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.
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.
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:
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.
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.
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:
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.
Users between thirteen and seventeen may remain entitled to additional protections under state law even where COPPA no longer applies.
Vervee may therefore require:
based upon applicable state law and product functionality.
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.
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:
Vervee will provide these rights where applicable law requires them.
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:
Recommended Vervee policy throughout the United States:
These commitments should apply nationally unless counsel approves a different use in a specific context.
Vervee should treat the following information as sensitive or heightened-risk information where applicable:
Collection should be avoided unless reasonably necessary.
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.
Vervee should avoid profiling children for commercial advertising purposes.
Any profiling used for adaptive learning should:
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.
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.
Vervee may maintain a United States State Privacy Addendum describing rights available to residents of jurisdictions including, where applicable:
and other states whose comprehensive privacy statutes become applicable.
The list must be reviewed and updated periodically as laws change.
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:
Vervee should not require users to waive rights that California law makes non-waivable.
Where Colorado law applies, Vervee should provide applicable rights relating to:
Where Connecticut law applies, Vervee should address applicable consumer privacy rights, sensitive-data processing, targeted advertising, sale, profiling, and protections applicable to minors.
Where Texas privacy law applies, Vervee should maintain appropriate disclosures and consumer rights concerning access, correction, deletion, portability, sale, targeted advertising, and sensitive data.
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.
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.
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:
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.
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.
Vervee should not rely exclusively upon consumer Terms for school programs.
Every school or district deployment should use an institutional agreement addressing:
Vervee will comply with applicable federal and state unfair-and-deceptive-practices laws.
Vervee should not make misleading claims concerning:
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:
Any future feature approaching these activities requires securities counsel review before launch.
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.
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.
Any national sweepstakes, contest, scholarship competition, prize promotion, or giveaway should have separate Official Rules reviewed for:
Vervee should apply a nationwide subscription standard that includes:
This approach should be used even where a particular state's statute is less demanding.
Vervee should not use interfaces that materially impair informed decision-making.
Examples to avoid include:
Heightened caution should apply 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.
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.
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.
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.
Any future outbound marketing calls require separate federal and state telemarketing review.
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.
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.
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.
Vervee may use reasonable age-screening or age-assurance measures to:
Any age-assurance provider must undergo privacy and security review.
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.
Recommended Vervee baseline for all known U.S. users under eighteen:
Vervee may determine a user's state using reasonably appropriate signals such as:
Vervee should not unnecessarily collect precise geolocation merely to determine state jurisdiction.
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:
The provision must not purport to impose an unenforceable waiver upon a minor.
Recommended language:
Recommended language:
*(County to be specified upon confirmation)*
Recommended language:
Vervee may retain the master liability provision using the greater of:
However, the provision must expressly exclude claims or liabilities that legally cannot be limited.
Counsel should assess whether different contractual caps should apply to:
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.
Nothing in Vervee's Terms should attempt to waive legally imposed duties concerning child privacy, child safety, statutory reporting, or prohibited harmful conduct.
Because state cybersecurity and breach-notification laws vary, Vervee should maintain a national incident-response program capable of identifying:
Vervee legal/security teams should maintain a confidential 50-state breach-notification matrix and update it at least annually or following material statutory change.
The Legal/Privacy function should monitor at minimum:
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:
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:
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:
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