agreement for complete custodial protections

12.4 Indemnification

You agree to indemnify, defend, and hold harmless Auranser Parties from any claims, damages, liabilities, costs, and expenses (including reasonable attorneys’ fees) arising from:

• Your willful misconduct or fraud in connection with Auranser services

• Your material breach of this Agreement

• Your willful violation of any third-party rights through Auranser services

• Content you submit or transmit through our services that infringes third-party rights or violates applicable law

Indemnification Limitations:

• This indemnification does not apply to claims arising from Auranser’s own negligence, willful misconduct, security failures, or breach of this Agreement

• You are not required to indemnify Auranser for losses that Auranser could have prevented through reasonable security measures or compliance with its own policies

We reserve the right to:

• Assume exclusive defense and control of any matter subject to indemnification

• Settle claims on your behalf, provided that any settlement that imposes financial obligations on you or waives your legal rights requires your prior written consent

• Require your cooperation in defending claims

You will not settle any claim without our prior written consent if the settlement:

• Imposes obligations on Auranser

• Admits fault on behalf of Auranser

• Affects Auranser’s legal rights

12.5 Specific Service Exclusions

Educational Content:

• Financial education and information provided through Auranser is for educational purposes only

• Not intended as financial, tax, or legal advice

• You should consult with qualified professionals for personal advice

• This Educational Content exclusion does not apply to financial education content delivered as part of Advisory Services under Investment Advisory Agreement §1.2(c), which is governed by the Investment Advisory Agreement

• We make no representations about accuracy or suitability for your situation

• Past performance examples do not guarantee future results

Behavioral Engagement Score:

• The Enrichment Score is governed by Section 3.4 and the Enrichment Score Disclosure.

Investment Services:

• Investment advisory services subject to separate Investment Advisory Agreement

• Investments involve risk of loss, including loss of principal

• Past performance does not guarantee future results

• We do not guarantee investment returns

• See Investment Advisory Agreement for complete disclaimers

13. DISPUTE RESOLUTION AND ARBITRATION

13.1 Please Read This Arbitration Provision Carefully

PLEASE READ: THIS AFFECTS HOW DISPUTES ARE RESOLVED: When you accept this Agreement, you agree to resolve disputes with Auranser through binding arbitration under this Section 13, unless you opt out within 30 days as described in Section 13.7. During account enrollment we will ask you to confirm that you have read and understood this Section 13; that confirmation is a record of notice and does not affect your right to opt out under Section 13.7.

This means:

• You give up your right to a jury trial

• You give up your right to a court trial (except small claims court)

• Discovery and appeal rights are more limited than in court

• The arbitrator’s decision is binding and final

Exception for small claims court:

You may bring claims in small claims court if the claim qualifies and remains in small claims court.

YOU HAVE THE RIGHT TO OPT OUT OF ARBITRATION (see Section 13.7 below).

Scope. Section 13 governs disputes under this Agreement and each other agreement that incorporates it (each a "Covered Agreement"). Each Covered Agreement keeps its own 30-day opt-out window; see §13.7.

13.2 Scope of Arbitration Agreement

Covered disputes:

This arbitration provision governs disputes arising under or relating to this Agreement and any other agreement between you and Auranser Inc., including the Investment Advisory Agreement and every current and future Product Supplement, except only the disputes expressly carved out in the "Exceptions" list below. Each such agreement incorporates this Section 13 by reference, and by accepting it you agree that disputes under it are resolved under this Section 13, subject to the per-agreement opt-out mechanics of §§ 13.1 and 13.7.

This arbitration provision applies to any dispute, claim, or controversy arising out of or relating to:

• This Agreement or any prior version

• Any Product Supplement or related agreement

• Your Auranser account or use of services

• Any transaction or attempted transaction

• Advertising or promotions

• Privacy or data security

• Behavioral engagement score calculation, methodology, or application (subject to the provisions below and the class action waiver in § 13.5)

• The relationship between you and Auranser (even after termination)

Important: Score-Related Disputes:

Disputes related to your behavioral engagement score are generally subject to arbitration; the following provisions apply:

Individual Score Disputes (Arbitration):

The following score disputes must be arbitrated or brought in small claims court:

• Calculation errors affecting your individual score (see also § 6.2 for dispute process) • Errors in the underlying activity data used in your score • Disputes over score factor disclosure or transparency • Unauthorized access to or disclosure of your score data • Claims that the behavioral engagement score produced an unlawfully discriminatory result affecting you individually

For these individual disputes, arbitration or small claims court provides adequate remedies. You retain the right to opt out of arbitration entirely under § 13.7.

Discovery in Score Arbitrations:

You are NOT entitled to the individual scores or score data of any other user, to Auranser’s proprietary model source code, weights, or training data, or to other users’ personal information in individual arbitration. The scope of discovery is governed by the applicable arbitration rules.

Covered parties:

This arbitration provision applies to disputes between you and:

• Auranser Inc. and its subsidiaries and affiliates

• Auranser’s officers, directors, employees, and agents

• Third-party service providers working on Auranser’s behalf (if named as co-party with Auranser), other than any FINRA-member broker-dealer (including the Custodian)

Exceptions (not subject to this arbitration provision):

• Claims in small claims court that remain in small claims court

• Actions seeking injunctive relief to protect intellectual property rights

• Claims that a court determines cannot be arbitrated under applicable law

• Individual claims by Auranser to collect debts owed

• Claims made non-arbitrable by law: Claims that applicable law makes non-arbitrable, including any claim under a federal or state consumer-protection statute to the extent that statute prohibits mandatory pre-dispute arbitration of the claim

• Claims against a FINRA-member broker-dealer (including the Custodian): Claims against Alpaca Securities LLC or any other FINRA-member broker-dealer are governed by your separate customer agreement with that firm and FINRA rules, not by this Section 13 (see § 13.2A(d)). Disputes against Auranser relating to investment advisory services are covered by this Section 13; see § 13.2A

• Regulatory complaints: Your right to file complaints with regulatory agencies, including the Consumer Financial Protection Bureau (CFPB), state attorneys general, state banking regulators, the Securities and Exchange Commission (SEC), or the Financial Industry Regulatory Authority (FINRA), is not affected by this arbitration provision. You may file regulatory complaints at any time regardless of this agreement, and nothing in this Section 13 requires you to exhaust arbitration before filing a regulatory complaint

• State consumer protection class actions: Claims exempt under state consumer protection laws that prohibit class action waivers (including the California Consumer Legal Remedies Act and, to the extent applicable, comparable laws of other states) may be brought as class actions. See Section 13.5 (State-Law Exempt Claims) for details

Who decides arbitrability:

The arbitrator decides threshold questions about whether a dispute is subject to arbitration under this Section 13, including questions about the validity, enforceability, interpretation, or scope of this arbitration agreement. A court of competent jurisdiction (not the arbitrator) decides (i) the enforceability of the class action waiver in § 13.5, (ii) whether a claim is a class or representative Advisory Dispute, or is otherwise carved out to court under this Section 13, and (iii) whether an agreement containing this Section 13 was formed.

13.2A Securities and Investment-Advisory Disputes

(a) Covered. Disputes arising under or relating to the Investment Advisory Agreement or the investment advisory services provided under it, including disputes involving the management, performance, or appropriateness of your investment portfolio, alleged violations of the Investment Advisers Act of 1940 or SEC regulations, and claims relating to securities transactions (collectively, "Advisory Disputes"), are arbitrable under this Section 13 on the same opt-out basis as other disputes: you are bound when you execute the Investment Advisory Agreement unless you opt out within the advisory-specific 30-day opt-out window that runs from that execution (§ 13.7). This Agreement evidences a transaction involving interstate commerce, and the Federal Arbitration Act governs the interpretation and enforcement of this Section 13. Advisory Disputes are administered by the AAA or JAMS as provided in § 13.3. Advisory Disputes are subject to the class action waiver in §13.5 and are arbitrable under this Section 13 unless you opt out.

(b) Investment Advisers Act anti-waiver (non-waivable rights preserved). Nothing in this Section 13 constitutes a condition, stipulation, or provision binding you to waive compliance with any provision of the Investment Advisers Act of 1940 or any SEC rule thereunder, or a waiver of any right you have under federal or state securities laws that cannot be waived by agreement. To the extent any provision of this Section 13 would operate to waive or limit such rights or Auranser's fiduciary obligations as your investment adviser, that provision is void and unenforceable to that extent. Arbitration under this Section changes only the forum in which Advisory Disputes are heard.

(c) Advisory liability. The measure of Auranser's liability for investment advisory services is governed by Investment Advisory Agreement §12.3 regardless of forum.

(d) Your FINRA rights against the Custodian are untouched. Auranser is an SEC-registered investment adviser and is not a FINRA member; FINRA Dispute Resolution Services has no jurisdiction over claims made solely against Auranser. Nothing in this Section 13 waives, limits, amends, or supersedes (i) your right under FINRA rules to arbitrate before FINRA Dispute Resolution Services any claim against Alpaca Securities LLC or any other FINRA-member broker-dealer or its associated persons, or (ii) any arbitration agreement between you and the Custodian. Claims against a FINRA-member broker-dealer are neither covered by nor barred by this Section 13. Your customer agreement with the Custodian contains its own mandatory FINRA arbitration clause, which has no opt-out; opting out of this Section 13 does not affect it, and you cannot use this Section 13 to opt out of arbitration of brokerage disputes with the Custodian.

(e) Predispute arbitration disclosure (securities). This Section 13, as applied to Advisory Disputes, is a predispute arbitration clause. Because it applies to Advisory Disputes unless you opt out, you agree that: (i) you are giving up the right to sue in court, including the right to a jury trial, except as the applicable arbitration rules or this Section otherwise permit; (ii) arbitration awards are generally final and binding, with very limited court review; and (iii) discovery is generally more limited than in court.

(f) Regulatory complaints preserved. Nothing in this Section 13 limits your right to file a complaint with the SEC, FINRA, or any other regulator at any time (see also § 13.2 "Exceptions").

(g) Amendments affecting advisory protections. Any amendment to this Section 13 as applied to Advisory Disputes is a material amendment; as to Investment Advisory Agreement clients, such a change takes effect only upon the affirmative consent required by Investment Advisory Agreement § 15.2(b).

13.3 Arbitration Procedures

Arbitration administrator:

Arbitration will be conducted by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, or by JAMS under its Streamlined Arbitration Rules and Procedures and its Consumer Arbitration Minimum Standards. The party filing the arbitration demand selects the administrator.

Rules available at:

• AAA: www.adr.org

• JAMS: www.jamsadr.com

If AAA and JAMS are unable or unwilling to arbitrate:

The designation of the AAA as administrator is not an integral or essential term of this arbitration agreement; the parties' agreement is to arbitrate, not to arbitrate only before a particular administrator. If both the AAA and JAMS are unavailable or decline to administer, either party may petition a court of competent jurisdiction to appoint a substitute arbitrator under the Federal Arbitration Act, and the arbitration will proceed before that arbitrator. Judgment on any award may be entered in any court of competent jurisdiction.

How to initiate arbitration:

1. Pre-arbitration notice (required):

• Send written notice to: Auranser Inc., Attn: Legal - Arbitration Notice, 3160 Hwy 21, STE 103-873, Fort Mill, SC 29715

• Notice must describe claim, provide contact information, and specify remedy sought

• We will attempt to resolve your claim informally within 60 days. Any applicable statute of limitations or repose is tolled during this 60-day informal-resolution period

2. File demand for arbitration:

• If we cannot resolve informally, file with AAA or JAMS

• Pay required filing fee (see fee provisions below)

• Provide copy to Auranser at address above

Arbitration format:

• Conducted by telephone, video conference, written submission, or in-person as determined by arbitrator

• In-person hearings held at location convenient to you or as determined by arbitrator

• Conducted in English

Arbitrator selection:

• One arbitrator selected according to AAA or JAMS rules

• Arbitrator must be attorney with at least 10 years experience or retired judge

• Arbitrator must follow and apply applicable law

Arbitrator authority:

• Arbitrator may award any relief available in court

• Except as necessary to preserve a claim for public injunctive relief that cannot be waived under applicable law (see Section 13.5), the arbitrator cannot award relief benefiting anyone other than you. Nothing in this Agreement waives, in any forum, your right to seek public injunctive relief; to the extent applicable law (including McGill v. Citibank, N.A., 2 Cal. 5th 945 (2017)) preserves that right, a claim for public injunctive relief may be brought and adjudicated in a court of competent jurisdiction.

• Arbitrator’s decision is binding and final (limited appeal rights)

• The arbitrator will provide a written reasoned decision stating the arbitrator's findings and conclusions

13.4 Fees and Costs

Arbitration fees are allocated as provided in the applicable administrator's consumer arbitration rules (AAA Consumer Arbitration Rules or JAMS Consumer Arbitration Minimum Standards, as applicable).

Attorney’s fees:

• Each party pays its own attorney’s fees, except where a statute or applicable law entitles the prevailing party to attorney’s fees, or where the arbitrator finds a claim or defense frivolous or brought in bad faith, in which case the arbitrator may award fees to the extent the applicable arbitration rules permit.

Other costs:

• Each party pays its own costs (travel, expert witnesses, etc.). The arbitrator may allocate costs as justice requires.

13.5 Class Action Waiver

NO CLASS ACTIONS:

YOU AND AURANSER AGREE THAT DISPUTES MUST BE BROUGHT ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, REPRESENTATIVE, MULTIPLE PLAINTIFF, OR SIMILAR PROCEEDING (“CLASS ACTION”).

This means:

• No class arbitrations

• No class actions in court

• No private attorney general actions

• No joining of claims with other customers

• No consolidation of arbitrations

Class action waiver applies to:

• Claims brought in arbitration

• Claims brought in small claims court

• Claims brought in any other forum

Effect of invalidity:

If a court or arbitrator finds the class action waiver invalid or unenforceable for any claim, that claim must be litigated in court and all other claims must be arbitrated.

Effect of an opt-out on this waiver:

If you opt out of arbitration as to a Covered Agreement under Section 13.7, this class action waiver no longer applies to disputes arising under or relating to that Covered Agreement; those disputes proceed in court on whatever basis (individual or class) is available there, but this waiver continues to apply to disputes under every Covered Agreement you did not opt out of.

Advisory Disputes: Advisory Disputes are subject to individual arbitration under this Section, except that claims seeking solely public injunctive relief may be brought in court to the extent required by applicable law.

State and Federal Law Savings Clause:

This class action waiver does not apply to the following categories of claims, which may be brought as class actions if otherwise permitted by applicable law:

State-Law Exempt Claims:

To the extent the following state laws prohibit waiver of class action rights for consumer claims, this waiver does not apply to such claims brought by residents of the specified states:

• California: Claims under the California Consumer Legal Remedies Act and claims to the extent McGill v. Citibank, N.A., 2 Cal. 5th 945 (2017), or subsequent California Supreme Court authority holds such waivers unenforceable, including any claim for public injunctive relief.

• Other States: To the extent any other state statute or state supreme court precedent prohibits enforcement of class action waivers for specific consumer claims, this waiver does not apply to those specific claims in that state.

Severability of Savings Clause:

If any provision of this savings clause is found invalid, the remaining provisions remain in effect and this class action waiver continues to apply to all claims not covered by the surviving savings clause provisions.

13.6 Governing Law and Venue

Governing law:

This Agreement is governed by:

• Federal law, where applicable

• Laws of the State of Delaware (without regard to conflict of laws principles)

Product-specific governing law:

• Investment services: governed by Investment Advisers Act and SEC regulations

Venue for non-arbitrated disputes:

If a dispute is not arbitrated (small claims, injunctive relief, etc.):

• Exclusive venue is state or federal courts in New Castle County, Delaware

• You consent to personal jurisdiction in these courts

Home-state savings: Notwithstanding the foregoing, any court proceeding permitted under this Section 13 (including a small-claims action or a claim within a § 13.5 carve-out) may instead be brought in a court of competent jurisdiction in your state of residence, and nothing in this Section deprives you of the protection of any law of your state of residence that cannot be waived by agreement.

13.7 Right to Opt Out of Arbitration

You may opt out of this arbitration provision separately for each Covered Agreement. Each keeps its own 30-day window running from your acceptance of that agreement. An opt-out under this Agreement does not cover Advisory Disputes; to exclude those, you must separately opt out within 30 days of executing the Investment Advisory Agreement. This opt-out does not affect brokerage disputes with the Custodian (see §13.2A(d)).

Deadline: Within 30 days of first accepting the applicable Covered Agreement.

Method: Use the opt-out form at auranser.com/legal/arbitration-opt-out, email legal@auranser.com, or mail written notice to Auranser Inc., Attn: Legal, 3160 Hwy 21, STE 103-873, Fort Mill, SC 29715, with the email associated with your Auranser account and the agreement(s) you are opting out of. If your notice does not identify a particular agreement, we treat it as opting out of every Covered Agreement then accepted. We will send a confirmation.

Effect: You opt out of arbitration only as to the identified agreement(s); all other provisions remain in effect. Those disputes proceed in court (§13.6) with jury-trial rights. The class action waiver in §13.5 no longer applies to disputes under an opted-out agreement but continues for others.

If you do not opt out: After the 30-day window closes, you are bound as to that agreement.

13.8 Severability

If any provision of this Section 13 is found invalid or unenforceable:

• The remaining provisions continue in effect

• Exception: Except as otherwise provided in Section 13.5 with respect to the class action waiver ("Effect of invalidity"), if the class action waiver is found invalid or unenforceable as to any claim, that claim must be litigated in court and all other claims remain subject to arbitration

13.9 Survival

This arbitration provision survives:

• Termination of your account

• Termination of this Agreement

• Payment of all amounts owed

The arbitration provision applies to disputes arising before, during, or after the relationship.

13.10 Changes to Arbitration Provision

We will provide 60 days advance notice of changes to this Section 13. You may reject changes by opting out within 30 days of the notice using the opt-out procedure in Section 13.7. If you reject changes, the prior version of the arbitration provision applies to your disputes. Amendments affecting Advisory Disputes require your affirmative consent under § 13.2A(g) and Investment Advisory Agreement § 15.2(b), not merely notice.

13.11 Primacy Over Other Arbitration Provisions

For Auranser account holders: To the extent the Website Terms of Service dispute-resolution provisions, or the provisions of any other Auranser agreement, differ from this Section 13, this Section 13 governs for account holders. The Website Terms of Service dispute-resolution provisions (Section 12 of the ToS) apply to website visitors who are not Auranser account holders.

For Investment Advisory Agreement clients: Securities and investment-advisory disputes are governed by this Section 13 (see § 13.2A), which the Investment Advisory Agreement incorporates by reference; the Investment Advisory Agreement does not contain a separate arbitration provision. For all disputes, this Section 13 is the operative arbitration provision. (FINRA-member and Custodian claims: see § 13.2A(d).)

14. GENERAL PROVISIONS

14.1 Entire Agreement

This Master User Agreement, together with all Product Supplements, Feature Supplements, our Privacy Policy, and any other agreement you enter into with Auranser, constitutes the entire agreement between you and Auranser regarding your use of Auranser services.

This Agreement supersedes:

• All prior agreements, whether oral or written

• All representations or statements made during sales process

• All marketing materials or advertising

Only authorized representatives can modify this Agreement:

Statements by customer service representatives or other employees do not modify this Agreement unless provided in writing and signed by an authorized Auranser officer.

14.2 Amendment

We may amend this Agreement at any time as described in Section 1.4 (Changes to Terms).

Material changes:

• 30 days advance notice

• Continued use after the effective date constitutes acceptance, except that advisory-fee and Platform Access Fee increases affecting Advisory clients are governed by Section 6.4

• Right to close account before effective date without fee

Non-material changes:

• Effective immediately

• Notice via updated “Last Updated” date and posting on website

Product-specific amendments:

Changes to Product Supplements govern only that specific product and do not affect other products or this Master User Agreement.

14.3 Assignment

You may not assign this Agreement:

You may not transfer, assign, or delegate this Agreement or your account to any other person or entity without our prior written consent. Any attempted assignment in violation of this provision is void.

We may assign this Agreement:

We may assign this Agreement and your account to:

• Any affiliate or subsidiary

• Any entity that acquires all or substantially all of Auranser’s business or assets

• Any entity in connection with merger, consolidation, or reorganization

Assignment notice:

We will notify you of any assignment that materially affects your rights or obligations.

Advisory relationship carve-out: Notwithstanding the foregoing, assignment of the Investment Advisory Agreement and of any advisory relationship or Advisory Services account is governed exclusively by Investment Advisory Agreement §15.5, which provides for advance notice and an opportunity to object or terminate; nothing in this Section 14.3 permits Auranser to assign the Investment Advisory Agreement or your advisory account except in accordance with that provision.

14.4 No Waiver

Our failure to enforce any provision of this Agreement does not waive our right to enforce that provision or any other provision in the future.

A waiver of any breach does not constitute a waiver of any subsequent breach.

Any waiver must be in writing and signed by an authorized Auranser representative to be effective.

14.5 Severability

If any provision of this Agreement is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction:

• The remaining provisions remain in full force and effect

• The invalid provision will be modified to reflect the parties’ intention to the maximum extent permitted by law

• Exception: Severability of arbitration provisions governed by Section 13.8

14.6 Force Majeure

We are not liable for failure to perform obligations under this Agreement due to causes beyond our reasonable control, including:

• Natural disasters (earthquakes, floods, hurricanes, etc.)

• War, terrorism, or civil unrest

• Pandemic or public health emergency

• Government actions, laws, or regulations

• Labor strikes or disputes

• Failure of telecommunications or internet infrastructure

• Cyberattacks or security incidents

• Third-party service provider failures

During force majeure events:

• We will make reasonable efforts to resume services

• We will provide updates on service restoration

• Fees may be waived or prorated for affected services

• Account access may be limited to protect account security

14.7 Relationship of Parties

You and Auranser are independent contractors.

This Agreement does not create:

• Partnership, joint venture, or agency relationship

• Employer-employee relationship

• Franchisor-franchisee relationship

• Fiduciary duty (except the fiduciary duty arising under the Investment Advisers Act of 1940 with respect to Advisory Services, which arises by operation of law upon the advisory relationship and is not created, limited, or defined by this Agreement)

Neither party has authority to:

• Bind the other party

• Make commitments on behalf of the other party

• Act as agent for the other party

14.8 Third-Party Rights

No third-party beneficiaries:

This Agreement is solely for the benefit of you and Auranser. No third party has any right to enforce any provision of this Agreement.

Exception:

• Arbitration provision extends to third parties as described in Section 13.2

14.9 Interpretation

Definitions:

• “Including” means “including but not limited to”

• “Or” means “and/or” unless context requires otherwise

• Singular includes plural and vice versa

• Headings are for convenience only and do not affect interpretation

• “Days” means calendar days unless stated as “business days”

• “Business days” means Monday through Friday, excluding federal holidays

Conflicts:

• Product Supplements control over this Master User Agreement for specific products

• Later-dated documents control over earlier documents, subject to Section 1.2 (Agreement Hierarchy) and Section 13.11 (Primacy Over Other Arbitration Provisions)

• Federal law controls over state law where preemptive

14.10 Notices and Communications

See Section 7 (Communications and Notices) for complete provisions.

14.11 Language

This Agreement is written and executed in English. Any translation is for convenience only. The English version controls in case of conflict.

14.12 Recordkeeping

Our records:

We maintain records of your account and transactions in accordance with applicable law. In any dispute, our records are presumed accurate, but this presumption may be rebutted by a preponderance of evidence to the contrary. You are encouraged to maintain your own records for comparison purposes.

Your records:

You should maintain your own records of:

• Account statements

• Transaction confirmations

• Communications with Auranser

• Tax documents

• Investment agreements and disclosures

14.13 Compliance with Laws

You agree to comply with all applicable laws when using Auranser services, including:

• Bank Secrecy Act and anti-money laundering laws

• Economic sanctions and export control laws

• Consumer protection laws

• Tax laws and reporting requirements

• Securities laws (for investment accounts)

14.14 Regulatory Supervision

You may file complaints about our services with the Consumer Financial Protection Bureau, the Securities and Exchange Commission, your state financial regulator, and other regulatory agencies at any time.

14.15 USA PATRIOT Act Notice

Important information about procedures for opening a new account:

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions, including our custodian, to obtain, verify, and record information that identifies each person who opens an account.

What this means for you:

When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

14.16 Military and Veteran Consumer Protections

Servicemember Self-Identification: If you are an active-duty servicemember, reservist, National Guard member, or military dependent, you may identify your military status during account opening or at any time in your account settings. Self-identification ensures you receive all applicable protections under federal and state military consumer protection laws. You may also contact support@auranser.com or call 888-311-9964 to report your military status.

Deployment Protections: If you are deployed on active duty, contact support@auranser.com to request account accommodations, which may include suspension of the Platform Access Fee and protection from dormancy or closure during your deployment. An account for which such accommodations have been granted is in "deployed status" for purposes of Section 4.6 for the documented deployment period. For an Advisory Services account, advisory services and the Investment Advisory Fee continue as disclosed in the Investment Advisory Agreement, and deployed status does not by itself cancel the subscription.

Military Consumer Resources:

• CFPB Office of Servicemember Affairs: consumerfinance.gov/servicemembers

• Armed Forces Legal Assistance: legalassistance.law.af.mil

• Military OneSource: militaryonesource.mil

15. CONTACT INFORMATION

15.1 How to Contact Auranser

Customer Support:

• Email: support@auranser.com

• Phone: 888-311-9964

• In-app: through the app

Privacy Questions:

• Email: privacy@auranser.com

• Privacy Officer, Auranser Inc., 3160 Hwy 21, STE 103-873, Fort Mill, SC 29715

Legal Notices and Disputes:

• Email: legal@auranser.com

• Legal Department, Auranser Inc., Attn: Legal Notices, 3160 Hwy 21, STE 103-873, Fort Mill, SC 29715

Arbitration Notices:

• Auranser Inc., Attn: Legal - Arbitration Notice, 3160 Hwy 21, STE 103-873, Fort Mill, SC 29715

Mailing Address:

Auranser Inc., 3160 Hwy 21, STE 103-873, Fort Mill, SC 29715

ACKNOWLEDGMENT AND ACCEPTANCE

By clicking “I Agree,” creating an Auranser account, or using Auranser services, you acknowledge that:

☐ You have read this Master User Agreement in its entirety

☐ You understand the terms and agree to be bound by them

☐ You have reviewed the E-SIGN consent and agree to receive communications electronically

☐ You consent to Auranser’s collection, use, and sharing of your information as described in the Privacy Policy

☐ You understand that Auranser is not a bank

☐ You certify that all information you provided is true, complete, and accurate

ARBITRATION NOTICE ACKNOWLEDGMENT (Section 13)

Section 13 applies to your disputes with Auranser when you accept this Agreement, unless you opt out within 30 days (Section 13.7). Checking this box confirms you have read and understood Section 13; it does not affect your right to opt out.

☐ I HAVE READ AND UNDERSTAND SECTION 13. By accepting this Agreement, I agree to resolve disputes through binding individual arbitration instead of court, unless I opt out within 30 days under Section 13.7. An opt-out under this Agreement does not cover Advisory Disputes; I must separately opt out within 30 days of executing the Investment Advisory Agreement (see Section 13.7).

Effective Date: [Date you accept this Agreement]

User Name: [Your Name]

Date: [Date]

Electronic Signature: Captured electronically at acceptance.

APPENDIX A: DEFINITIONS

Account: Your Auranser user account on the Platform, including any Advisory Services accounts.

Agreements: Collectively, this Master User Agreement, all Product Supplements, Feature Supplements, the Privacy Policy, and any other terms you accept when using specific Auranser services.

Advisory Services: Investment advisory services provided by Auranser under the Investment Advisory Agreement, including portfolio management, investment recommendations, and asset allocation advice. See the Investment Advisory Agreement for complete terms.

Auranser Platform: The Auranser mobile application, website (auranser.com), and all associated technology, software, and services.

Business Day: Monday through Friday, excluding federal holidays.

Custodian: Alpaca Securities LLC, a FINRA/SIPC member broker-dealer that holds and safeguards securities in your investment account. See the Investment Advisory Agreement for complete custodial terms.

Educational Services: Financial literacy content, tools, games, and educational materials provided through the Auranser platform.

Platform Access Fee: The Auranser Plus subscription fee ($9.99/month or $99.99/year) described in Section 6.1. Required for Advisory Services; never deducted from your investment account. Not required to keep securities custodied after the advisory relationship ends.

Platform Services: The technology platform, financial education, engagement tracking, budget tools, community features, market intelligence, and other non-advisory services provided by Auranser through the Auranser Platform. See the Website Terms of Service (§1.5(a)) for complete terms.

Product Supplements: Agreement documents specific to individual Auranser products, including the Investment Advisory Agreement and any future product-specific terms.

Enrichment Score: (also referred to in this Agreement as the "behavioral engagement score") A proprietary, self-only gamified engagement metric developed by Auranser that measures behavioral engagement categories described in the Enrichment Score Disclosure. It is not a consumer report or credit score, is not used for credit or lending decisions, and is visible to you in the app. See § 3.4 (prohibited uses and classification), § 6.2 (governance and dispute rights), and the Enrichment Score Disclosure (auranser.com/enrichment-score-disclosure).

You/Your: The person who has opened an Auranser account and agreed to this Master User Agreement.

END OF MASTER USER AGREEMENT