Legal Disclaimer and Regulatory Disclosure Statement
1. Critical Notices – Read Before Using This Platform
NOT INVESTMENT ADVICE: Nothing on this platform or in any ArcStone Financial Pulse communication constitutes investment advice, a recommendation, a research report, or a solicitation to buy or sell any security. ArcStone Financial Pulse is a media and investor communications platform. You should not make any investment decision based on content published or distributed by ArcStone Financial Pulse without first consulting a qualified registered financial professional.
COMPENSATION DISCLOSURE – SECTION 17(b) / ISSUER-PAID CONTENT: ArcStone Financial Pulse receives, or may receive, direct or indirect compensation from issuers whose securities or businesses are described or featured in its communications. This is a material conflict of interest. All issuer-paid or compensated content will be identified as such. Under Section 17(b) of the U.S. Securities Act of 1933 and applicable Canadian securities laws, ArcStone Financial Pulse is required to disclose any compensation received or to be received in connection with the publication or distribution of promotional communications regarding a security. Compensated content should be read as promotional, not as independent research or analysis.
RISK WARNING: Many of the companies featured by ArcStone Financial Pulse are early-stage, micro-cap, or speculative in nature. There is a HIGH degree of risk in these securities. You may lose your ENTIRE investment. Investments in small-cap and micro-cap public companies are highly illiquid, subject to extreme price volatility, and may be unsuitable for most investors. Past performance is not indicative of future results.
2. About ArcStone Financial Pulse and the ArcStone Group
2.1 ArcStone Financial Pulse
ArcStone Financial Pulse is a digital investor communications and media platform ("AFP" or "the Platform") operated by ArcStone Securities and Investments Corp. ("ASIC"), a Delaware holding company. AFP specializes in distributing issuer-provided updates, corporate announcements, market-focused informational materials, and investor relations content to a broad audience including high net worth investors, family offices, alternative investment funds, institutional subscribers, and general market participants.
AFP is a media and communications platform, not a registered broker-dealer, investment dealer, investment adviser, portfolio manager, or securities research provider in any jurisdiction. AFP does not engage in any activity requiring registration or licensing as a dealer or adviser under U.S. or Canadian securities laws. AFP does not execute securities transactions, hold client funds or securities, or provide individualized investment recommendations.
2.2 ArcStone Group Structure – Regulatory Status
The ArcStone group of companies includes both regulated and non-regulated entities. The following is a summary of the regulatory status of key entities:
- ArcStone Securities and Investments Corp. (ASIC): Delaware holding company. Non-regulated. Operates ArcStone Financial Pulse as a media and IR platform.
- ArcStone Securities LLC: FINRA-registered broker-dealer, member FINRA and SIPC, CRD #306029. Conducts U.S. regulated securities activities including equity capital markets, private placements, and investment banking. ArcStone Securities LLC is a SEPARATE legal entity from ASIC and from AFP.
- ArcStone Canada Inc.: Canadian advisory and consulting entity. Subject to applicable Canadian provincial securities laws with respect to any registerable activities conducted in Canada.
- ArcStone Kingswood: A branded division of Kingswood US, a FINRA-registered broker-dealer separate from ArcStone Securities LLC.
- ArcStone US Corp.: U.S. advisory and consulting entity. Non-regulated.
- ArcStone Branding Inc.: Marketing and brand strategy entity. Non-regulated.
IMPORTANT CLARIFICATION: ArcStone Financial Pulse is operated by the holding company, ArcStone Securities and Investments Corp. ArcStone Financial Pulse is NOT operated by, and its content is NOT the responsibility of, ArcStone Securities LLC (the FINRA-registered broker-dealer). ArcStone Securities LLC and ArcStone Financial Pulse are separate entities with separate regulatory obligations. However, given that ArcStone Securities LLC may from time to time have investment banking or advisory relationships with companies featured by AFP, readers should be aware of this potential conflict of interest, which is disclosed in Section 5 of this Disclaimer.
3. No Investment Advice and No Offer of Securities
3.1 Not Investment Advice
All content published and distributed by or through AFP – including articles, newsletters, email communications, digital publications, social media posts, and website content – is for informational and promotional purposes ONLY. It does not constitute, and shall not be construed as:
• Investment advice or a recommendation within the meaning of the Investment Advisers Act of 1940 (U.S.), the Securities Act (Ontario), the Securities Act (British Columbia), or any other applicable securities legislation;
• A research report, analyst report, or research analysis within the meaning of FINRA Rule 2241 or NI 31-103;
• A solicitation of interest or an offer to sell or buy securities; or
• A prospectus, offering memorandum, or other offering document.
Readers should independently verify all information and consult a qualified registered financial adviser, broker-dealer, investment dealer, or portfolio manager before making any investment decision.
3.2 No Offer or Solicitation
Content distributed through AFP does not constitute an offer to sell or a solicitation of an offer to buy any securities in any jurisdiction. No securities shall be offered or sold in any jurisdiction except pursuant to an applicable exemption from the registration or qualification requirements of the securities laws of that jurisdiction, or where the offering has been duly registered or qualified.
In particular, no content on this Platform shall constitute an offer to sell or a solicitation of an offer to buy securities to or from any person in any province or territory of Canada, except pursuant to applicable exemptions under provincial or territorial securities legislation, or in the United States, except pursuant to applicable exemptions under the U.S. Securities Act of 1933, as amended, and the regulations promulgated thereunder.
3.3 Accredited Investors and Eligible Investors Only
Certain content distributed by AFP may relate to securities offerings that are available only to accredited investors (as defined under Regulation D under the U.S. Securities Act of 1933 and under National Instrument 45-106 in Canada) or eligible investors as defined under applicable provincial securities legislation. Where AFP distributes content related to such offerings, it does so on the basis that its distribution list has been screened or limited to persons who qualify, or that the recipient is responsible for determining their own eligibility before acting on such content.
4. United States – Regulatory Disclosure
4.1 Section 17(b) – Securities Act of 1933 – Compensation Disclosure
Section 17(b) of the U.S. Securities Act of 1933 makes it unlawful for any person to publish, give publicity to, or circulate any communication that describes a security for consideration received or to be received, directly or indirectly, without fully disclosing the receipt of such consideration and the amount thereof.
ArcStone Financial Pulse DISCLOSES that it has received, receives, or may in the future receive direct or indirect compensation from issuers in connection with the distribution of communications describing such issuers' securities or business activities. Such compensation may include:
- Cash compensation paid directly to ASIC or AFP in exchange for distribution services, investor relations communications, or promotional content placement;
- Securities compensation, including common shares, warrants, or other equity interests in issuers, which creates an additional financial interest in the success of those issuers;
- Indirect compensation paid through arrangements with third parties engaged by the issuer; and
- Compensation paid to ArcStone Securities LLC or other ArcStone affiliates in connection with investment banking or capital markets services provided to a featured issuer, creating a potential indirect benefit to the ArcStone group as a whole.
SPECIFIC COMPENSATION: The nature and amount of compensation received in connection with each featured issuer will be disclosed, to the extent required by applicable law, in each communication relating to that issuer. Where compensation has been received in securities (shares or warrants), the aggregate amount and nature of such compensation will be stated. Readers should treat any communication from AFP about an issuer as PROMOTIONAL in nature and independently verify all claims.
4.2 FINRA Rule 2210 – Communications with the Public
ArcStone Securities LLC, as a FINRA-registered broker-dealer, is subject to FINRA Rule 2210, which governs communications with the public. Where ArcStone Securities LLC is involved in a capital markets transaction or advisory mandate involving a company that is also featured by AFP, the content of any AFP communication relating to that company may be subject to FINRA Rule 2210 review and approval requirements applicable to ArcStone Securities LLC.
ArcStone Financial Pulse content itself, to the extent it is produced and distributed by ASIC (the holding company) rather than ArcStone Securities LLC, is not directly subject to FINRA Rule 2210. However, where AFP content relates to a company in connection with which ArcStone Securities LLC is providing regulated broker-dealer services, coordination between AFP and ArcStone Securities LLC's compliance department is maintained to help ensure consistency with applicable FINRA communications standards.
AFP content is NOT a FINRA-supervised communication and does not constitute a FINRA-approved research report. Readers should not treat AFP content as having been reviewed or approved by FINRA or any other regulatory authority.
4.3 Not a Registered Broker-Dealer or Investment Adviser (AFP)
ArcStone Financial Pulse is operated by ASIC, which is not a registered broker-dealer under the Securities Exchange Act of 1934 and is not a registered investment adviser under the Investment Advisers Act of 1940. AFP does not engage in activities requiring broker-dealer or investment adviser registration. All regulated U.S. broker-dealer activities within the ArcStone group are conducted exclusively through ArcStone Securities LLC (CRD #306029), which is a separate legal entity from ASIC.
4.4 FINRA Rule 2241 – Research Analyst Conflicts
AFP does not produce securities research within the meaning of FINRA Rule 2241 and is not subject to the research analyst conflict of interest rules applicable to FINRA member firms. AFP content is issuer-sourced promotional and informational material, not independent securities research. Readers should not treat AFP content as independent research or as a research analyst's opinion regarding the merits of any investment.
4.5 SEC Regulation FD
AFP may from time to time distribute corporate disclosure materials provided by publicly traded U.S. issuers. Where such materials include information that constitutes material non-public information (MNPI) regarding a publicly traded issuer, AFP is not the appropriate vehicle for initial disclosure of such information. AFP does not knowingly distribute MNPI that has not first been publicly disclosed by the issuer in compliance with Regulation FD (17 C.F.R. ss. 243.100). Any issuer that provides content to AFP for distribution represents that such content does not contain MNPI that has not been publicly disclosed.
4.6 Anti-Fraud Provisions – Sections 10(b) and 17(a)
All content distributed by AFP is subject to the anti-fraud provisions of U.S. securities law, including Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, and Section 17(a) of the Securities Act of 1933, which prohibit material misstatements and omissions in connection with the purchase or sale of securities, and fraudulent or deceptive practices in securities offerings. AFP endeavours to distribute only factual, issuer-supplied content and to include all material disclosures required by applicable law. However, AFP does not independently verify the accuracy of issuer-supplied content and is not responsible for misstatements made by issuers.
4.7 Forward-Looking Statements – U.S. Safe Harbor
Communications distributed by AFP may contain forward-looking statements within the meaning of Section 27A of the U.S. Securities Act of 1933 and Section 21E of the U.S. Securities Exchange Act of 1934. Forward-looking statements include, but are not limited to, statements regarding future revenues, earnings, financial condition, plans, prospects, and management objectives, and often include words such as "anticipates", "believes", "estimates", "expects", "intends", "plans", "projects", or similar expressions.
Forward-looking statements are based on current expectations and are subject to risks and uncertainties that could cause actual results to differ materially from those projected. These risks include, among others: general economic conditions; competition; regulatory changes; commodity prices; capital market conditions; and the ability of the issuer to execute on its business plan. Forward-looking statements speak only as of the date made and AFP assumes no obligation to update them. Investors should not place undue reliance on forward-looking statements.
5. Canada – Regulatory Disclosure
5.1 Overview – Canadian Securities Regulatory Framework
Securities regulation in Canada is administered at the provincial and territorial level. The Canadian Securities Administrators (CSA) is an umbrella organization of provincial and territorial securities regulators that coordinates regulatory initiatives and adopts harmonized National Instruments (NIs) applicable across most Canadian jurisdictions. AFP content distributed to Canadian recipients is subject to applicable provincial securities legislation and CSA National Instruments, including the rules described in this Section 5.
ArcStone Canada Inc. is the ArcStone group entity through which Canadian advisory and consulting activities are conducted. To the extent any ArcStone entity engages in activities requiring registration as a dealer or adviser in any Canadian province or territory, it will do so through ArcStone Canada Inc. or another appropriately registered or exempt entity. AFP itself does not carry on regulated dealer or adviser activities in Canada.
5.2 Ontario Securities Commission (OSC)
5.2.1 OSC Jurisdiction
The Ontario Securities Commission (OSC) is the securities regulatory authority for the Province of Ontario. AFP communications distributed to Ontario residents are subject to the Securities Act (Ontario), OSC Rules, and applicable CSA National Instruments as adopted in Ontario. The OSC has jurisdiction over communications that constitute advertising or promotional activity in connection with securities of reporting issuers or in connection with distributions exempt from the prospectus requirement.
5.2.2 Section 17(b) Equivalent – Promotional Communications (Ontario)
Under Ontario securities law, it is prohibited to engage in promotional activity regarding a security for compensation without adequate disclosure of that compensation. OSC Policy 57-602 and related guidance address the disclosure obligations applicable to promotional communications and investor relations activities. ArcStone Financial Pulse acknowledges and discloses that it receives compensation from issuers in connection with the promotional distribution of issuer content, as described in Section 4.1 of this Disclaimer. All issuer-compensated content distributed to Ontario recipients will include disclosure of compensation consistent with applicable OSC requirements.
5.2.3 NI 33-105 – Underwriting Conflicts
National Instrument 33-105 (Underwriting Conflicts) governs conflicts of interest in the context of underwriting and distribution of securities in Canada. Where ArcStone Canada Inc. or ArcStone Securities LLC has, or has had, an investment banking or underwriting relationship with an issuer whose securities are featured by AFP, this relationship constitutes a material conflict of interest that is required to be disclosed under NI 33-105. AFP will identify any such relationship in its content where applicable.
5.2.4 NI 51-102 – Continuous Disclosure
National Instrument 51-102 (Continuous Disclosure Obligations) governs the ongoing disclosure obligations of reporting issuers in Canada. AFP may distribute materials that constitute continuous disclosure documents provided by reporting issuers (e.g., news releases, financial statements, management discussion and analysis). AFP does not independently verify the accuracy or completeness of such documents. Readers are encouraged to review all continuous disclosure materials filed by an issuer on SEDAR+ (www.sedarplus.ca) before making any investment decision.
5.2.5 NI 31-103 – Registration Requirements and Exemptions
National Instrument 31-103 (Registration Requirements, Exemptions and Ongoing Registrant Obligations) sets out the registration requirements for dealers, advisers, and investment fund managers in Canada, as well as available exemptions. AFP does not act as a registered dealer or adviser in Ontario or any other Canadian province. AFP relies on applicable exemptions from the dealer and adviser registration requirements in connection with its media and communications activities. To the extent ArcStone Canada Inc. engages in any registerable activity in Ontario, it will do so in accordance with applicable OSC registration requirements or available exemptions.
5.2.6 OSC Staff Notice – Investor Relations and Social Media
The OSC has issued guidance regarding investor relations activities and social media communications in connection with securities. AFP acknowledges this guidance and endeavours to ensure that all AFP content distributed to Ontario recipients is factual, non-misleading, and includes all material disclosures required by applicable OSC rules and guidance, including compensation disclosure and risk warnings.
5.3 British Columbia Securities Commission (BCSC)
5.3.1 BCSC Jurisdiction
The British Columbia Securities Commission (BCSC) is the securities regulatory authority for the Province of British Columbia. AFP communications distributed to British Columbia residents are subject to the Securities Act (British Columbia), BCSC Rules and Orders, and applicable CSA National Instruments as adopted in British Columbia.
5.3.2 Promotional Communications and Compensation Disclosure (B.C.)
Section 50 and related provisions of the Securities Act (British Columbia) address prohibited representations and promotional activities in connection with securities. AFP discloses, consistent with applicable BCSC requirements, that it receives or may receive compensation from issuers in connection with communications distributed to B.C. residents, as described in Section 4.1 of this Disclaimer. Where AFP distributes issuer-compensated content to B.C. residents, such content will include a clear disclosure of the compensation arrangement.
5.3.3 BC Instrument 72-503 – Distribution of Securities Outside Canada
BC Instrument 72-503 addresses the offering of securities to British Columbia residents by issuers outside Canada. Where AFP distributes content relating to securities offerings by non-Canadian issuers to B.C. residents, AFP will include appropriate disclosure of the nature of the offering and applicable exemptions relied upon, consistent with BC Instrument 72-503 and related BCSC guidance.
5.3.4 BCSC Investor Relations Guidance
The BCSC has issued guidance regarding investor relations activities, promotional communications, and the conduct of persons who receive compensation for promoting securities. AFP complies with applicable BCSC guidance on investor relations activities and will include all required compensation and conflict disclosures in communications distributed to B.C. residents.
5.4 Other Canadian Provinces – Alberta (ASC), Quebec (AMF), and Others
AFP content may be distributed to residents of Canadian provinces and territories beyond Ontario and British Columbia, including Alberta (regulated by the Alberta Securities Commission, ASC), Quebec (regulated by the Autorite des marches financiers, AMF), and other provinces. All AFP content distributed to Canadian recipients across any province or territory is subject to applicable provincial securities legislation and CSA National Instruments. AFP applies the same compensation disclosure, conflict of interest disclosure, and risk warning standards to all Canadian recipients regardless of province.
Residents of any Canadian province who have questions about the applicability of provincial securities laws to AFP communications may consult their applicable provincial securities commission or a qualified securities lawyer.
5.5 Forward-Looking Statements – Canadian Safe Harbor (NI 51-102)
AFP communications may contain forward-looking statements within the meaning of applicable Canadian securities legislation, including NI 51-102. Forward-looking statements reflect AFP's or an issuer's current expectations and are subject to a number of risks and uncertainties. Material assumptions underlying such statements include, among others: general economic conditions in Canada and internationally; conditions in the securities markets; regulatory approvals; commodity prices (where applicable); and the ability of the issuer to execute on its business plan.
AFP and the relevant issuers caution that forward-looking statements involve known and unknown risks, and that actual results may differ materially from those expressed or implied by such statements. No forward-looking statement constitutes a guarantee of future performance. AFP assumes no obligation to update forward-looking statements contained in any communication except as required by applicable Canadian securities legislation.
5.6 CASL – Canada's Anti-Spam Legislation
AFP's electronic distribution of communications to Canadian recipients is subject to Canada's Anti-Spam Legislation (CASL, S.C. 2010, c. 23). AFP operates an email distribution program and sends commercial electronic messages (CEMs) to recipients who have provided express or implied consent in accordance with CASL. Specifically:
- AFP collects recipient consent on the basis of prior inbound communications (CASL s.10(1)(b) – implied consent arising from a prior business communication) or on the basis of express consent obtained through subscription or opt-in mechanisms;
- All AFP electronic communications include: (a) clear identification of AFP and ASIC as the sender; (b) a valid physical mailing address; and (c) a functional, one-click unsubscribe mechanism;
- Recipients who unsubscribe are removed from AFP's distribution list within 10 business days and are added to AFP's suppression list;
- AFP's email database is maintained for internal use only and is not shared, sold, or distributed to third parties; and
- AFP's full CASL Compliance Policy is available upon request from compliance@arcstoneglobalsecurities.com.
6. Conflicts of Interest
ArcStone Financial Pulse operates in an environment that involves multiple potential conflicts of interest. These conflicts are disclosed below and should be considered by all recipients of AFP content:
6.1 Issuer Compensation
As described in Section 4.1, AFP may receive cash or securities compensation from issuers in exchange for distribution services. This creates a direct financial incentive for AFP to publish content favourable to the issuer. All compensated content is intended to be identified as such, but readers should assume that any featured issuer may be a compensating issuer and treat the content accordingly.
6.2 ArcStone Investment Banking Relationships
ArcStone Securities LLC, an affiliated FINRA-registered broker-dealer, may have or have had investment banking, placement agent, or advisory relationships with companies featured by AFP. This creates an indirect conflict of interest: the ArcStone group as a whole may benefit financially from positive investor attention to a featured issuer if ArcStone Securities LLC is engaged in a capital markets mandate for that issuer. Where such a relationship exists, AFP will endeavour to disclose it in the relevant communication.
6.3 Securities Holdings
Directors, officers, employees, or contractors of ASIC, ArcStone Securities LLC, ArcStone Canada Inc., or other ArcStone affiliates may hold, directly or indirectly, securities of companies featured by AFP. These holdings create a personal financial interest in the success of the featured company. AFP discloses this general conflict and will include specific disclosure where known personal holdings are material.
6.4 Warrant and Equity Compensation
In addition to cash compensation, AFP or its affiliates may receive warrants or other equity interests in featured issuers as partial compensation for distribution services or investment banking services. Such equity interests create an ongoing financial stake in the featured issuer that may not be immediately apparent from the face of the communication. AFP discloses the existence of such arrangements in connection with the relevant issuer communications.
6.5 Simultaneous Distribution and Trading
AFP may distribute communications regarding a featured issuer at or around the same time that ArcStone Securities LLC or affiliated persons are participating in capital markets transactions involving that issuer's securities. This temporal proximity may affect the market price of the issuer's securities. Readers should be aware of this dynamic and factor it into their assessment of any featured content.
7. Investment Risk Warnings
7.1 General Risk Warning
Investing in securities involves a substantial degree of risk. The value of investments can go down as well as up, and investors may lose all or a substantial portion of their investment. Past performance is not indicative of future results. Returns on investment are not guaranteed.
7.2 Small-Cap and Micro-Cap Securities
Many of the companies featured by AFP are small-capitalization or micro-capitalization public companies, including companies listed on the TSX Venture Exchange (TSXV), the Canadian Securities Exchange (CSE), the OTC Markets (OTC Pink, OTCQB, OTCQX), and similar junior markets. Securities of small-cap and micro-cap companies carry significantly greater risks than securities of established, large-cap companies, including:
- Limited operating history, revenues, or proven business models;
- High susceptibility to market manipulation, "pump and dump" schemes, and speculative trading activity;
- Extreme price volatility and wide bid-ask spreads;
- Limited liquidity, meaning investors may be unable to sell their securities at desired times or prices;
- Concentration risk arising from small management teams, limited resources, and dependence on key personnel;
- Regulatory risk, including the risk of securities law violations, regulatory investigations, or exchange delisting; and
- Financing risk, including the risk that the company may be unable to raise capital needed to continue as a going concern.
7.3 Speculative Securities
AFP content may relate to companies that are exploration-stage, pre-revenue, or in early stages of development. Investment in such companies is highly speculative and involves a high risk of loss of the entire investment. These investments are suitable ONLY for investors who can bear the total loss of their investment and who have the sophistication to evaluate the specific risks involved.
7.4 Currency Risk
AFP features companies whose securities may be traded in Canadian dollars, U.S. dollars, or other currencies. Fluctuations in currency exchange rates may increase or decrease the value of investments as measured in an investor's home currency. Currency risk should be considered as part of any investment evaluation.
7.5 Liquidity Risk
Securities of the companies featured by AFP may be thinly traded or illiquid. There may be no active market for such securities, and investors may be unable to sell their securities in a timely manner or at a price that reflects the underlying value of the investment. Illiquid investments should be considered long-term commitments.
8. Regulatory Framework by Jurisdiction – Summary
The following table summarises the regulatory framework applicable to AFP content by jurisdiction:
|
Jurisdiction |
ArcStone
Entity / Status |
Key
Regulatory Framework |
|
United States |
ArcStone Securities LLC --
Member FINRA/SIPC, CRD #306029. ArcStone Financial Pulse is a non-registered
media/IR platform operated by ArcStone Securities and Investments Corp. |
Securities Act of 1933
(ss.17(b)); Securities Exchange Act of 1934; FINRA Rules 2010, 2210, 2241;
Investment Advisers Act of 1940 |
|
Canada -- Ontario |
ArcStone Canada Inc. --
registered/exempt as applicable under OSC jurisdiction. ArcStone Financial
Pulse content distributed to Ontario persons is subject to OSC oversight. |
Securities Act (Ontario);
OSC Rules 14-501, NI 51-102; NI 33-105; NI 31-103; OSC Policy 57-602 |
|
Canada -- British
Columbia |
ArcStone Canada Inc. --
subject to BCSC jurisdiction for distribution to B.C. residents. |
Securities Act (British
Columbia); BCSC Rules; NI 51-102; NI 33-105; NI 31-103; BC Instrument 72-503 |
|
Canada -- Alberta |
ArcStone Canada Inc. --
subject to ASC jurisdiction for distribution to Alberta residents. |
Securities Act (Alberta);
ASC Rules; NI 51-102; NI 33-105; NI 31-103 |
|
Canada -- Other
Provinces |
Subject to applicable
provincial securities legislation and CSA National Instruments as adopted in
each province. |
CSA National Instruments;
applicable provincial securities Acts |
|
Cross-Border |
Cross-border communications
involving U.S. and Canadian persons are subject to Regulation S, Regulation D
exemption frameworks, and applicable OSC/BCSC cross-border guidance. |
Regulation S; Regulation D;
CSA Staff Notices 31-352, 33-321 |
JURISDICTION WARNING: AFP content is not directed to, and should not be acted upon by, any person in any jurisdiction in which such action would be unlawful. Persons outside the United States and Canada who receive AFP communications should satisfy themselves that they are permitted to do so under applicable local laws before acting on any content. AFP makes no representation that its content complies with the laws of any jurisdiction outside the United States and Canada.
9. No Independent Verification of Issuer Content
All information distributed by AFP is sourced from materials provided by issuers, publicly available filings, or other sources believed to be reliable. AFP does not independently verify the accuracy, completeness, or fairness of issuer-supplied content. AFP is not responsible for any inaccuracies, misstatements, or material omissions in issuer-supplied materials. Readers are strongly encouraged to:
- Review all public filings made by featured issuers on SEDAR+ (www.sedarplus.ca) for Canadian issuers and EDGAR (www.sec.gov) for U.S. issuers;
- Conduct their own independent due diligence on any investment; and
- Consult a qualified, registered financial professional before making any investment decision.
The fact that AFP has featured or distributed information regarding a particular issuer does not constitute an endorsement of that issuer, its management, its business, or its securities by AFP, ASIC, ArcStone Securities LLC, or any other ArcStone entity.
10. Limitation of Liability and Disclaimer of Warranties
TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW:
- AFP MAKES NO REPRESENTATION OR WARRANTY, EXPRESS OR IMPLIED, REGARDING THE ACCURACY, COMPLETENESS, OR TIMELINESS OF ANY CONTENT ON THIS PLATFORM OR IN ANY AFP COMMUNICATION;
- AFP DISCLAIMS ALL LIABILITY FOR ANY LOSS OR DAMAGE, INCLUDING DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, ARISING OUT OF OR RELATING TO ANY RELIANCE ON AFP CONTENT OR ANY INVESTMENT DECISION MADE ON THE BASIS OF AFP CONTENT; AND
- AFP'S TOTAL LIABILITY FOR ANY CLAIM ARISING OUT OF OR RELATING TO THE CONTENT ON THIS PLATFORM SHALL NOT EXCEED THE AMOUNTS PAID BY THE CLAIMANT (IF ANY) TO ACCESS THIS PLATFORM.
The foregoing limitations apply whether the claim is based in contract, tort, negligence, strict liability, or any other legal theory, and even if AFP has been advised of the possibility of such damages.
11. Privacy and Data
ArcStone Financial Pulse collects personal information from subscribers and email recipients in accordance with its Privacy Policy, available at www.arcstonefinancialpulse.com/privacy-policy/. AFP's collection, use, and disclosure of personal information is governed by:
- The Personal Information Protection and Electronic Documents Act (PIPEDA) for Canadian recipients;
- Applicable U.S. state privacy laws for U.S. recipients; and
- CASL, with respect to the transmission of commercial electronic messages.
AFP does not sell, share, or disclose subscriber personal information to third parties for their own marketing or commercial purposes without subscriber consent, except as required by law.
12. Updates, Revisions, and Governing Version
This Legal Disclaimer and Regulatory Disclosure Statement will be reviewed and updated at least annually, and more frequently as warranted by changes in AFP's business, regulatory developments, or changes in the ArcStone group structure. The date at the top of this document indicates the effective date of the most current version.
In the event of any conflict between this Disclaimer and any specific disclosure contained in a particular AFP communication, the specific disclosure in the communication shall prevail to the extent of the conflict with respect to that communication.
Questions regarding this Disclaimer, compensation disclosure, regulatory compliance, or AFP's practices may be directed to:
ArcStone Financial Pulse / ArcStone Securities and Investments Corp.
Website: www.arcstonefinancialpulse.com
Compliance / Legal: compliance@arcstoneglobalsecurities.com
ArcStone Securities LLC (FINRA BD): brokercheck.finra.org | CRD #306029
SEDAR+ (Canadian issuer filings): www.sedarplus.ca
SEC EDGAR (U.S. issuer filings): www.sec.gov/edgar
OSC: www.osc.ca | BCSC: www.bcsc.bc.ca | CSA: www.securities-administrators.ca