Terms & Conditions

Vervee Academy — Financial Education & Trading Community Platform

United States Nationwide Legal Framework

Corporate Jurisdiction: Florida, United States  |  Service Territory: United States (All 50 States & District of Columbia)

This Addendum supplements the Vervee Academy Incorporated Terms of Use, Privacy Policy, Children's Privacy Notice, Parent/Guardian Terms, Community Guidelines, Financial Education Disclaimer, Subscription Terms, School Terms, and other applicable policies.

1. Florida Corporate Base

Vervee Academy Incorporated is incorporated in the State of Florida.

Except where applicable federal law or mandatory law of another jurisdiction requires otherwise, the Terms of Use and the relationship between Vervee Academy Incorporated and its users will be governed by the laws of the State of Florida, without regard to conflict-of-law principles.

2. United States-Wide Availability

Vervee Academy may make its Services available to users throughout the United States, including all fifty states and the District of Columbia.

The availability of Vervee in a particular jurisdiction does not mean that every feature will necessarily be available to every user.

Vervee may modify, restrict, disable, or condition features according to:

  • user age;
  • state of residence;
  • school or district requirements;
  • parental-consent requirements;
  • privacy requirements;
  • child-safety laws;
  • financial-services laws;
  • consumer-protection requirements;
  • app-store requirements; or
  • other applicable legal obligations.

3. Mandatory State Rights Are Preserved

Nothing in Vervee's Terms or policies is intended to eliminate, waive, restrict, or limit a statutory right that applicable federal or state law does not permit a consumer to waive.

If a provision of Vervee's Terms conflicts with a mandatory right under applicable law, that mandatory right will control solely to the extent of the conflict.

All remaining Terms will continue to apply.

4. No Contractual Avoidance of State Law

The designation of Florida law as governing law does not mean Vervee may disregard mandatory laws applicable to residents of another state.

Where required, Vervee will comply with applicable laws of the state in which an affected user resides.

5. Children and Teen Users

Vervee recognizes that state laws may provide protections beyond federal COPPA requirements.

Accordingly, Vervee may apply heightened protections to all known users under eighteen years of age, including:

  • privacy-protective defaults;
  • data minimization;
  • restricted profiling;
  • restricted advertising;
  • restrictions on sale or sharing of personal information;
  • limits on precise location use;
  • restrictions on direct messaging;
  • age-appropriate content;
  • parental controls;
  • parental consent where required;
  • simplified account deletion;
  • restrictions on addictive or manipulative design;
  • restricted notifications;
  • restricted recommendation systems; and
  • additional child-safety controls.

6. Under-13 Users

For children under thirteen years of age, Vervee will comply with the Children's Online Privacy Protection Act and applicable state laws.

Where required, Vervee will obtain verifiable parental consent before collecting, using, or disclosing personal information.

Vervee may provide only limited functionality before consent where legally permissible.

7. Users Age 13–17

Users between thirteen and seventeen may remain entitled to additional protections under state law even where COPPA no longer applies.

Vervee may therefore require:

  • parental consent;
  • parental account linkage;
  • restricted social functions;
  • restricted profiling;
  • restricted targeted advertising;
  • restricted sensitive-data processing;
  • default-private accounts;
  • restricted messaging;
  • additional age verification; or
  • other safety measures

based upon applicable state law and product functionality.

8. Florida Minor Users

For Florida residents, Vervee will evaluate and comply with applicable Florida requirements regarding children and online platforms.

Where Vervee constitutes a covered online platform under applicable law, Vervee will implement legally required safeguards concerning children's information and potentially harmful processing.

Where Vervee constitutes a covered social-media platform under applicable Florida law, additional age, parental-consent, account termination, and deletion requirements may apply.

Vervee will evaluate these obligations based upon the Services' actual functionality rather than solely upon how Vervee markets or describes the platform.

9. State Privacy Laws

Vervee will maintain a privacy program designed to address applicable United States state privacy laws.

Depending upon the jurisdiction and applicability thresholds, users may have rights concerning:

  • access;
  • confirmation of processing;
  • correction;
  • deletion;
  • portability;
  • obtaining copies of personal information;
  • opting out of sale;
  • opting out of targeted advertising;
  • opting out of certain profiling;
  • limiting use of sensitive personal information;
  • withdrawing consent;
  • appealing privacy decisions;
  • obtaining information about categories of data disclosed; and
  • authorized-agent requests.

Vervee will provide these rights where applicable law requires them.

10. Unified Privacy Rights Standard

To reduce unnecessary differences between states, Vervee may voluntarily provide certain privacy rights to United States users even where a particular state statute does not technically require those rights.

Providing a voluntary right does not constitute an admission that a particular statute applies to Vervee.

Recommended nationwide user rights include:

  • access;
  • correction;
  • deletion;
  • data copy;
  • account deletion;
  • parental access for eligible minor accounts;
  • opting out of marketing;
  • opting out of targeted advertising where offered; and
  • contacting Vervee regarding privacy concerns.

11. Children's Information — National Baseline

Recommended Vervee policy throughout the United States:

  • Vervee will not sell children's personal information.
  • Vervee will not use children's personal information for cross-context behavioral advertising.
  • Vervee will not intentionally disclose children's personal information to advertising networks for behavioral profiling.
  • Vervee will limit collection from children to information reasonably necessary for the educational service being provided.

These commitments should apply nationally unless counsel approves a different use in a specific context.

12. Sensitive Information

Vervee should treat the following information as sensitive or heightened-risk information where applicable:

  • precise geolocation;
  • Social Security numbers;
  • government identifiers;
  • account passwords;
  • financial-account credentials;
  • authentication information;
  • biometric identifiers;
  • racial or ethnic information;
  • religious information;
  • health information;
  • sexual-orientation information;
  • citizenship or immigration information;
  • children's information; and
  • other categories designated sensitive under applicable state law.

Collection should be avoided unless reasonably necessary.

13. Precise Geolocation

Recommended rule for minor accounts:

Do not collect precise geolocation unless a specific feature requires it, the collection has undergone legal/privacy review, and all required consent has been obtained.

Approximate location derived from IP may be used where reasonably necessary for security, compliance, localization, or jurisdiction identification.

14. Profiling of Minors

Vervee should avoid profiling children for commercial advertising purposes.

Any profiling used for adaptive learning should:

  • serve a legitimate educational purpose;
  • use the minimum information necessary;
  • be age appropriate;
  • include appropriate safeguards;
  • not create material financial, psychological, physical, or privacy harm; and
  • undergo privacy review.

15. Targeted Advertising

Recommended nationwide rule:

No targeted or cross-context behavioral advertising based on children's personal information.

For adult users, Vervee must provide any opt-out rights required by applicable state law.

16. Sale or Sharing of Data

Vervee should design its business model so that personal information, particularly student and minor data, is not sold.

If any advertising, analytics, data-sharing, or partnership arrangement could legally constitute a "sale," "sharing," or "targeted advertising" activity under a state statute, the arrangement must receive legal review before deployment.

17. State-Specific Privacy Addendum

Vervee may maintain a United States State Privacy Addendum describing rights available to residents of jurisdictions including, where applicable:

• California• Colorado• Connecticut• Delaware• Florida• Indiana• Iowa• Kentucky• Maryland• Minnesota• Montana• Nebraska• New Hampshire• New Jersey• Oregon• Rhode Island• Tennessee• Texas• Utah• Virginia

and other states whose comprehensive privacy statutes become applicable.

The list must be reviewed and updated periodically as laws change.

18. California

For California residents, where applicable, Vervee should address the California Consumer Privacy Act as amended by the California Privacy Rights Act.

Applicable notices should address:

  • categories of personal information collected;
  • sources;
  • business or commercial purposes;
  • disclosure categories;
  • retention;
  • access;
  • correction;
  • deletion;
  • portability;
  • sale/sharing opt-out;
  • sensitive information;
  • authorized agents;
  • nondiscrimination; and
  • rights applicable to minors.

Vervee should not require users to waive rights that California law makes non-waivable.

19. Colorado

Where Colorado law applies, Vervee should provide applicable rights relating to:

  • access;
  • correction;
  • deletion;
  • portability;
  • targeted advertising;
  • sale;
  • certain profiling;
  • sensitive-data consent; and
  • universal opt-out mechanisms where required.

20. Connecticut

Where Connecticut law applies, Vervee should address applicable consumer privacy rights, sensitive-data processing, targeted advertising, sale, profiling, and protections applicable to minors.

21. Texas

Where Texas privacy law applies, Vervee should maintain appropriate disclosures and consumer rights concerning access, correction, deletion, portability, sale, targeted advertising, and sensitive data.

22. Oregon

Where Oregon privacy law applies, Vervee should provide applicable rights and disclosures concerning processing, third-party disclosure, sensitive data, sale, targeted advertising, profiling, and consumer requests.

23. Other States

Vervee's privacy program must be reviewed periodically as additional state laws are enacted, amended, become effective, or receive regulatory interpretation.

The absence of a state from a public policy list does not mean Vervee may disregard applicable law.

24. Student Privacy

School deployments require a separate student-data compliance program.

Vervee should treat student information as educational data subject to contractual and statutory restrictions.

Vervee should not:

  • sell student information;
  • use school-provided student information for behavioral advertising;
  • build commercial advertising profiles from student information;
  • disclose education records for unrelated commercial purposes; or
  • retain school data longer than legally or contractually appropriate.

25. FERPA

Where Vervee receives information constituting education records subject to FERPA, the applicable school agreement should establish the lawful basis for Vervee's access.

If Vervee acts as a school official under FERPA, it must use education records only for purposes authorized by the school and remain subject to applicable use and redisclosure restrictions.

26. State Student-Privacy Laws

School deployment must account for state-specific student-data statutes in addition to FERPA and COPPA.

Each district contract should be reviewed for the district's jurisdiction.

Vervee should maintain a school-contract matrix identifying applicable state student-privacy requirements.

27. School Contracts

Vervee should not rely exclusively upon consumer Terms for school programs.

Every school or district deployment should use an institutional agreement addressing:

• Permitted purposes• Student information• FERPA & COPPA• State student-privacy laws• Security & Data ownership• Subprocessors & Deletion• Retention & Incidents• Parental & Teacher access• Administrator access• Intellectual property• Fees & Termination• Indemnification & Liability• Governing law

28. Consumer-Protection Laws

Vervee will comply with applicable federal and state unfair-and-deceptive-practices laws.

Vervee should not make misleading claims concerning:

  • educational outcomes;
  • investment outcomes;
  • guaranteed returns;
  • wealth or income;
  • credit improvement;
  • financial independence;
  • employment;
  • scholarships or admission;
  • endorsements or partnerships;
  • security or privacy; or
  • regulatory approval.

29. Financial Education vs. Financial Advice

Vervee will remain positioned as a financial-literacy and educational platform.

Product design should avoid turning generalized education into individualized regulated investment advice.

Accordingly, educational features should generally avoid:

  • telling a specific user which security to buy;
  • instructing a specific user to sell a security;
  • creating individualized securities portfolios presented as recommendations;
  • presenting trading alerts as personalized advice;
  • taking custody of investment assets;
  • executing trades;
  • representing Vervee as a broker;
  • representing Vervee as an investment adviser; or
  • accepting transaction-based compensation without legal review.

Any future feature approaching these activities requires securities counsel review before launch.

30. Cryptocurrency and Digital Assets

Any educational material discussing crypto, tokens, NFTs, decentralized finance, or similar digital assets should include heightened risk disclosures.

Vervee must not imply that such assets are safe, guaranteed, insured, or suitable for a particular user.

Minor accounts should not be directed to independently open real-world digital-asset accounts through Vervee educational content.

31. Gambling Distinction

Financial simulations and educational games must not unintentionally function as gambling.

Features involving real-money stakes, randomized prizes, entry fees, token redemption, chance-based rewards, or cash-equivalent virtual items require specialized legal review before launch.

32. Promotions, Contests and Sweepstakes

Any national sweepstakes, contest, scholarship competition, prize promotion, or giveaway should have separate Official Rules reviewed for:

  • eligibility and age;
  • state restrictions;
  • consideration;
  • skill versus chance;
  • prize value and taxes;
  • registration or bonding where applicable;
  • publicity rights;
  • parental consent;
  • alternate method of entry where applicable; and
  • prohibited jurisdictions.

33. Subscription Law — National Approach

Vervee should apply a nationwide subscription standard that includes:

  • clear price and billing interval;
  • automatic-renewal disclosure;
  • trial-conversion disclosure;
  • affirmative consent;
  • confirmation of subscription terms;
  • simple cancellation;
  • advance notice of material pricing changes where required; and
  • legally required reminders.

This approach should be used even where a particular state's statute is less demanding.

34. No Dark Patterns

Vervee should not use interfaces that materially impair informed decision-making.

Examples to avoid include:

  • misleading cancellation buttons;
  • hidden unsubscribe mechanisms;
  • confusing privacy settings;
  • automatically selected permissions;
  • guilt-based prompts directed at children;
  • deceptive countdown timers;
  • misleading scarcity; or
  • designs intended to pressure users to surrender privacy rights.

Heightened caution should apply to minors.

35. Marketing to Minors

Marketing to children should be age appropriate and must not exploit children's lack of experience.

Vervee should not encourage minors to conceal purchases from parents or pressure parents to make purchases.

36. Influencers and Testimonials

Paid relationships should be clearly disclosed.

Testimonials should represent genuine experiences and must not imply guaranteed outcomes.

Material connections between Vervee and endorsers should be disclosed as required by applicable advertising law.

37. Email Marketing

Commercial email must comply with applicable federal and state requirements.

Marketing messages should contain legally required identification and unsubscribe mechanisms.

Children's accounts should receive only age-appropriate communications.

38. Text Messaging

Promotional SMS, automated dialing, or automated marketing texts should be used only after legal review and obtaining legally sufficient consent.

Users should be able to revoke consent.

39. Telemarketing

Any future outbound marketing calls require separate federal and state telemarketing review.

40. Accessibility

Vervee should design its consumer and school products according to recognized digital-accessibility standards.

Recommended technical objective: WCAG 2.2 Level AA, where reasonably applicable.

Public-school deployments may create additional accessibility obligations.

41. Apple App Store

Vervee must independently comply with current Apple App Review Guidelines.

If Vervee enters the Kids Category, applicable child privacy, parental gate, third-party SDK, analytics, advertising, external-link, and purchase rules must be incorporated into the product.

42. Google Play

Vervee must accurately designate its target audience and comply with applicable Google Play Families requirements if children are within the target audience.

Only compliant SDKs and advertising arrangements should be used in child-accessible areas.

43. Age Assurance

Vervee may use reasonable age-screening or age-assurance measures to:

  • determine applicable experiences;
  • protect children;
  • obtain parental consent;
  • satisfy legal obligations;
  • restrict inappropriate features; and
  • provide jurisdiction-specific functionality.

Any age-assurance provider must undergo privacy and security review.

44. Minimum Data for Age Assurance

Age verification must not become an excuse to collect excessive personal information.

Vervee should select methods that minimize collection and retention.

Verification information should be deleted or deidentified when it is no longer reasonably necessary, subject to legal requirements.

45. National Minor Privacy Default

Recommended Vervee baseline for all known U.S. users under eighteen:

  • account private by default where social functionality exists;
  • no behavioral advertising;
  • no sale of personal information;
  • no public precise geolocation;
  • restricted direct messaging;
  • restricted adult-to-minor contact;
  • limited profiling;
  • limited notifications;
  • no unnecessary sensitive-data collection;
  • easy reporting;
  • easy blocking;
  • parental controls where applicable;
  • easy account deletion;
  • age-appropriate financial content; and
  • enhanced moderation.

46. Location-Aware Compliance

Vervee may determine a user's state using reasonably appropriate signals such as:

  • information provided by the user;
  • billing address;
  • school location;
  • parent address;
  • IP-derived approximate location; or
  • other lawful location signals.

Vervee should not unnecessarily collect precise geolocation merely to determine state jurisdiction.

47. Arbitration — Florida Base

Subject to final counsel approval, Vervee may use an arbitration provision governed by the Federal Arbitration Act for adult consumer disputes.

The arbitration provision should:

  • be conspicuous;
  • provide clear notice;
  • require affirmative assent;
  • identify the arbitration administrator;
  • explain costs;
  • preserve small-claims rights;
  • contain a reasonable informal-dispute process;
  • explain the class-action waiver;
  • provide any selected opt-out mechanism; and
  • state explicitly that mandatory statutory rights remain available.

The provision must not purport to impose an unenforceable waiver upon a minor.

48. Governing-Law Clause

Recommended language:

"These Terms and any dispute arising out of or relating to these Terms or the Services are governed by the laws of the State of Florida and applicable federal law, without regard to conflict-of-law principles, except that this choice of law will not deprive a consumer of protections provided by mandatory laws of the state in which the consumer resides that cannot lawfully be waived by contract."

49. Court Venue

Recommended language:

"For any dispute not subject to arbitration, the parties consent to jurisdiction in the state and federal courts located in the Florida county in which Vervee Academy Incorporated maintains its principal place of business, except where applicable law gives a consumer the non-waivable right to bring an action in another jurisdiction."

*(County to be specified upon confirmation)*

50. Consumer-Rights Savings Clause

Recommended language:

"Nothing in these Terms is intended to limit any right or remedy available to a consumer under applicable law that cannot legally be waived or limited. If any limitation, disclaimer, release, arbitration provision, indemnification obligation, governing-law provision, or other contractual term is unenforceable under applicable law, it will apply only to the maximum extent legally permitted."

51. Liability Cap

Vervee may retain the master liability provision using the greater of:

  • amounts paid by the claimant during the twelve months preceding the event giving rise to the claim; or
  • US $100.

However, the provision must expressly exclude claims or liabilities that legally cannot be limited.

Counsel should assess whether different contractual caps should apply to:

• Consumer users• Schools• Enterprise customers• Sponsors• Contributors• Commercial partners

52. Parental Indemnity

Do not rely upon a blanket statement making parents responsible for every act of a child.

Any parental indemnification provision should be limited to legally enforceable circumstances involving the adult's own conduct, representations, misuse, unlawful acts, or contractual breach.

53. No Waiver of Child-Safety Duties

Nothing in Vervee's Terms should attempt to waive legally imposed duties concerning child privacy, child safety, statutory reporting, or prohibited harmful conduct.

54. Security Compliance

Because state cybersecurity and breach-notification laws vary, Vervee should maintain a national incident-response program capable of identifying:

  • affected residents;
  • applicable state;
  • information categories;
  • encryption status;
  • dates and number of affected individuals;
  • notification deadlines;
  • regulator notice;
  • consumer reporting agency notice;
  • school notice;
  • parent notice; and
  • contractual notice.

55. Breach Response Matrix

Vervee legal/security teams should maintain a confidential 50-state breach-notification matrix and update it at least annually or following material statutory change.

56. State Law Monitoring

The Legal/Privacy function should monitor at minimum:

  • consumer privacy laws;
  • children's online safety laws;
  • student privacy laws;
  • data-breach laws;
  • automatic-renewal laws;
  • consumer protection;
  • biometric privacy;
  • AI regulation;
  • accessibility;
  • financial-services regulation;
  • advertising and sweepstakes;
  • social-media regulation; and
  • age-assurance laws.

57. Quarterly Compliance Review

Recommended internal process:

At least quarterly, review material legal changes affecting Vervee's United States operations.

A review should also occur before launching any materially new:

• AI feature• Social feature• Messaging feature• Investment education feature• Payment feature• Advertising system• Child-directed experience• School program• Marketplace• Competition• Data-sharing arrangement

58. Highest Reasonable Standard

Where implementing separate rules in multiple states would create unnecessary complexity, Vervee may elect to apply the highest practical protective standard nationwide.

Examples may include:

  • no sale of children's data;
  • no targeted advertising to minors;
  • deletion rights;
  • private-by-default minor profiles;
  • parental controls;
  • simple subscription cancellation;
  • data minimization;
  • privacy request mechanisms; and
  • accessible educational content.

59. No Representation of Universal Compliance

Vervee should not publicly state:

"100% compliant with every law"

"fully compliant in all 50 states"

unless counsel has specifically approved the claim.

Preferred wording:

"Vervee Academy maintains a compliance program designed to address applicable federal and state requirements."

60. Final National Savings Clause

Vervee Academy Incorporated intends these Terms and policies to operate consistently with applicable United States federal and state law. Nothing herein will be interpreted to waive, restrict, or eliminate a statutory right or legal protection that cannot lawfully be waived. Where applicable law provides greater protection than these Terms, that law will control to the extent required.

© 2026 Vervee Academy. All rights reserved.