Terms of Service

Effective Date: June 1, 2026

The following document sets out the terms of use of the billcara.com website and the publications, newsletters, reports, podcasts, data products, portfolio updates, and other content distributed under the Bill Cara brand (the “Services”). Before subscribing to, registering for, or otherwise using any of the Services, you are required to read, understand, and agree to these terms.

Please read this User Agreement, together with the Privacy Policy, the Disclaimers, and the DMCA Copyright Policy (collectively, the “User Agreement”), fully and carefully before using billcara.com (the “Site”) and the Services offered through the Site and our affiliated channels, including Substack (“we,” “us,” or “our”).

This User Agreement sets out the legally binding terms and conditions for your use of the Site and the Services.

1. Acceptance of User Agreement

By registering for and/or using the Services in any manner — including visiting or browsing the Site, subscribing to any free or paid publication, accessing any portfolio update, or downloading any report — you agree to this User Agreement and to all operating rules, policies, and procedures published from time to time on the Site. Each is incorporated by reference and may be updated from time to time without individual notice to you.

Certain portions of the Services — including, for example, paid subscription tiers, freemium portfolio updates, and proprietary research reports — may be subject to additional terms specified by us at the point of purchase or access. Your use of those Services is subject to those additional terms, which are incorporated into this User Agreement by reference.

This User Agreement applies to all users of the Services, including, without limitation, free subscribers, paid subscribers, trial users, contributors of content, and casual visitors, whether registered or otherwise.

Arbitration Notice and Class Action Waiver: Except for certain disputes described in the Arbitration section below, you agree that disputes between you and us will be resolved by binding, individual arbitration, and you waive your right to participate in a class action lawsuit or class-wide arbitration.

2. Eligibility

You represent and warrant that you are at least 18 years of age. If you are under 18, you may not use the Services under any circumstances without the supervision of an adult. The Services are intended for adult, financially literate readers who understand the risks of capital markets.

We may, in our sole discretion, refuse to offer the Services to any person or entity and may change eligibility criteria at any time. You are solely responsible for ensuring that your use of the Services complies with all laws, rules, and regulations applicable to you, including securities, tax, and import/export laws of your jurisdiction. The right to access the Services is revoked where this User Agreement or use of the Services is prohibited, or where any aspect of the Services conflicts with applicable law. The Services are offered for your personal use and not for the use or benefit of any third party.

3. Registration and Subscriptions

You may register for an account on the Site (an “Account”) using e-mail or other supported means of identification. Some portions of the Services — including general Site browsing and certain free posts — do not require an Account. Other portions — including Forum access, paid newsletters, the Portfolio Updates, the Global Market Navigator, INSTAT Market Pulse reports, the Cara Playbook, and reserved research areas — require either a registered Account, an active paid subscription, or both.

You must provide accurate and complete information at registration and keep your Account information current. You shall not:

select or use as a username the name of another person with intent to impersonate that person;
use as a username a name subject to the rights of any person other than you without authorization; or
use a username that is offensive, vulgar, or obscene.

You are solely responsible for activity that occurs under your Account and for keeping your Account password and payment information secure. You may not use another person’s Account or registration information without permission, and you may not share, resell, or transfer your subscription credentials. We treat credential sharing as a breach of this Agreement and a basis for termination without refund.

You must notify us promptly of any unauthorized use of your Account, any change in your eligibility to use the Services, or any breach of security. You may delete your Account at any time by following the instructions on the Site or by writing to us at the contact address below.

4. Subscription Fees, Billing, and Cancellation

Paid access to billcara.com publications — and to publications distributed through third-party platforms such as Substack — is billed in advance on a recurring basis (monthly, annual, or as otherwise stated at checkout). By subscribing, you authorize us, or the third-party platform through which you subscribed, to charge the payment method on file at the then-current rate until you cancel.

Where books, single reports, or other one-off products are sold directly through billcara.com, the sale is between you and us. Unless we expressly state otherwise at the point of sale, all one-off purchases are final and non-refundable once access has been granted or the digital product has been delivered. Where the same or comparable books, single reports, or other one-off products are sold through third-party platforms such as Amazon, the platform’s own purchase, delivery, and refund terms apply in addition to this User Agreement, and your transaction is between you and that platform.

Prices, tiers, and product bundles may change. We will give reasonable advance notice of any price increase that applies to your renewal. Promotional pricing, founder rates, and launch discounts — including any discount offered in connection with the launch of billcara.com — apply only as described in the offer and may not be combined with other offers.

You may cancel a paid subscription at any time. Cancellation stops future renewals; it does not entitle you to a refund of fees already paid for the current billing period, except where required by applicable law. Where a subscription is purchased through a third-party platform (for example, Substack), cancellation and refund mechanics are governed by that platform’s terms in addition to this User Agreement.

5. Forum and Community Features

Access to the Forum and any other community-discussion or feedback features (collectively, the “Forum”) is offered to paid subscribers, on the tiers we designate from time to time, as a facility for open discourse about markets, securities, the Services, and the operation of the Site — including bug reports, feature suggestions, and other feedback to us.

The Forum is a user-generated content channel. Posts, replies, and other contributions made by subscribers in the Forum are the opinions of the contributing users and not of billcara.com, Bill Cara, or any contributor to our publications. We do not review, pre-screen, verify, endorse, adopt, or take responsibility for the accuracy, completeness, legality, or suitability of any user post. Nothing posted by another subscriber in the Forum is investment advice, a recommendation, or a solicitation, and all such posts are subject to the Investment, Educational, and Publishing Disclaimer in Section 13 below. You access and rely on Forum content at your own risk.

All posts in the Forum are User Content and are governed by Sections 6.3, 8, and 11 of this User Agreement, including the license you grant to us. Without limiting the foregoing, by submitting any feedback, suggestion, idea, bug report, or feature request through the Forum or any other channel (collectively, “Feedback”), you acknowledge that Feedback is non-confidential and you grant us a perpetual, irrevocable, worldwide, royalty-free, sublicensable, and transferable right to use, implement, modify, and exploit such Feedback for any purpose, in any product, without compensation or attribution to you, and without any obligation of confidentiality, accounting, or further notice.

We may, in our sole discretion and at any time, with or without notice and with or without cause: moderate, edit, redact, hide, lock, remove, or refuse to post any Forum contribution; suspend, restrict, or terminate your access to the Forum independently of, and without affecting, your underlying paid subscription, except that no refund is owed for loss of Forum access alone; and apply community guidelines, posting rate limits, topic restrictions, or other rules that we publish from time to time. We may, but are not obligated to, retain or remove archived Forum content upon termination of your Account.

6. Content

6.1 Definition

For purposes of this User Agreement, “Content” includes, without limitation, information, data, text, charts, tables, photographs, videos, audio clips, podcasts (including NotebookLM-generated audio summaries), written posts, articles, comments, research reports, portfolio updates, scoring outputs, software, scripts, graphics, and interactive features generated, provided, or otherwise made accessible on or through the Services. Content also includes User Content as defined below.

6.2 Proprietary Content

The Services include Content authored, developed, scored, or curated by us, including but not limited to:

the Global Market Navigator;
INSTAT Market Pulse reports and INSTAT technical scoring outputs across the R-file universe;
the Cara Playbook (pre-market strategic decision briefs);
the Portfolio Updates (five-to-ten-position model equity portfolios); and
STAT, INSTAT, Four-Gate Funnel methodology, scoring frameworks, and any associated written commentary, models, ratings, screens, charts, and ranking tables.

All such Content is protected by copyright, trademark, trade secret, and other proprietary rights. You must preserve all copyright notices and proprietary markings in any Content you access through the Services.

6.3 User Content

All Content uploaded, submitted, posted, or transmitted to the Services by users (“User Content”) — including comments, replies, Forum posts, and questions submitted to the editor — is the sole responsibility of the person who originated it. You represent that all User Content provided by you is accurate, complete, current, and in compliance with applicable laws, rules, and regulations. You accept that all Content accessed by you through the Services is at your own risk and that you are solely responsible for any loss or damage resulting from your reliance on it.

7. Use License

Subject to this User Agreement and, where applicable, to the subscription tier you hold, we grant each user a worldwide, non-exclusive, non-sublicensable, and non-transferable license to use the Content, meaning to download and display it locally, solely for that user’s personal, non-commercial purposes of using the Services.

Use, reproduction, modification, redistribution, republication, storage, or commercial exploitation of any Content — including, without limitation, redistributing portfolio updates, republishing INSTAT scores, copying tables or charts into third-party publications, scraping Site data, or training machine learning or generative artificial intelligence models on Content — is expressly prohibited without our prior written permission. You may not sell, license, rent, sublicense, or otherwise exploit any Content for commercial use or in any way that violates any third-party right.

Brief, attributed quotation for the purposes of bona fide journalism, commentary, or academic citation is permitted within the limits of fair use, provided that attribution clearly identifies billcara.com and the author.

8. License Grant from You to Us

By submitting User Content through the Services, you grant us a worldwide, non-exclusive, perpetual, irrevocable, royalty-free, fully paid-up, sublicensable, and transferable license to use, edit, modify, truncate, aggregate, reproduce, distribute, prepare derivative works of, display, perform, and otherwise fully exploit the User Content in connection with the Site, the Services, and our businesses and those of our successors and assigns, including for the purpose of promoting and redistributing part or all of the Services in any media now known or later developed.

The foregoing license includes our right to use, display, and perform User Content in connection with sponsor or partner material, and you are not entitled to remuneration for such use. To the extent any User Content includes your name, likeness, voice, or photograph, this license applies to the same.

You also grant each user of the Services a non-exclusive, perpetual license to access your User Content through the Services solely for personal, non-commercial use, including after you terminate your Account.

You represent and warrant that you have all rights necessary to grant these licenses without infringing or violating any third-party rights, including privacy rights, publicity rights, copyrights, trademarks, contract rights, or any other intellectual property rights.

9. Availability of Content

We do not guarantee that any specific Content will be made available on the Site or through the Services. We reserve the right, in our sole discretion and without notice to you, to remove, edit, modify, replace, paywall, or otherwise manipulate any Content at any time, and to remove or block any Content from the Services, including upon receipt of claims from third parties or where we are concerned that this User Agreement may have been violated.

Where Content is reorganized under a freemium model — including portions of reports that become readable by free subscribers once full migration to billcara.com is complete — the allocation of Content between free and paid tiers may change without prior notice.

10. Third-Party Affiliates and Sponsorships

From time to time we may participate in affiliate marketing, sponsorship arrangements, or other commercial relationships, and may include affiliate links on the Site. This means we may earn a commission when you click on such a link or make a purchase through it. The inclusion of any affiliate link does not constitute investment advice, an endorsement of the linked product, or a recommendation that you transact with the linked vendor, and you should evaluate any such product or service on its own merits.

11. Rules of Conduct

As a condition of use, you agree not to use the Services for any purpose prohibited by these Terms. You are responsible for all of your activity in connection with the Services.

You shall not, and shall not permit any third party to, take any action — or upload, post, submit, or otherwise distribute any Content, including User Content — that:

infringes any patent, trademark, trade secret, copyright, right of publicity, or other right of any person or entity, or violates any law or contractual duty;
you know or reasonably should know is false, misleading, untruthful, or inaccurate;
is unlawful, threatening, abusive, harassing, defamatory, libelous, deceptive, fraudulent, invasive of another’s privacy, tortious, obscene, vulgar, pornographic, offensive, or otherwise inappropriate in our sole discretion;
constitutes unauthorized or unsolicited advertising, junk mail, or bulk e-mail;
contains software viruses, malware, or any code, files, or programs designed to disrupt, damage, limit, or interfere with the proper function of any software, hardware, or telecommunications equipment, or to gain unauthorized access to any system or data;
impersonates any person or entity, including any of our employees, representatives, or associates;
includes anyone’s identification documents, account numbers, or sensitive financial information; or
solicits other users to participate in any investment scheme, pyramid arrangement, pump-and-dump activity, coordinated trading, market manipulation, or unregistered securities offering.

You also shall not:

take any action that imposes or may impose an unreasonable or disproportionately large load on our or our third-party providers’ infrastructure;
interfere with the proper working of the Services;
bypass or attempt to bypass any measures we use to prevent or restrict access to the Services or to any paid tier;
run any form of auto-responder or spam on the Services;
use manual or automated software, devices, or processes to crawl, spider, scrape, or harvest any Content from the Services;
use any Content for the training, fine-tuning, evaluation, or grounding of any artificial intelligence, machine learning, or large language model system; or
otherwise take any action in violation of our published guidelines or policies.

You shall not, directly or indirectly:

decipher, decompile, disassemble, reverse engineer, or attempt to derive any source code, scoring formulae, model weights, or underlying algorithms of any part of the Services, including the INSTAT scoring system and any related models, except to the limited extent applicable law specifically permits such restriction to be overridden;
modify, translate, or create derivative works of any part of the Services; or
copy, rent, lease, distribute, or otherwise transfer any of the rights you receive under this Agreement.

You shall comply with all applicable local, state, provincial, national, and international laws and regulations, including securities, sanctions, and tax laws.

We reserve the right to access, read, preserve, and disclose any information we reasonably believe necessary to: (a) satisfy any applicable law, regulation, legal process, or governmental request; (b) enforce this User Agreement, including investigation of potential violations; (c) detect, prevent, or address fraud, security, or technical issues; (d) respond to user support requests; or (e) protect the rights, property, or safety of us, our users, and the public.

12. Third-Party Services

The Services may link to, embed, or otherwise interoperate with third-party websites, services, or resources — including Substack, podcast distributors, data providers, brokerage platforms, charting services, and analytics services such as Ziggma, Investing.com Pro, and similar tools referenced in our methodology. When you access third-party resources you do so at your own risk. These resources are not under our control, and we are not responsible for their content, functions, accuracy, legality, or any other aspect, including the security of any payment or personal data you provide to them. The inclusion of any link does not imply our endorsement of, or any association with, the operator of the linked resource.

13. Investment, Educational, and Publishing Disclaimer

billcara.com is a financial publisher. The Services — including but not limited to all newsletters, reports, podcasts, portfolio updates, INSTAT scores, STAT scores, Four-Gate Funnel screens, Cara Playbook briefs, Navigator content, watchlists, model portfolios, and any commentary by Bill Cara, contributors, or guests — are provided for general informational and educational purposes only.

Nothing in the Services constitutes, or is intended to constitute:

personalized investment advice;
a recommendation to buy, sell, hold, or refrain from buying or selling any security, derivative, digital asset, or other financial instrument;
an offer or solicitation to buy or sell any security in any jurisdiction;
tax, legal, accounting, or insurance advice; or
a substitute for independent due diligence or for the services of a licensed financial professional retained by you for an engagement that takes account of your specific financial situation, objectives, risk tolerance, and constraints.

Although Bill Cara is a retired licensed fiduciary investment manager (NASAA Series 65), no fiduciary, advisory, or client relationship is created between you and us, between you and Bill Cara, or between you and any contributor, by virtue of your subscription to, access to, or use of the Services. Subscribers are readers of a publication, not advisory clients.

Model portfolios are illustrative and educational. They are not personally managed accounts, they reflect hypothetical or paper positions and trades, and their disclosed performance does not reflect actual trading by any account, the impact of material economic and market factors on actual decision-making, transaction costs, taxes, slippage, liquidity constraints, or position sizing appropriate to any individual investor. Past performance — actual or hypothetical — does not guarantee or reliably indicate future results. All investing involves risk, including the loss of principal.

Any decision you make to act, or not to act, on Content obtained from the Services is your sole responsibility. You should consult a licensed financial professional and conduct your own independent analysis before making any investment decision. You release us from all liability for any action or omission you take on the basis of Content obtained through the Services.

14. Forward-Looking Statements

Content on the Services frequently includes forward-looking statements — for example, views on macro regime change, stagflation risk, rate cycles, sector rotation, geopolitical conflict, commodity supply disruption, currency movements, and individual security trajectories. Forward-looking statements are inherently uncertain. Actual results may differ materially from those expressed or implied. We undertake no obligation to update any forward-looking statement after publication.

15. Termination

We may terminate or suspend your access to all or any part of the Services at any time, with or without cause, with or without notice, effective immediately. Termination may result in the forfeiture and destruction of all information associated with your Account, including subscription history. If you wish to terminate your Account, you may do so by following the instructions on the Site or by contacting us. Where you cancel a paid subscription, access to paid Content generally continues to the end of the current billing period unless we determine that you have breached this User Agreement, in which case access may be terminated immediately without refund.

All provisions of this User Agreement that by their nature should survive termination — including, without limitation, intellectual property and license provisions, User Content licenses, the Investment Disclaimer, warranty disclaimers, indemnity, limitation of liability, and dispute resolution — shall survive termination.

16. Warranty Disclaimer

You acknowledge that we have no duty to take any action regarding which users may access the Services, what Content you access through the Services, or how you interpret or use the Content. You release us from all liability arising from your having acquired or not acquired any Content through the Services. We make no representations concerning any Content contained in or accessed through the Services and are not responsible for the accuracy, copyright compliance, legality, or fitness of any Content.

THE SERVICES AND CONTENT ARE PROVIDED “AS IS” AND “AS AVAILABLE,” AND WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED — INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF TITLE, NON-INFRINGEMENT, MERCHANTABILITY, AND FITNESS FOR A PARTICULAR PURPOSE — ALL OF WHICH ARE EXPRESSLY DISCLAIMED. WE, AND OUR DIRECTORS, EMPLOYEES, AGENTS, SUPPLIERS, PARTNERS, AND CONTENT PROVIDERS DO NOT WARRANT THAT:

THE SERVICES WILL BE SECURE OR AVAILABLE AT ANY PARTICULAR TIME OR LOCATION.
ANY DEFECTS OR ERRORS WILL BE CORRECTED.
ANY CONTENT OR SOFTWARE AVAILABLE THROUGH THE SERVICES IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.
THE RESULTS OF USING THE SERVICES WILL MEET YOUR REQUIREMENTS OR FINANCIAL OBJECTIVES.

YOUR USE OF THE SERVICES IS SOLELY AT YOUR OWN RISK.

17. Indemnification

You shall defend, indemnify, and hold harmless us, our affiliates, and each of our and their respective employees, contractors, directors, suppliers, and representatives from all liabilities, claims, losses, and expenses (including reasonable attorneys’ fees) that arise from or relate to your use or misuse of the Site, the Services, or any Content; your User Content; your violation of this User Agreement; any investment decision you make in reliance on the Services; or any infringement by you — or by any third party using your Account or identity — of any intellectual property or other right of any person or entity. We reserve the right to assume exclusive defense and control of any matter otherwise subject to indemnification by you, and you agree to cooperate in asserting available defenses.

18. Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL WE — NOR OUR DIRECTORS, EMPLOYEES, AGENTS, PARTNERS, SUPPLIERS, OR CONTENT PROVIDERS — BE LIABLE UNDER CONTRACT, TORT, STRICT LIABILITY, NEGLIGENCE, OR ANY OTHER LEGAL OR EQUITABLE THEORY WITH RESPECT TO THE SERVICES:

FOR ANY LOST PROFITS, TRADING LOSSES, INVESTMENT LOSSES, DATA LOSS, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR SPECIAL, INDIRECT, INCIDENTAL, PUNITIVE, COMPENSATORY, OR CONSEQUENTIAL DAMAGES OF ANY KIND;
FOR ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE, REGARDLESS OF SOURCE; OR
FOR ANY DIRECT DAMAGES IN THE AGGREGATE IN EXCESS OF THE GREATER OF (A) THE AMOUNTS YOU PAID US FOR THE SPECIFIC SERVICE GIVING RISE TO THE CLAIM IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM AND (B) US$500.

19. Arbitration and Class Action Waiver

YOU AGREE THAT ALL DISPUTES BETWEEN YOU AND US — WHETHER OR NOT INVOLVING A THIRD PARTY — RELATING TO YOUR RELATIONSHIP WITH US, INCLUDING WITHOUT LIMITATION DISPUTES RELATED TO THIS USER AGREEMENT, YOUR USE OF THE SERVICES, ANY SUBSCRIPTION OR PAYMENT, OR ANY RIGHT OF PRIVACY OR PUBLICITY, WILL BE RESOLVED BY BINDING, INDIVIDUAL ARBITRATION UNDER THE AMERICAN ARBITRATION ASSOCIATION’S RULES FOR ARBITRATION OF CONSUMER-RELATED DISPUTES. YOU AND WE EXPRESSLY WAIVE TRIAL BY JURY. DISCOVERY AND RIGHTS TO APPEAL IN ARBITRATION ARE GENERALLY MORE LIMITED THAN IN A LAWSUIT.

YOU ARE GIVING UP YOUR RIGHT TO PARTICIPATE AS A CLASS REPRESENTATIVE OR CLASS MEMBER ON ANY CLASS CLAIM YOU MAY HAVE AGAINST US, INCLUDING ANY RIGHT TO CLASS ARBITRATION OR ANY CONSOLIDATION OF INDIVIDUAL ARBITRATIONS.

You agree not to participate in claims brought in a private attorney general or representative capacity, or in consolidated claims involving another person’s account, where we are a party to the proceeding. This dispute-resolution provision is governed by the Federal Arbitration Act and not by any state law concerning arbitration.

If the American Arbitration Association is unwilling or unable to set a hearing date within one hundred and sixty (160) days of filing, either party may elect to have the arbitration administered by Judicial Arbitration and Mediation Services (JAMS). Judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction. Notwithstanding any provision of applicable law, the arbitrator may not award damages, remedies, or relief that conflict with this User Agreement.

20. Governing Law and Jurisdiction

This User Agreement is governed by and construed under the laws of the State of New York, including its conflicts-of-law rules, and the United States of America. You agree that any dispute arising from or relating to the subject matter of this User Agreement that is not subject to arbitration shall be brought exclusively in the state or federal courts located in New York County, New York, and you submit to the personal jurisdiction of those courts.

21. Modification

We reserve the right, in our sole discretion, to modify or replace any part of this User Agreement, or to change, suspend, or discontinue the Services — including the availability of any feature, database, publication, portfolio, or Content — at any time, by posting a notice on the Site or by sending you a notice through the Services, by e-mail, or by another appropriate means of electronic communication. We may also impose limits on certain features and services or restrict your access to parts or all of the Services without notice or liability. While we will endeavor to provide timely notice of material modifications, it is your responsibility to check this User Agreement periodically for changes. Your continued use of the Services after notification of any changes constitutes your acceptance of those changes.

22. Miscellaneous

22.1 Entire Agreement and Severability

This User Agreement, together with the Privacy Policy, the Disclaimers, and the DMCA Copyright Policy, constitutes the entire agreement between you and us concerning the Services and supersedes all prior or contemporaneous communications and proposals, whether oral, written, or electronic, between you and us concerning the Services. If any provision is found unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary so that this User Agreement otherwise remains in full force and effect. The failure of either party to exercise any right shall not be deemed a waiver of any further rights.

22.2 Force Majeure

We shall not be liable for any failure to perform our obligations where such failure results from any cause beyond our reasonable control, including mechanical, electronic, or communications failure or degradation; outages or policy changes affecting third-party platforms (including Substack, payment processors, data vendors, and hosting providers); war, civil unrest, pandemic, sanctions, or governmental action.

22.3 Assignment

This User Agreement is personal to you and is not assignable, transferable, or sublicensable by you except with our prior written consent. We may assign, transfer, or delegate any of our rights and obligations under this User Agreement without your consent.

22.4 Agency

No agency, partnership, joint venture, employment, advisory, or fiduciary relationship is created as a result of this User Agreement, and neither party has any authority of any kind to bind the other in any respect.

22.5 Notices

Unless otherwise specified, all notices under this User Agreement shall be in writing and shall be deemed given when received — if personally delivered or sent by certified or registered mail, return receipt requested; when receipt is electronically confirmed, if transmitted by e-mail; or the day after sending, if sent for next-day delivery by a recognized overnight delivery service. Electronic notices to us should be sent to: terms@billcara.com.

22.6 No Waiver

Our failure to enforce any part of this User Agreement shall not constitute a waiver of our right to later enforce that or any other part. Waiver of compliance in any particular instance does not mean we will waive compliance in the future. Any waiver, to be binding, must be provided in writing by an authorized representative.

22.7 Headings

Section and paragraph headings in this User Agreement are for convenience only and shall not affect interpretation.

Effective Date of this User Agreement: June 1, 2026.