Legal

1. Who publishes this

Frictionless Capital Research, including its articles, reports, newsletters, emails, the Frictionless podcast (episodes in audio and video, clips, transcripts, captions, show notes, and feeds, together the "Podcast"), videos, social posts, and other materials (together, the "Content"), is published by Frictionless Capital Management LLC ("FCM," "we," "us," or "our"), a Delaware limited liability company registered to do business in Florida. FCM manages Frictionless, a frontier venture fund, through private investment funds including Frictionless Fund I and Frictionless Fund II and their related vehicles (together, the "Frictionless Funds"). The Frictionless Funds are separate legal entities. The Content is written by FCM's authors, including Logan Jastremski and Diego Perez de Ayala (the "Authors"), who also host the Podcast (the "Hosts"), and by other contributors and guests. This page applies to all Content, free and paid.

2. No regulatory review

No regulator has reviewed, approved, or endorsed the Content, and nothing in the Content is a statement that FCM or any author has any particular skill, training, license, or regulatory status.

3. Information only; not advice

The Content is provided for general informational and educational purposes only. It is not, and must not be relied on as, investment, financial, trading, legal, tax, accounting, or other professional advice. It is not a recommendation or endorsement to buy, sell, or hold any security, token, or other asset, or to follow any strategy. Words like "bullish," "favorite," "opportunity," "undervalued," or "we like" are opinions about ideas, not instructions to act.

The Content is written for a general audience and does not consider your objectives, financial situation, risk tolerance, tax position, or needs. Before you make any financial decision, consult your own qualified advisers and do your own research.

4. Impersonal publication; no advisory relationship

The Content is the same for every reader at a given tier. It is published on a regular basis to the general public, is not timed to any trade or market event, and is not tailored to any person. FCM is not acting as your investment adviser, fiduciary, broker, or agent. No advisory, fiduciary, client, or other special relationship is created by reading, subscribing (free or paid), listening, commenting, replying, or contacting us. We do not give personalized advice, model portfolios, trade signals, or alerts. If you write to us we may read your message, but we will not advise you about your own investments, and any reply is general information only. A paid subscription buys access to published Content only.

5. Not an offer or solicitation; no reliance

The Content is not directed at any investor or prospective investor in any Frictionless Fund or other investment vehicle. It is not an offer to sell, or a solicitation of an offer to buy, any security, token, or interest in any Frictionless Fund or other investment vehicle, and it may not be used or relied on in evaluating the merits of any investment. Any offer of interests in a Frictionless Fund is made only through that fund's confidential offering documents, only to investors who qualify under them, and only where lawful. If anything in the Content conflicts with a fund's offering documents, the offering documents control.

You should not rely on the Content as the basis for any investment decision. Any decision you make is your own, at your own risk.

6. Our positions and conflicts of interest

FCM, the Frictionless Funds, the Authors, and our other principals, employees, and affiliates have invested, and may in the future invest, in companies, tokens, protocols, and other assets discussed in the Content. We may buy, sell, short, or otherwise transact in those assets at any time, including before, during, or after publication, and our positions may change without notice to you; we have no obligation to disclose any position or change. Our trading may affect prices. Our interests may differ from, and may conflict with, yours.

When we write about a company or project in which we or the Frictionless Funds hold an interest, or whose founders or investors have relationships with us, we have a financial incentive to describe it favorably and we benefit if its value rises. Portfolio companies and their founders may likewise have an incentive to say positive things about us.

Where we know at the time of publication that FCM, a Frictionless Fund, or an Author holds a position in an asset that a piece of Content discusses, we aim to say so in that piece. The absence of such a statement does not mean that we hold no position. Any list of investments we publish may be incomplete or out of date and is not a recommendation.

7. Sponsorship, compensation, and advertising

We do not accept payment from issuers to write about or discuss their securities or tokens without disclosing it. If we, an Author, or a Host receive money, tokens, equity, or anything else of value from a company, project, issuer, underwriter, or dealer in connection with Content that describes or promotes it or its security or token, we will say so, and say how much where the law requires, in that Content. Sponsored content, paid placements, and affiliate links will be labeled. For the Podcast, a sponsorship or paid promotion will be disclosed clearly in the episode itself (spoken, on screen, or both) at or before the sponsored segment, consistent with the FTC's Endorsement Guides (16 C.F.R. Part 255), and not only in the show notes. A Host, FCM, or a Frictionless Fund may also have a financial connection to a company discussed (for example, as an investor); we aim to disclose that too (Sections 6 and 12). A disclosure may be missing from an excerpt, clip, thumbnail, or a post made by someone other than us, and a missing disclosure does not mean that no connection exists. We have not reviewed third-party advertising and do not endorse it.

8. Opinions and forward-looking statements

Views in the Content are those of the individual author or speaker as of the date given, and are not necessarily the views of FCM, the Frictionless Funds, or their affiliates. Projections, estimates, forecasts, targets, and opinions are subjective, can change without notice, and may prove wrong. Statements about the future, including those using words such as "believe," "expect," "anticipate," "may," "will," "could," "should," "potential," "target," or "plan," involve risks and uncertainties and are not guarantees. Actual results may differ materially. Charts, graphs, and illustrations are for information only and should not be used to make any investment decision.

9. Risk, past performance, and digital assets

All investing involves risk, including the loss of your entire investment. Investments in early-stage and private companies are speculative and illiquid and may never return any money. Digital assets, where we discuss them, are highly volatile and can lose all of their value; they may be exposed to hacks, fraud, market manipulation, loss of keys or access, smart-contract or protocol failure, exchange or custodian failure, and changing law and regulation, and they may not be readily sellable. We make no statement about whether any token or digital asset is or is not a security, commodity, or other legally defined instrument, and nothing in the Content is a legal opinion.

Past performance, of any asset, company, strategy, prediction, or investment vehicle, does not indicate or guarantee future results. Examples, case studies, and past calls we discuss are selected for illustration, are not representative of all of our views or investments, and do not mean similar results will be achieved. The Content does not present the performance of any Frictionless Fund.

10. As-of date; no duty to update

The Content speaks only as of its publication date, or any earlier date it states. We have no obligation to update, correct, or supplement it, and we may not do so even if we learn it is inaccurate or out of date. Archived and older Content, including pieces first published elsewhere and republished here with their original dates, may no longer reflect our views or holdings.

11. Third-party information and data

Some Content relies on information from third parties, including public filings, data providers, companies, founders, guests, and media. We believe our sources to be reliable but have not independently verified their information, and we make no representation or warranty about its accuracy, completeness, or timeliness. Market data and prices may be delayed or wrong. Third-party statements may reflect the speaker's own interests. Links, quotations, and mentions are not endorsements. Trademarks and logos belong to their owners, and their use does not mean endorsement or affiliation.

12. The Frictionless podcast, video, clips, and guests

This Section applies to every episode, video, clip, short, transcript, caption, and show note of the Podcast, wherever it appears (our websites, YouTube, Spotify, Apple Podcasts, X, RSS feeds, and clips on social media), and to any live recording or event.

12.1 Episode disclaimer (as shown on screen and in show notes).

THE VIEWS EXPRESSED IN THIS EPISODE BY THE HOST AND THE GUEST ARE THEIR PERSONAL VIEWS AND DO NOT NECESSARILY REPRESENT THE VIEWS OF FRICTIONLESS CAPITAL, ITS FUNDS, OR ANY ORGANIZATION WITH WHICH THEY ARE ASSOCIATED. NOTHING IN THIS EPISODE IS, OR MAY BE CONSTRUED OR RELIED UPON AS, FINANCIAL, INVESTMENT, TECHNICAL, TAX, LEGAL, OR OTHER ADVICE, A RECOMMENDATION TO BUY OR SELL ANYTHING, OR AN OFFER OR SOLICITATION OF ANY INTEREST IN ANY FRICTIONLESS FUND. FRICTIONLESS CAPITAL, ITS FUNDS, AND ITS HOSTS MAY HOLD POSITIONS IN COMPANIES DISCUSSED, INCLUDING PORTFOLIO COMPANIES. A GUEST'S APPEARANCE IS NOT AN ENDORSEMENT. SEE RESEARCH.FRICTIONLESS.CAPITAL/DISCLAIMER.

12.2 Views. Hosts, guests, and other speakers speak for themselves. Their views are not necessarily the views of FCM, the Frictionless Funds, or any organization with which they are associated. This includes the Hosts, whose comments about companies, markets, and ideas are their own opinions and not recommendations. Live and unscripted remarks may be inaccurate or incomplete, and statements may be edited for length and clarity.

12.3 Guests. Guests are usually founders, engineers, and investors. A guest is not an employee, agent, or affiliate of FCM or any Frictionless Fund unless the episode says so. A guest's appearance is not an endorsement by FCM of the guest, their company, or any asset, product, or service, and is not a testimonial by the guest about FCM or any Frictionless Fund. A guest may hold positions in, be paid by, or have other financial interests in what they discuss, and may not disclose them. We do not verify what guests say.

12.4 Our positions. FCM, the Frictionless Funds, the Hosts, and their affiliates may hold positions in companies, tokens, and other assets discussed in an episode, including portfolio companies, and the guest's own company or its competitors, and may buy, sell, or change those positions at any time, including before, during, and after the episode, without notice. Where we know of a relationship that a listener would likely want to know about (for example, that the guest's company is a portfolio company), we aim to say so in the episode or show notes, but we have no obligation to, and the absence of a statement does not mean that no position or relationship exists.

12.5 No advice, no offer. Nothing in the Podcast is investment, financial, tax, legal, or other advice, a recommendation, or an offer to sell or a solicitation of an offer to buy any security, token, or interest in any Frictionless Fund (see Sections 3 to 5 and 18). The Hosts do not offer fund interests on the Podcast. If a Host or guest mentions a fund, a fund's strategy, or its investments, it is not an offer and not a statement of performance; any offer is made only through that fund's offering documents.

12.6 Forward-looking statements. Predictions, projections, and views about the future expressed in an episode are opinions, not guarantees, and may prove wrong (Section 8).

12.7 Clips and excerpts. A clip or short is an excerpt that may leave out context, caveats, and disclosures. This Disclaimer applies to every clip, whether or not the clip shows it. Clips that others make and share are not made or approved by us.

12.8 Sponsors. Sponsored episodes and segments are labeled (Section 7). Sponsors do not control our editorial content unless the episode says so.

12.9 Transcripts and captions. Transcripts, captions, summaries, and translations may be machine-generated and may contain errors. The audio or video is the primary record.

12.10 Platforms. The Podcast is distributed on third-party platforms that have their own terms, privacy policies, advertising, and comments. We do not control or endorse them, and the platform's own advertising is not our advertising.

13. AI-assisted content and beta features

Some Content, including summaries, transcripts, translations, images, data, and drafts, may be prepared with the help of artificial-intelligence tools. We aim to review it, but it may contain errors or omissions. Features labeled "beta," "preview," or "experimental" are provided as-is and may change or end at any time. This page applies to AI-assisted and beta Content in the same way as to all other Content.

14. Tax and legal matters

Nothing in the Content is tax or legal advice. Any discussion of tax or legal matters is general, may not apply to you, and cannot be used to avoid penalties. Consult your own tax and legal advisers.

15. Opinion, commentary, and corrections

Our analysis and commentary about companies, people, protocols, and markets is opinion based on the facts we state or link to, which we draw from public sources, documents, and the statements of the people we quote. It is not an assertion of undisclosed facts. If you believe a statement of fact in the Content is wrong, write to hello@frictionless.capital, identify the Content and the statement, and explain what is inaccurate and why. We will review it in good faith and correct a verified factual error where we decide a correction is warranted. A request for a correction is not a legal notice unless it also complies with the notice requirements that apply to claims about published statements, and nothing here waives any right or defense we have, including any notice or correction right under applicable law.

16. Where the Content is intended to be read

The Content is published from the United States and is intended for readers in the United States. It is not directed at, and is not a financial promotion, investment recommendation, or offer to, any person in any country where publishing it or making an offer would be unlawful or would require a filing, license, authorization, or approval that we do not hold. If you are outside the United States, you are responsible for complying with your local laws, and you should not treat the Content as a recommendation or promotion. Nothing in the Content is an offer of interests in any Frictionless Fund to persons in the United Kingdom, the European Economic Area, Switzerland, Canada, or any other jurisdiction except through that fund's offering documents and in compliance with local law.

17. Your use of the Content; Terms apply

Your use of the Content is also governed by our Terms of Service (research.frictionless.capital/terms), which set out, among other things, the limits on our liability, your acknowledgments and release, the time limit for claims, and how disputes are resolved (including individual binding arbitration). Those Terms apply to you if you have agreed to them. This page does not limit or expand them. Nothing on this page excludes any liability, or waives any right, that applicable law does not allow to be excluded or waived.

18. Legend for any Content that refers to a fund offering

This section applies to any Content, including any episode or clip of the Podcast, that refers to the offering of interests in a Frictionless Fund.

Interests in the Frictionless Funds are offered only by confidential private placement memorandum and related documents, which should be read in their entirety, and only to investors who meet the qualifications in them. In the United States, Frictionless Fund I and Frictionless Fund II offer interests under Rule 506(c) of Regulation D, which permits general solicitation only if every purchaser is an accredited investor and the fund takes reasonable steps to verify that status; each prospective investor must complete the fund's verification process before any interest is sold. The funds' documents may impose additional eligibility requirements, such as "qualified client" status. Outside the United States, interests are offered only to non-U.S. persons in offshore transactions under Regulation S, and only by separate documents. Interests in any vehicle that is offered privately without general solicitation (for example, a special purpose vehicle relying on Rule 506(b) or Section 4(a)(2)) are never offered through the Content, and nothing in the Content refers to any such offering. The interests have not been registered under the Securities Act of 1933 or any state securities law, and the funds are not registered as investment companies under the Investment Company Act of 1940. No regulator has approved or disapproved of the interests or passed on the accuracy or adequacy of any offering document. An investment in a Frictionless Fund is speculative and illiquid and involves a high degree of risk, including the loss of the entire investment. Past performance is not indicative of future results. Mentioning a fund is not a statement that interests are currently available. If anything in the Content differs from a fund's offering documents, the offering documents control.

19. Intellectual property

© 2026 Frictionless Capital Management LLC. All rights reserved. You may not reproduce, redistribute, forward, scrape, or resell Content (and in particular paid Content), rehost, re-upload, or monetize episodes or clips of the Podcast, or use it to train or ground any artificial-intelligence system, without our written permission, except for short quotations with attribution and a link, as described in our Terms of Service. We reserve all rights, including the right to opt out of text and data mining.

20. Changes and contact

We may update this page at any time; the "Last updated" date shows the current version, which applies to all Content, including Content published before the update. Questions or corrections: hello@frictionless.capital, or Frictionless Capital Management LLC, 1000 Brickell Ave, Ste 715, PMB 2237, Miami, FL 33131, USA.

Legend for fund results and portfolio marks

Where this website shows fund results, portfolio marks, or similar figures, this legend applies. It is not an offer to sell, or a solicitation of an offer to buy, any interest in any fund. Any offer is made only through the fund's confidential private placement memorandum and related documents, which control if they differ from what is shown. Figures are unaudited, preliminary, and provided by the investment manager; they may change and may differ from the figures in the fund administrator's statements, which control. Valuations of private and illiquid positions are estimates based on the manager's judgment and the information then available, may differ materially from the value ultimately realized, and may be adjusted without notice. Unless a figure is expressly labeled as net, treat it as gross: gross figures do not reflect fund-level fees, expenses, or carried interest, and the returns an investor actually receives will be lower. Figures for an individual investment are not the returns of the fund or of any investor and do not show how other investments performed. Past performance does not predict future results, and there is no assurance that a fund will achieve its objectives or avoid loss. Digital assets and early-stage investments are speculative and can lose all value. Statements about the future, including targets and expectations, are forward-looking, are not guarantees, and speak only as of the date they are published; we have no obligation to update them. Views are those of the investment manager as of the date of publication. This is not tax, legal, or investment advice. The manager and its principals have interests in the investments described and in other investments, and may buy or sell at any time. Nothing here waives any right you have under federal or state securities law.

1. Who we are and what these Terms cover

1.1. Frictionless Capital Research (the "Publication") is published by Frictionless Capital Management LLC, a Delaware limited liability company registered to do business in Florida ("FCM," "we," "us," or "our"). FCM manages Frictionless, a frontier venture fund, through private investment funds including Frictionless Fund I and Frictionless Fund II and their related vehicles (together, the "Frictionless Funds"). The Publication's authors include Logan Jastremski and Diego Perez de Ayala (the "Authors"), and other contributors may write for it.

1.2. These Terms of Service (the "Terms") are a binding agreement between you and FCM. They govern your use of the Publication, including the website at research.frictionless.capital, the newsletter signup on frictionless.capital, our emails and newsletters, articles, reports, the Frictionless podcast (including episodes in audio and video, clips, transcripts, captions, show notes, and feeds), videos, social posts, and any other content or service we offer under the Publication's name (together, the "Service," and everything published through it, the "Content").

1.3. "FCM Parties" means FCM, the Frictionless Funds and their general partners, managers, and affiliates, the Authors, and each of their respective members, managers, partners, principals, officers, employees, contributors, agents, licensors, successors, and assigns.

1.4. Our Disclaimer (research.frictionless.capital/disclaimer) and Privacy Policy (research.frictionless.capital/privacy) are part of these Terms for anyone who agrees to these Terms. If the Disclaimer and these Terms conflict, these Terms control on dispute-resolution, billing, liability, and ownership questions, and the Disclaimer controls on what the Content is and is not.

1.5. How you agree. You agree to these Terms when you do any of the following after we have shown you a notice that doing it means you agree to the Terms: (a) check a box or click a button (such as "Subscribe" or "Upgrade") next to a statement that you agree to the Terms; (b) create an account or log in; (c) buy a paid subscription; or (d) keep using the Service after we notify you of these Terms or of a change to them under Section 14. We keep a record of the date, time, Terms version, and method of each acceptance. If you receive our emails but have never agreed to these Terms, these Terms do not bind you until you do one of the things above. You will be asked to agree to them before you create an account or buy Premium. If you do not agree, do not use the Service.

1.6. The Podcast. The "Podcast" means the Frictionless podcast and any other audio or video show FCM publishes, and every episode, trailer, clip, short, transcript, caption, show note, thumbnail, and feed of it, wherever it appears: on our websites, on YouTube, Spotify, Apple Podcasts, and X, in feeds and podcast apps, and in clips on social media (each outside platform, a "Platform"). The Podcast is part of the Service and its recordings are part of the Content, so everything in these Terms that applies to the Service or the Content applies to the Podcast. The Podcast is hosted by Logan Jastremski and sometimes by Diego Perez de Ayala (the "Hosts"), who are Authors. People who appear on it as guests ("Guests") are usually founders, engineers, and investors.

1.7. Listening on a Platform. You can listen to or watch the Podcast on a Platform without accepting these Terms. If that is all you do, your use of the Platform is governed by the Platform's own terms, and your use of the Content is governed by copyright law and by any license we give in Section 8. These Terms bind you only if you agree to them under Section 1.5. Listening on a Platform does not by itself mean you agreed to the dispute-resolution terms in Sections 21 to 23.

2. Not investment advice; no advisory relationship

2.1. No regulator has reviewed, approved, or endorsed the Publication or any Content.

2.2. The Content is general, impersonal information and commentary published on the same terms to every reader at a given subscription tier, on a regular schedule, and not timed to any trade or market event. It is not investment, financial, trading, legal, tax, accounting, or other professional advice. It is not a recommendation to buy, sell, or hold any security, token, or other asset, and it does not take into account your objectives, financial situation, or needs.

2.3. Using the Service, including paying for a subscription, replying to an email, commenting, or contacting us, does not create an investment advisory, fiduciary, broker-dealer, client, or other special relationship between you and any FCM Party. FCM is not acting as your investment adviser, fiduciary, broker, or agent. We do not provide personalized advice, model portfolios, trade signals, or alerts, and we will not review your portfolio or tell you what to do with your own investments. Anything we say in a reply or comment is general information only. A paid subscription buys access to published Content only.

2.4. Not an offer. Nothing in the Service is an offer to sell, or a solicitation of an offer to buy, any security or any interest in a Frictionless Fund or other investment vehicle. Interests in the Frictionless Funds are offered only through each fund's confidential offering documents, only to investors who qualify under them, and only where lawful. Being a subscriber gives you no right to invest, no priority in any offering, and no access to non-public information about any fund.

2.5. Conflicts. FCM Parties may hold, buy, or sell positions in companies, tokens, and other assets discussed in the Content, at any time, including before and after publication. See the Disclaimer.

2.6. You are solely responsible for your own investment and other decisions and for confirming any information before relying on it. Consult your own qualified advisers.

2.7. The Podcast. Sections 2.1 to 2.6 apply in full to the Podcast. What Hosts and Guests say in an episode, a clip, or a transcript is conversation and opinion, is often unscripted, and is not advice, a recommendation, or an offer. The views of a Host or Guest are that person's own and are not necessarily the views of FCM or of any organization with which that person is associated. Guests are not employees, agents, or affiliates of FCM unless the episode says so, and a Guest's appearance is not an endorsement by FCM of the Guest, the Guest's company, or any asset, product, or service, or an endorsement by the Guest of FCM or any Frictionless Fund. No part of the Podcast is an offer to sell, or a solicitation of an offer to buy, any interest in any Frictionless Fund, and the Hosts will not offer fund interests on it.

3. Eligibility

3.1. You must be at least 18 years old (or the age of majority where you live, if higher) and able to form a binding contract to use the Service. The Service is not directed to children, and we do not knowingly collect information from anyone under 18. If you subscribe for an organization, you confirm you have authority to bind it, and "you" includes the organization.

3.2. You may not use the Service if you are (a) located in, ordinarily resident in, or organized under the laws of any country or region subject to comprehensive U.S. sanctions, or (b) on, or owned or controlled by someone on, any U.S., U.N., U.K., or E.U. sanctions or restricted-party list, including the U.S. Treasury Department's Specially Designated Nationals list. You represent that neither applies to you. You will not export or re-export Content in violation of U.S. export-control or sanctions laws.

3.3. The Service is published from the United States for readers in the United States. You are responsible for making sure your use of the Service is lawful where you live. We may restrict or refuse access or sales in any location, including by blocking payments from some countries.

4. Your account

4.1. You may need an account (for example, an email address with a one-time code or link) to access some Content. Give us accurate information and keep it up to date.

4.2. You are responsible for all activity under your account and for keeping your login, email account, and any codes or links secure. Tell us promptly at hello@frictionless.capital if you think your account has been misused.

4.3. One subscription, one person. Each subscription is for one named individual. You may not share your login, codes, or access links, or let anyone else use your account. Group or team subscriptions are available only if we offer them at checkout, and then only for the number of named people purchased.

4.4. We may use reasonable technical measures to detect and deter sharing and redistribution of paid Content. These include unique identifiers or tracking links in emails and posts, device and IP checks, and limits on simultaneous sessions. You consent to this. If we reasonably believe an account is being shared, we may suspend it, require you to verify your identity, or end it under Section 15.

5. Free and paid subscriptions

5.1. Free tier. Some Content is available free. By subscribing to the free tier you ask us to send you the Publication's emails. You can unsubscribe at any time using the link in any email.

5.2. Premium. Our paid tier ("Premium") gives you access to the Content we designate as paid, for as long as your subscription is active. It costs US$30 per month (the "Monthly Plan") or US$300 per year (the "Annual Plan"), plus any applicable taxes. The price, billing period, and renewal terms shown at checkout when you subscribe are the ones that apply to you.

5.3. What Premium is not. Premium is a subscription to general published content only. It is not a subscription to investment advice, alerts, trade signals, model portfolios, or any personal service, and it is not an investment in or a relationship with any Frictionless Fund.

5.4. What Premium includes may change. We decide what Content is paid or free, how often we publish, and what topics we cover. We may add, change, or stop features or Content. We do not promise any particular number, length, or schedule of posts. If we make a change that materially reduces what Premium includes, we will tell you, and you may cancel (see Section 7). If we end Premium altogether, Section 7.6 applies.

6. Billing and automatic renewal

6.1. Automatic renewal disclosure. PREMIUM RENEWS AUTOMATICALLY. UNLESS YOU CANCEL, YOUR SUBSCRIPTION WILL RENEW AT THE END OF EACH BILLING PERIOD (EACH MONTH ON THE MONTHLY PLAN, OR EACH YEAR ON THE ANNUAL PLAN) AT THE PRICE THEN IN EFFECT (US$30 PER MONTH OR US$300 PER YEAR AT SIGN-UP), PLUS APPLICABLE TAXES, AND WE WILL CHARGE YOUR PAYMENT METHOD WITHOUT FURTHER ACTION BY YOU. YOU CAN CANCEL ONLINE AT ANY TIME (SECTION 7.1). The renewal period equals the billing period you chose.

6.2. Authorization and consent. Checkout shows the price and billing frequency of the plan you choose. By clicking the button to subscribe or upgrade (for example, "Subscribe" or "Upgrade") next to a notice that you agree to these Terms, you accept these Terms, including this Section 6 and the automatic-renewal terms. These Terms and the confirmation email we send you explain that the subscription renews automatically until canceled and how to cancel. By completing checkout you authorize us and our payment processor, Stripe, to charge your payment method at the start of the subscription and at the start of each renewal period until you cancel. We keep a record of your consent for at least three years, or one year after your subscription ends, whichever is longer.

6.3. Confirmation. After you subscribe, we will email you a confirmation, in a form you can keep, that includes the automatic-renewal terms, the cancellation policy, and how to cancel. Stripe may also send you a receipt.

6.4. Renewal reminders. If you are on the Annual Plan, we will email you a reminder that includes the product, the renewal date and price, that the subscription will renew unless you cancel, and a link and instructions to cancel. We will send it about 35 to 40 days before the renewal date, and in any case no fewer than 30 and no more than 45 days before it. We will send any other reminder or notice that the law requires.

6.5. Price changes. We may change the price of Premium. We will email you notice of a price change, with how to cancel, between 15 and 30 days before it applies to you. The new price applies from your next billing period after the notice. If you do not want to pay the new price, cancel before it takes effect. Continuing after the effective date is your agreement to the new price.

6.6. Payment method; failed payments. You must give us a valid payment method that you are authorized to use. If a payment fails, we or Stripe may retry it, and we may suspend or end your Premium access until payment succeeds. We may update your stored card details through your card network's account-updater service. You are responsible for any fees your bank charges.

6.7. Taxes. Prices do not include taxes unless we say so. We may collect sales, use, value-added, goods and services, or similar taxes where required.

6.8. Currency. We charge in U.S. dollars. Your bank may charge conversion or foreign-transaction fees.

6.9. Discounts, trials, and gifts. If we offer a discount, free trial, gift, or promotional price, the specific terms shown with that offer apply. Unless the offer says otherwise, when a trial or promotional period ends your subscription will renew at the regular price shown at checkout, and we will tell you this, and how to cancel, before it does. Gift subscriptions do not automatically renew unless the recipient chooses to start a paid subscription.

7. Cancellation, refunds, and chargebacks

7.1. How to cancel. You can cancel Premium at any time, online, in one step, without contacting anyone and without any retention steps that delay it, using the subscription settings in your account on research.frictionless.capital or the manage-subscription link in your confirmation email or receipt. You can also cancel by emailing hello@frictionless.capital from the email address on your account, and we will process the request promptly.

7.2. When cancellation takes effect. Cancellation stops future renewals and charges. You keep Premium access until the end of the billing period you have already paid for, after which your account moves to the free tier (unless you also unsubscribe).

7.3. Refunds. Except as stated in this Section 7 or required by law, payments are non-refundable, and we do not give refunds or credits for partial billing periods or unused time. We will refund (a) duplicate charges, (b) charges made after you validly canceled, and (c) charges we made in error, if you tell us within 60 days of the charge. We may give other refunds or credits at our discretion; doing so once does not oblige us to do so again.

7.4. Your legal rights. Some places give consumers a right to cancel within a period after purchase or other rights that cannot be waived. Nothing in these Terms limits those rights. If you are a consumer in the European Union or the United Kingdom, you may have a 14-day right to withdraw from a digital-content subscription. Because paid Content is available to you as soon as you subscribe, you ask us to start providing it right away, and, to the extent the law allows, that may end your right of withdrawal once access begins. If you are unsure of your rights, write to us before you subscribe.

7.5. Chargebacks. If you think a charge is wrong, contact us first at hello@frictionless.capital and give us a reasonable chance (at least 10 business days) to fix it. If you dispute a charge you authorized with your bank or card issuer instead, you agree that we may (a) suspend your account while the dispute is open, (b) give the card network, your bank, and Stripe records showing your agreement to these Terms, your consent to automatic renewal, your account activity, and your access to paid Content, and (c) recover from you any dispute or chargeback fee our payment processor charges us, to the extent the law allows. A chargeback that is later reversed in your favor does not waive our right to end your account if the charge was valid.

7.6. If we end your subscription. If we stop publishing paid Content or end your Premium subscription without cause, we will refund the unused part of any prepaid period on a pro-rata basis. If we end it because you broke these Terms, we do not have to give a refund.

8. Ownership and your license to use the Content

8.1. The Content, and the Publication's names, logos, and design, are owned by FCM or its licensors and are protected by copyright, trademark, and other laws. © 2026 Frictionless Capital Management LLC. All rights reserved.

8.2. Subject to these Terms, we give you a limited, personal, non-exclusive, non-transferable, non-sublicensable, revocable license to access and read, listen to, or view the Content for your own personal, non-commercial use, and, if you are a Premium subscriber, the paid Content while your subscription is active.

8.3. You may not, without our prior written permission:

• (a) copy, forward, share, republish, post, summarize in a way that substitutes for the original, sell, resell, rent, license, or distribute any paid Content, in whole or in part, including by forwarding paid emails or posting them in group chats, Slack, Discord, Telegram, forums, newsletters, or shared drives;
• (b) share your login, one-time codes, or access links;
• (c) remove or change any copyright, disclaimer, watermark, tracking identifier, or attribution notice;
• (d) scrape, crawl, or bulk-download the Service, or use bots, spiders, or other automated tools to access it, other than standard search-engine indexing of public pages that follows our robots.txt instructions;
• (e) use any Content, or any output derived from it, to train, fine-tune, test, benchmark, ground, or improve any artificial-intelligence or machine-learning model, or include it in a dataset, vector store, retrieval system, or similar tool, or use it for text and data mining. We expressly reserve all rights, including the right to opt out of text and data mining under Article 4(3) of EU Directive 2019/790 and similar laws;
• (f) use the Content to build or offer a competing product or service, or for any commercial research, trading, signals, or data service;
• (g) frame, mirror, or create derivative works of the Content; or
• (h) use our names, logos, or trademarks, or suggest that we endorse you.

8.4. Fair quotation. You may quote short excerpts of Content (for example, a few sentences) for commentary, criticism, or news reporting, if you credit "Frictionless Capital Research" and, where possible, link to the original. You may share links to our public pages. Nothing in these Terms limits fair use under copyright law.

8.5. Remedies for misuse. The restrictions in Section 8.3 protect the value of paid Content, and damage from breach is hard to measure. If you breach Section 8.3(a), (b), (d), (e), or (f), then in addition to our other remedies, including injunctive relief, our right to recover our profits and actual damages, and our rights under copyright law: (i) your license ends automatically and we may end your account without refund; and (ii) at our election, instead of proving actual damages, you will pay us US$300 (the Annual Plan price) for each person who received paid Content through your breach, which the parties agree is a reasonable estimate of the subscription revenue lost for each such person and not a penalty. This Section does not limit any remedy that cannot be limited by law.

8.6. We reserve all rights not expressly granted.

8.7. Podcast: what you may and may not do. The Podcast is free to listen to and watch, but it is not free to copy. In addition to Section 8.3, which applies to all Content, you may not, without our prior written permission: (a) download, rip, record, re-upload, rehost, mirror, or republish any episode, or a substantial part of one, on any other website, Platform, feed, app, or service, or add it to any RSS feed, playlist service, or aggregator we have not approved; (b) post compilations, "best-of" edits, re-edits, dubs, voice or face clones, or translations of the Podcast; (c) take clips beyond fair use, or post clips that remove the context needed to understand them, that remove or hide our name, watermark, or attribution, or that suggest that we or a Guest endorse you or anything you sell; (d) use the Podcast, its audio, video, transcripts, captions, or any Guest's or Host's voice or likeness to create synthetic voices, avatars, or "deepfakes," or to train or ground any AI or machine-learning model (Section 8.3(e) applies to all Podcast Content); (e) monetize any part of the Podcast, including by running advertising against it, selling it, or using it to promote any product, token, or service; or (f) republish a transcript, whether made by us or by a tool, other than a short quotation under Section 8.4. You may share links to the Podcast on any Platform, use a Platform's official share and embed functions, and post short clips for commentary, criticism, or news reporting that credit "Frictionless" and link to the full episode. Nothing in these Terms limits fair use under copyright law.

8.8. Guests and third-party material. Each Guest appears under our Guest Terms, which the Guest accepts by accepting the invitation, booking, or joining after being told of them in the booking confirmation, and which give FCM rights in the recording. Music, clips, images, and other third-party material in an episode are used under license or under fair use and belong to their owners; you have no right to copy them. The statements of a Guest or other speaker are theirs, not ours.

8.9. Availability and edits. We may edit, re-cut, caption, translate, add or remove sponsorship, correct, age-gate, unpublish, or delete any episode, clip, or feed at any time, and we do not promise that an episode will stay available, or stay in the same form, on any Platform. We may enforce our rights against infringing copies through the Platforms' takedown processes and under Section 10. The US$300 remedy in Section 8.5 applies only to paid Content; for the Podcast, our remedies are those in this Section 8, injunctive relief, our actual damages and profits, and our rights under copyright law.

9. Your submissions, comments, and feedback

9.1. If we enable comments, polls, replies, or other ways to submit material ("Submissions"), you are responsible for what you submit. Do not submit anything that is unlawful, defamatory, harassing, infringing, misleading, confidential, promotional, or that contains material non-public information, or any personal data of others without permission.

9.2. You keep ownership of your Submissions. You grant FCM a worldwide, royalty-free, perpetual, irrevocable, non-exclusive, transferable, sublicensable license to use, reproduce, edit, publish, and display your Submissions in connection with the Service and our business. You confirm that you have the rights needed to grant this license.

9.3. If you send us ideas, suggestions, or feedback, we may use them for any purpose without paying or crediting you.

9.4. We may remove any Submission at any time. We are not obliged to monitor Submissions and are not responsible for them.

9.5. Podcast submissions and comments. If you send a question, voicemail, call-in, audio or video clip, review, or comment for use on the Podcast, or tag or reply to us about it on a Platform, it is a Submission. You give FCM the license in Section 9.2, including the right to play, quote, edit, and show it on the Podcast and in clips, with your name or handle as you posted it, unless you ask us in writing not to use your name. A comment or review you post on a Platform is also governed by that Platform's terms, and we do not control what the Platform does with it. If you appear in an episode or recording in any other way (for example, at a live recording or event), you consent to being recorded and to our use of the recording, and we may ask you to sign a release first. Recording consent for Guests is also covered by the Guest Terms; recording laws differ by state and country, and we will tell you before we record you.

10. Copyright complaints (DMCA)

10.1. We respect intellectual property rights. If you believe that material on the Service infringes your copyright, send a notice to our designated agent containing the information required by 17 U.S.C. § 512(c)(3): your physical or electronic signature; identification of the copyrighted work; identification of the material and where it is on the Service; your contact details; a statement that you have a good-faith belief the use is not authorized by the owner, its agent, or the law; and a statement, under penalty of perjury, that the notice is accurate and that you are authorized to act for the owner. A person who knowingly misrepresents that material is infringing may be liable under 17 U.S.C. § 512(f).

10.2. Designated agent: Copyright Agent, Frictionless Capital Management LLC, 1000 Brickell Ave, Ste 715, PMB 2237, Miami, FL 33131, USA. Email: hello@frictionless.capital (subject: "DMCA Notice").

10.3. If your material was removed and you believe that was a mistake, you may send a counter-notice that meets 17 U.S.C. § 512(g)(3). We will end the accounts of subscribers who are repeat infringers in appropriate circumstances.

11. Acceptable use

You agree not to: (a) break any law or anyone's rights; (b) interfere with, overload, or try to gain unauthorized access to the Service or its systems; (c) probe, scan, or test the vulnerability of the Service, or get around any access control, paywall, watermark, or rate limit; (d) introduce malware; (e) impersonate anyone or misstate your affiliation; (f) use the Service to send spam or unsolicited messages; (g) use the Service or Content to manipulate any market, to front-run or trade ahead of other readers on the basis of non-public advance copies, or to misrepresent our Content or imply our endorsement; (h) misrepresent that our Content is advice you or anyone else has been given by us; or (i) help anyone else do any of these things.

12. Third-party services, links, and advertising

12.1. We use third-party providers to run the Service, including beehiiv (website, email delivery, subscriber management, and analytics) and Stripe (payment processing), and, for the Podcast, Riverside (recording and production), Google Workspace (email and documents), Vercel (website hosting), Storyblok (website content), and Affinity (contact management), and the Platforms described in Section 12.3. Your use of their services may also be governed by their own terms and privacy policies. We are not responsible for third-party services, their outages, or their handling of data under their own policies.

12.2. The Content may link to, mention, or include third-party websites, products, tokens, protocols, data, quotes, guests, or advertising. We do not control, review, or endorse them and are not responsible for them, and a link or mention is not a recommendation. Sponsored content, affiliate links, and paid placements, if any, will be labeled (Section 12.4).

12.3. Platforms. We publish the Podcast and clips through Platforms such as YouTube, Spotify, Apple Podcasts, and X, and may use others. A Platform is not our service provider in the same way beehiiv or Stripe is: its terms, privacy policy, advertising, recommendations, algorithms, comments, and availability are its own. We do not control and are not responsible for a Platform's outage, removal or demonetization of content, insertion of ads, analytics, handling of your data, or changes to its rules. Your use of a Platform is at your own risk and subject to its terms.

12.4. Sponsorship and paid promotion. If anyone pays FCM or a Host (in money, tokens, equity, or anything else of value) to feature, mention, or discuss them, or if a Host, FCM, or a Frictionless Fund has a financial or other material connection to a company, token, or product being discussed (for example, a position, an investment in the company or in the Guest's company, or a relationship with the Guest), we will disclose that, clearly and close to the discussion it relates to, in the episode itself (spoken or on screen) and not only in the show notes or a link, consistent with the FTC's Endorsement Guides (16 C.F.R. Part 255) and Section 17(b) of the Securities Act where it applies. A disclosure may be missing from an older or edited clip, from a Platform's thumbnail or summary, or from a post made by someone other than us, and a missing disclosure does not mean that no connection exists. Sponsors do not control our editorial content unless the episode says so.

13. Beta features and AI-assisted content

13.1. We may offer features, tools, or content labeled "beta," "preview," or "experimental." They are provided as-is, may change or end at any time, and may contain errors.

13.2. Some Content, including summaries, transcripts, captions, show notes, clip selection, translations, audio or video enhancement, images, data, and drafts, may be prepared with the help of artificial-intelligence tools. We aim to review it, but it may contain errors or omissions. These Terms and the Disclaimer apply to it exactly as they do to other Content.

14. Changes to the Service and to these Terms

14.1. We may change, suspend, or stop any part of the Service at any time. If we stop Premium, Section 7.6 applies.

14.2. We may update these Terms. We will post the updated Terms with a new "Last updated" date and version. If a change is material, we will give you at least 30 days' notice by email to the address on your account, and we will say how to cancel, before it applies to you, except where a faster change is required by law or to address security, fraud, or misuse. If you do not agree to a change, you may cancel before it takes effect and your existing paid period will not be changed. If you keep using the Service after the change takes effect, you accept the updated Terms.

14.3. No retroactive changes to dispute terms. A change to Sections 21 to 23 applies only to Disputes that arise after the change takes effect, and never to a Dispute of which a party gave written notice before then. If you do not accept a change to those Sections, you may reject it by canceling and telling us in writing within 30 days after our notice; the version of those Sections that you originally accepted will then continue to govern any Dispute arising before your cancellation took effect. We are bound by the same rule.

15. Suspension and termination

15.1. You may stop using the Service at any time, unsubscribe from emails, cancel Premium (Section 7), or ask us to delete your account.

15.2. We may suspend or end your access to all or part of the Service, with or without notice, if we reasonably believe you have broken these Terms, misused the Service, created legal or security risk, or if we are required to by law. If we end your access for breach, we do not have to refund any fees. We may also end the Service for anyone at any time for any other reason, in which case Section 7.6 applies to prepaid fees.

15.3. Survival. Sections 1, 2, 4.4, 6.2, 7.3 to 7.6, 8, 9, 10, 15, 16 to 25, and any other terms that by their nature should survive, survive termination or expiry of your subscription and your closing your account.

16. Your acknowledgments: no reliance, no advice, our positions

By using the Service, you acknowledge and agree that:

16.1. No advice; no advisory relationship. Section 2 is true, and you understand it. No advisory, fiduciary, broker, client, or other special relationship exists between you and any FCM Party, and none is created by your paying for a subscription, replying, commenting, or contacting us. No FCM Party owes you any duty of care in connection with your investment, trading, or other financial decisions.

16.2. No reliance. You will not rely, and you have not relied, on any Content as the basis for any investment, trading, or other financial decision. Any decision you make is made solely on your own judgment and independent investigation, and with your own advisers, and at your sole risk. You have not relied on any statement, promise, or representation by anyone that is not set out in these Terms.

16.3. Not an offer. The Content is not an offer to sell, or a solicitation of an offer to buy, any security, token, or interest in any Frictionless Fund or other vehicle. Any such offer is made only through the relevant offering documents, which alone govern.

16.4. Our positions may be held and may change without notice. FCM Parties may hold long, short, or other positions in, or have other financial interests in, companies, tokens, and other assets discussed in the Content. They may buy, sell, or change those positions at any time, including before, during, or after publication, without notice to you, and they may act in a way that is inconsistent with the Content. Where we know at publication that a position exists we aim to say so, but we have no obligation to disclose any position or change. Their interests may conflict with yours.

16.5. Opinion; forward-looking statements. Content expresses opinions and estimates as of its date. Projections, estimates, targets, forecasts, and other statements about the future involve risks and uncertainties, are not guarantees, and may turn out to be wrong. Actual results may differ materially. We have no duty to update or correct any Content, although we may do so.

16.6. Third-party data and speakers. Content may include or rely on information, data, prices, charts, and statements from third parties (including companies, founders, guests, data providers, and public sources). No FCM Party has independently verified that information or makes any representation about its accuracy, completeness, or timeliness, and the views of guests and other speakers are their own.

16.7. Risk. Investing, and especially investing in early-stage companies and digital assets, is speculative and can result in the loss of your entire investment. Past performance does not indicate future results.

16.8. The Disclaimer. You have read and accept the Disclaimer (research.frictionless.capital/disclaimer).

16.9. The Podcast. You understand that (a) Hosts and Guests speak informally and often without a script, and what they say may be wrong, incomplete, or out of date; (b) the views of each Host and Guest are their own and are not necessarily those of FCM; (c) Guests are not affiliated with FCM unless stated, and a Guest's appearance is not an endorsement; (d) the Hosts, FCM, the Frictionless Funds, and their affiliates may hold positions in companies and assets discussed, including portfolio companies and Guests' companies, and may change them without notice; (e) clips are excerpts that may leave out context, and the Disclaimer applies to them in full; and (f) nothing in the Podcast is advice, a recommendation, or an offer of any interest in a Frictionless Fund.

17. Assumption of risk and release

17.1. Assumption of risk. You use the Service and the Content at your own risk. You assume all risk of any loss arising from any decision you make, or do not make, after reading, hearing, or viewing any Content.

17.2. Release. To the fullest extent permitted by law, you release each FCM Party from all claims, demands, damages, losses, and liabilities, known or unknown, arising out of or relating to your reliance on any Content, or any investment, trading, or other decision you make, or do not make, in connection with any Content. This includes any claim that Content was inaccurate, incomplete, out of date, or not disclosed in time, that any FCM Party held, bought, or sold any asset, and claims based on any FCM Party's ordinary or gross negligence. This release is a complete defense to any claim it covers.

17.3. Unknown claims. To the fullest extent permitted by law, you waive the benefit of any law that would limit this release to claims known or suspected when you agree to it. This includes California Civil Code § 1542, to the extent it applies, which says: "A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party."

17.4. What this Section does not do. This Section 17 does not release (a) fraud, or intentional or willful misconduct, by an FCM Party, (b) any claim for a refund or for breach of our obligations about billing, cancellation, or privacy under these Terms, or (c) any claim, right, or remedy that applicable law does not allow to be released or waived in advance, including certain rights under federal and state securities laws and consumer-protection statutes. Section 19.5 explains how this works in practice.

18. Disclaimer of warranties

18.1. THE SERVICE AND ALL CONTENT ARE PROVIDED "AS IS," "AS AVAILABLE," AND "WITH ALL FAULTS," WITHOUT WARRANTIES OF ANY KIND. To the fullest extent permitted by law, the FCM Parties disclaim all warranties, representations, and conditions, whether express, implied, or statutory. This includes any warranty of accuracy, completeness, timeliness, reliability, availability, merchantability, satisfactory quality, fitness for a particular purpose, title, quiet enjoyment, and non-infringement, and any warranty arising from course of dealing or usage of trade.

18.2. Without limiting Section 18.1, no FCM Party warrants that the Content is correct, complete, or current, that the Service will be uninterrupted, timely, secure, or error-free, or that the Service is free of viruses or other harmful components. No advice or information, whether oral or written, that you get from any FCM Party creates any warranty not expressly stated in these Terms.

18.3. If the law does not allow a warranty to be disclaimed, that warranty lasts only as long as, and is limited to the extent, the law requires.

18.4. No FCM Party warrants that any episode, clip, or feed will be available, complete, accurate, or in any particular form, or that any Platform will carry it.

19. Limitation of liability

19.1. Excluded damages. TO THE FULLEST EXTENT PERMITTED BY LAW, NO FCM PARTY WILL BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY TRADING OR INVESTMENT LOSSES, LOST PROFITS, LOST REVENUE, LOST OPPORTUNITIES, DIMINUTION IN VALUE, LOST DATA, BUSINESS INTERRUPTION, OR LOSS OF GOODWILL. This applies to anything arising out of or relating to the Service, the Content, or these Terms, under any theory of liability, whether contract, tort (including negligence), strict liability, statute, or otherwise. It applies even if an FCM Party was advised of the possibility of those damages and even if they were foreseeable.

19.2. Cap. TO THE FULLEST EXTENT PERMITTED BY LAW, THE TOTAL AGGREGATE LIABILITY OF ALL FCM PARTIES TOGETHER, FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THE SERVICE, THE CONTENT, OR THESE TERMS, WILL NOT EXCEED THE GREATER OF (A) THE TOTAL AMOUNT YOU PAID FCM FOR THE SERVICE IN THE 12 MONTHS BEFORE THE EVENT GIVING RISE TO THE FIRST CLAIM, AND (B) US$100.

19.3. Basis of the bargain. These exclusions and limits are an essential part of the bargain between you and FCM, and are reflected in the price. Without them, FCM would not offer the Service at its current price, or at all. They apply even if any limited remedy fails of its essential purpose.

19.4. What these limits do not cover. Sections 17, 19.1, and 19.2 do not limit liability for (a) fraud, or intentional or willful misconduct, or (b) any liability that applicable law does not allow to be excluded or limited, such as actual damages, restitution, and attorneys' fees recoverable under a consumer-protection statute that cannot be waived, or rights under federal or state securities laws that cannot be waived in advance.

19.5. Statutory remedies; step-down. If a law applicable to a particular claim does not allow part of Section 17, 19.1, or 19.2 to be enforced against it, then that part does not apply to that claim, and the rest of those Sections, and the same Sections as to all other claims, remain fully in effect. Where the law allows a lower or narrower limit than the one stated, the lower or narrower limit applies instead of no limit at all. These limits are separate from the Arbitration Agreement in Section 23, and nothing in them restricts the arbitrator's power to award any remedy that a court could award on an individual claim.

20. Indemnity

20.1. To the fullest extent permitted by law, you will defend, indemnify, and hold harmless each FCM Party from and against all claims, demands, actions, and proceedings brought by a third party, and all related losses, liabilities, damages, judgments, settlements, fines, penalties, costs, and expenses (including reasonable attorneys' fees), to the extent they arise out of:

• (a) your breach of these Terms or of a representation in them;
• (b) your Submissions;
• (c) your copying, sharing, forwarding, or redistribution of Content, or your sharing of account access;
• (d) your use of Content in providing advice, products, or services to others, or any statement you make to others about the Content or about us;
• (e) your violation of any law or regulation; or
• (f) your violation of any third party's rights.

20.2. FCM may assume control of the defense and settlement of any matter covered by this Section 20, at your expense, and you will cooperate. You may not settle any such matter without FCM's prior written consent.

20.3. This Section 20 does not apply to the extent a court or arbitrator finally determines that the loss resulted from an FCM Party's own fraud or willful misconduct, and does not require you to pay any amount that the law does not allow a consumer to be required to pay.

21. Governing law and courts

21.1. Governing law. These Terms, the Service, and any Dispute (defined in Section 23.1) are governed by the laws of the State of Delaware, without regard to conflict-of-law rules that would apply another state's law, because FCM is organized in Delaware and the Terms are administered from there and from Florida. Section 23 (the Arbitration Agreement) is governed by the Federal Arbitration Act, 9 U.S.C. § 1 et seq. (the "FAA"), and federal arbitration law, and these Terms evidence a transaction involving interstate commerce. If a court decides that Delaware law cannot be applied to a particular claim, then Florida law (and federal law) applies to that claim instead, and every other part of these Terms continues to apply.

21.2. Mandatory local law. Nothing in these Terms removes any right that you have under a consumer-protection or other law of the place where you live that cannot be waived or displaced by a choice of law, and those laws apply only to the extent they are mandatory.

21.3. Courts. Where a proceeding is allowed in court under Section 23 (small claims, requests for interim relief, enforcement of an arbitration agreement or award, or a claim that must be decided by a court), it must be brought exclusively in the state or federal courts located in Miami-Dade County, Florida (or, for small claims, as Section 23.3 says), and you and FCM consent to their personal jurisdiction and venue and waive any objection based on inconvenient forum. This Section 21.3 chooses a court location only. It does not limit Section 23.4 (Delegation) and does not mean the parties agreed that a court, rather than the arbitrator, decides whether a Dispute is arbitrable.

22. Time limit for claims

22.1. TO THE FULLEST EXTENT PERMITTED BY LAW, ANY CLAIM BETWEEN YOU AND ANY FCM PARTY ARISING OUT OF OR RELATING TO THE SERVICE, THE CONTENT, OR THESE TERMS MUST BE STARTED, BY THE NOTICE OF DISPUTE IN SECTION 23.2 FOLLOWED BY A FILING UNDER SECTION 23, WITHIN ONE (1) YEAR AFTER THE CLAIM ACCRUED, OR IT IS PERMANENTLY BARRED. The time during which the informal resolution process in Section 23.2 is under way, up to 90 days, does not count toward the one year.

22.2. Step-down. If applicable law does not allow a one-year period for a particular claim, the shortest period that the law allows applies to that claim instead, and the claim is not otherwise affected. This Section is separate from Section 23 and does not apply to the extent it would shorten a period for a claim under a statute that does not permit that.

23. Dispute resolution: informal notice, small claims, and a separate Arbitration Agreement

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS. IT REQUIRES YOU AND FCM TO RESOLVE DISPUTES BY INDIVIDUAL BINDING ARBITRATION INSTEAD OF IN COURT, AND WAIVES CLASS ACTIONS AND JURY TRIALS. THERE IS NO OPT-OUT.

23.1. What this covers. "Dispute" means any dispute, claim, or controversy between you and any FCM Party, past, present, or future, arising out of or relating in any way to these Terms, the Service, the Content, any subscription or payment, any communication or marketing, or your relationship with FCM, whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory. It includes disputes about the validity or scope of this Section 23, except as Sections 23.4 and 23.7 say. Each FCM Party that is not a signatory to these Terms is an intended third-party beneficiary of this Section 23 and may enforce it.

23.2. Step 1: Notice of dispute and informal resolution. Before starting an arbitration or a small-claims case, the party with a Dispute must send the other a written notice of dispute. The notice must include the claimant's name and the email address on any account; a description of the Dispute and the facts behind it; and the specific relief sought and how it was calculated. It must be signed personally by the claimant (and by counsel, if represented). Send notices to FCM at hello@frictionless.capital with the subject "Notice of Dispute," and by mail to Frictionless Capital Management LLC, 1000 Brickell Ave, Ste 715, PMB 2237, Miami, FL 33131, USA; we will send notices to you at the email address on your account. For 60 days after the notice is received, the parties will try in good faith to resolve the Dispute and, if either party asks, will hold an individual telephone or video conference that the claimant attends personally. Completing this process, once per Dispute, is a condition to starting arbitration. An arbitration filed without completing it may be dismissed without prejudice or paused until it is completed, as the arbitrator decides, and the Section 22 time limit is paused for up to 90 days while it is under way. This Section does not prevent anyone from asking a court for interim relief under Section 23.8.

23.3. Small-claims option. Either party may bring an individual Dispute in small-claims court instead of arbitration, in Miami-Dade County, Florida, or in the county where you live, if the Dispute qualifies for that court and stays there on an individual basis. This is consistent with the AAA's small-claims rule (R-9 of the Consumer Arbitration Rules).

23.4. Step 2: Arbitration Agreement. Except for small-claims cases under Section 23.3 and the court proceedings allowed by Section 23.8, you and FCM agree that every Dispute will be resolved exclusively by final and binding arbitration on an individual basis, and not in a court. This Section 23 is a separate agreement to arbitrate (the "Arbitration Agreement") that is independent of the rest of these Terms and survives their termination. The arbitrator, and not any court or agency, has exclusive authority to decide all disputes about the interpretation, applicability, scope, enforceability, unconscionability, or formation of the Arbitration Agreement, including any claim that all or part of it is void or voidable and whether a Dispute is arbitrable (the "Delegation"). The Delegation does not apply to the matters that Section 23.7 reserves to a court. A challenge to the Delegation itself must be specific to it. A challenge to the rest of these Terms, or to the Terms as a whole, is for the arbitrator.

23.5. Administrator, rules, and seat. The arbitration will be administered by the American Arbitration Association ("AAA") under its Consumer Arbitration Rules in effect when the arbitration is filed (the "AAA Rules"), available at adr.org, as supplemented by this Section 23. If the AAA is unavailable or declines to administer the arbitration, it will be administered by JAMS under its Streamlined Arbitration Rules and Procedures and its Consumer Minimum Standards, and if neither is available, a court may appoint an arbitrator under 9 U.S.C. § 5. One arbitrator will decide each Dispute. The arbitrator will apply the law that governs under Section 21 and these Terms, including Sections 17 to 20 and 22, except that the arbitrator will not apply any part of them to the extent Section 19.5 says it does not apply, and will follow statutory rules of privilege and evidence. The seat (legal place) of arbitration is Miami-Dade County, Florida. Hearings will be held by video conference or telephone, or by written submission, as the AAA Rules provide, unless the arbitrator decides an in-person hearing is needed; any in-person hearing will be held in a location reasonably convenient to you, as the AAA Rules provide, or by agreement. Judgment on the award may be entered in any court of competent jurisdiction.

23.6. Fees and remedies. The AAA Rules and fee schedule in effect when the case is filed govern who pays what. At the time of these Terms, the AAA Consumer Fee Schedule caps your filing fee at US$225 and makes FCM responsible for the remaining administrative fees and the arbitrator's compensation, unless the arbitrator finds that a claim was filed for harassment or is patently frivolous. Each party bears its own attorneys' fees and costs except where applicable law or the AAA Rules allow an award of them. The arbitrator may award any remedy, individual relief, or outcome that a court could award on an individual claim, including statutory damages, attorneys' fees where a statute provides for them, and injunctive or declaratory relief, but only in favor of the individual party seeking relief and only to the extent needed to provide relief for that party's individual claim.

23.7. Class, collective, and representative waiver. TO THE FULLEST EXTENT PERMITTED BY LAW, YOU AND FCM EACH AGREE THAT ANY DISPUTE WILL BE RESOLVED ONLY ON AN INDIVIDUAL BASIS. NEITHER YOU NOR FCM MAY BRING, JOIN, OR PARTICIPATE IN A CLASS, COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE ACTION OR ARBITRATION, INCLUDING AS A PRIVATE ATTORNEY GENERAL, AND THE ARBITRATOR MAY NOT CONSOLIDATE OTHER PEOPLE'S CLAIMS OR AWARD RELIEF TO OR AGAINST ANYONE WHO IS NOT A PARTY.

• Only a court may decide whether this Section 23.7 is valid and enforceable or applies to a particular claim.
• If a request for public injunctive relief cannot lawfully be waived and must be heard, it will be severed and stayed until the individual arbitration has finished. It will then be decided only by a court under Section 21.3. The arbitrator's decisions on the individual claims will bind the parties to the extent the law allows.
• If a final, non-appealable judgment holds this Section 23.7 unenforceable as to a particular claim or remedy, only that claim or remedy will be severed and decided in court under Section 21.3, and all other claims remain in individual arbitration.

23.8. Court proceedings that are still allowed. Either party may go to court (a) for small claims under Section 23.3; (b) to compel arbitration, stay a court case in favor of arbitration, or confirm, vacate, or enforce an award; (c) to ask for temporary or preliminary injunctive relief to preserve the status quo, or to stop infringement or misuse of intellectual property, unauthorized scraping, unauthorized redistribution of paid Content, or unauthorized access to the Service, while an arbitration is pending or being started, without waiving the right to arbitrate everything else; and (d) for the matters Sections 23.7 and 23.9 reserve to a court. This Section applies equally to you and to FCM.

23.9. Mass filings. If 25 or more demands for arbitration that are substantially similar are filed against FCM or any FCM Party by or with the help of the same or coordinated counsel or organizations (a "Mass Filing"), then, in addition to the rest of this Section 23: (a) the AAA's Mass Arbitration Supplementary Rules (or the equivalent JAMS procedures) apply, and the administrator's process arbitrator will decide whether each claimant has met the conditions to filing, including Section 23.2; (b) each claimant must satisfy Section 23.2 individually, and must provide the individual facts and documents the AAA Rules require (including the email address on the claimant's account and proof of any payment claimed); (c) the administrator may group, stage, or sequence the cases and appoint arbitrators to groups of cases under the AAA's Mass Arbitration Supplementary Rules, provided that each claimant's claim is decided individually, on that claimant's own facts, and no ruling in one claimant's case binds a different claimant who did not agree to be bound; (d) the Section 22 time limit is paused for each claimant whose case has not yet been administered because of staging, from the date the claimant's demand was properly submitted until administration begins; and (e) the parties will take part in the global mediation that those rules provide for. A court may enforce this Section 23.9, including by enjoining the filing or prosecution of demands that do not comply with it. If any part of this Section 23.9 is held unenforceable, the Mass Filing proceeds under the administrator's own mass-arbitration rules, one case at a time, with the rest of this Section 23 in force.

23.10. Jury-trial waiver. TO THE FULLEST EXTENT PERMITTED BY LAW, YOU AND FCM EACH KNOWINGLY, VOLUNTARILY, AND INTENTIONALLY WAIVE ANY RIGHT TO A TRIAL BY JURY in any Dispute, and in any court proceeding permitted by this Section 23.

23.11. Changes. Section 14.3 governs changes to this Section 23.

23.12. Severability of the Arbitration Agreement. Except as Section 23.7 says, if any part of this Section 23 is found invalid or unenforceable, that part will be severed or narrowed to the minimum extent needed and the rest of this Section 23 will remain enforceable. No part of Sections 17 to 20 or 22 is a term of the Arbitration Agreement, and if any of them is held unenforceable that does not affect the Arbitration Agreement. This Section 23 survives termination of these Terms and of your use of the Service. If the Arbitration Agreement is found unenforceable in its entirety for a Dispute, that Dispute will be decided in court under Section 21.3, individually and without a jury to the extent the law allows.

24. Electronic communications and notices

24.1. You agree to receive agreements, notices, disclosures, receipts, and other communications from us electronically, including by email and by posting on the Service, and that these satisfy any legal requirement that they be in writing. You can withdraw this consent by emailing hello@frictionless.capital, but then we may have to end your account, because the Service is electronic. You can ask us for a paper copy of any notice at no charge. To access our notices you need an internet-connected device, a current browser, and an email account that can receive our messages. You confirm that you can open and keep them.

24.2. Notices to us must be sent to hello@frictionless.capital, with a copy for legal notices by mail to the address in Section 26. Notices of dispute must follow Section 23.2. Transactional and account emails (such as receipts, renewal, price-change, security, and legal notices) may be sent even if you have unsubscribed from the newsletter.

24.3. Our records of the Terms version you accepted, when and how you accepted it, your payments, and your use of the Service, kept in the ordinary course of business, are admissible and are evidence of those facts, and you agree not to object to them solely because they are in electronic form.

25. General

25.1. Entire agreement. These Terms, the Disclaimer, the Privacy Policy, and any terms shown to you at checkout are the entire agreement between you and FCM about the Service and replace any prior agreements or understandings about it. They do not change any separate agreement you have with a Frictionless Fund; if you are an investor in a fund, that fund's documents govern your investment.

25.2. Severability; step-down. If any provision of these Terms is found invalid or unenforceable as applied to a claim or person, then (a) it will be enforced to the maximum extent the law allows, as narrowed or limited to the least extent necessary, (b) it will not affect that provision's application to other claims or persons, and (c) the rest of these Terms remains in effect, except that Section 23.7 and Section 23.12 control for the Arbitration Agreement. The parties intend that a court or arbitrator reform any provision that would otherwise be unenforceable so that it is enforceable to the greatest extent the law allows.

25.3. No waiver. Our failure to enforce a provision is not a waiver, and a waiver is effective only if it is in writing and signed by us.

25.4. Assignment. You may not assign or transfer these Terms without our written consent. We may assign or transfer them, including to an affiliate or to any successor to the Publication, for example in a reorganization, merger, or sale. These Terms bind and benefit successors and permitted assigns.

25.5. Force majeure. We are not liable for any delay or failure caused by events beyond our reasonable control, including outages of our service providers or of the internet, power or telecommunications failures, cyberattacks, natural disasters, epidemic, war, terrorism, labor disputes, or government action.

25.6. No third-party beneficiaries. Except for the FCM Parties, who may enforce Sections 2 and 16 through 23, these Terms do not give rights to anyone else.

25.7. Relationship. Nothing in these Terms creates any partnership, joint venture, agency, employment, fiduciary, or advisory relationship.

25.8. Interpretation. Headings are for convenience only. "Including" means "including without limitation." These Terms will not be construed against us because we drafted them. If we translate these Terms, the English version controls to the extent permitted by law.

25.9. Equitable relief. A breach of Sections 8 or 11 would cause harm that money cannot fully repair, and we may seek injunctive relief for it under Section 23.8 without having to post a bond, to the extent the court allows.

26. Contact

Frictionless Capital Management LLC
1000 Brickell Ave, Ste 715, PMB 2237
Miami, FL 33131, USA
Email: hello@frictionless.capital

This page is the Terms of Service for Frictionless Capital Research. Separate terms from beehiiv (beehiiv.com/tou) and Stripe apply to your use of their services.

1. Who is responsible for your data

FCM is the "controller" (or "business") responsible for personal information processed through the Service, except where a provider acts as an independent controller under its own policy (see Section 6).

Frictionless Capital Management LLC
1000 Brickell Ave, Ste 715, PMB 2237
Miami, FL 33131, USA
Email: hello@frictionless.capital (subject: "Privacy")

FCM also manages private investment funds (the "Frictionless Funds"). If you are an investor or prospective investor in a Frictionless Fund, the privacy notice in that fund's documents governs information collected for that purpose. This Privacy Policy covers only the Publication.

2. Information we collect

2.1 Information you give us

• Subscription details: email address, and if you provide them, your name, company, role, and preferences.
• Paid subscription details: name, email, billing country and postal code, and payment details. Card details go directly to Stripe. We do not see or store your full card number. We receive limited information from Stripe, such as the last four digits, card brand, expiry date, transaction history, disputes, and subscription status.
• Communications: what you send us when you reply to an email, contact us, comment, take part in a survey or poll, or ask for support.
• Podcast guests and contributors: your name, email, phone, company, role, bio, headshot and logos, social handles, scheduling details, the audio and video recording of you, the transcript, and what you say in an episode (which is publicly published). We also keep records of how you were told about and agreed to our Guest Terms (such as the booking confirmation and calendar invitation, the time you booked and joined, and session logs including your IP address) and, where you give it, any conflict-of-interest or position disclosure.
• Podcast listener submissions: questions, voicemails, call-ins, comments, and reviews you send us or post to us, with the name or handle you used.
• Account and agreement records: when, how, and from what IP address and device type you subscribed, accepted our Terms (and which version), consented to automatic renewal, opted in, or opted out. We keep these records as proof of what you agreed to.

2.2 Information collected automatically
When you visit the website or open our emails, our providers automatically collect:

• Device and usage data: IP address, approximate location derived from IP (city or region, country), browser and device type, operating system, referring page, pages viewed, time and date of visits, and referral or campaign tags (UTM parameters).
• Email engagement data: whether an email was delivered, opened, or clicked, and which links were clicked. This uses tracking pixels and tracked links (see Section 7).
• Access-protection data: unique identifiers or personalized links in paid emails and posts, and access patterns such as the number of devices or locations using one account, which we use to detect and deter unauthorized sharing of paid Content.
• Podcast listening data: if you play or download an episode from our website or a feed we operate, our providers may log the request (IP address, device or app type, and time). Platform analytics are described in Section 2.4.
• Cookies and similar technologies (see Section 7).

2.3 What we do not collect
We do not knowingly collect sensitive personal information (such as government ID numbers, health data, or precise geolocation) through the Service. Please do not send it to us. We do not ourselves create voiceprints, face templates, or voice clones from Podcast recordings.

2.4 The Podcast: recording, platforms, and listeners

• Recording. Guests and Hosts are recorded on Riverside, a cloud recording and production service, which stores the audio and video and may produce transcripts and other outputs using automated tools. Local copies are kept on our devices and our editing tools. The recording is processed for production, editing, captioning, translation, and publication. Raw and unedited recordings are private; the published episode is public.
• Publication. We publish episodes and clips on our websites, and through YouTube (Google), Spotify, Apple Podcasts, X, and RSS. Anything said in a published episode, including your name, voice, face, and statements, is public, may be copied by others, and cannot be fully recalled once published. Platforms and search engines may keep copies.
• Platform analytics. YouTube, Spotify, and Apple Podcasts give us aggregate statistics about listening and viewing (for example, plays, watch time, geography at a country or city level, devices, apps, and audience demographics). We do not receive listeners' names or email addresses from them as part of those analytics. Each platform is an independent controller of its own users' data under its own privacy policy, and we do not control it. If you comment, subscribe publicly, tag us, or otherwise engage publicly, we can see your public profile and content.
• Listeners who are also subscribers. We do not match platform listening data to our subscriber list.

3. How we use information, and our legal bases

• Send the Publication: Deliver free and paid newsletters, posts, and podcast updates. Legal basis (EU/UK/Swiss law): Consent; legitimate interests.
• Provide paid subscriptions: Create your account, give access to paid Content, take payments, send receipts and renewal and price-change notices, handle cancellations and refunds. Legal basis (EU/UK/Swiss law): Performance of a contract; legal obligation.
• Communicate with you: Respond to your messages; send service, security, and legal notices. Legal basis (EU/UK/Swiss law): Contract; legitimate interests.
• Understand and improve the Service: Measure opens, clicks, and readership trends; decide what to write about; fix problems. Legal basis (EU/UK/Swiss law): Legitimate interests; consent where required for non-essential cookies and similar technologies.
• Protect the Service and our content: Prevent fraud, abuse, and unauthorized sharing or scraping of paid Content; enforce our Terms and intellectual property. Legal basis (EU/UK/Swiss law): Legitimate interests; legal obligation.
• Keep proof of agreements and comply with law: Records of Terms acceptance and automatic-renewal consent; tax and accounting records; responding to lawful requests; records of consents and opt-outs; establishing or defending legal claims. Legal basis (EU/UK/Swiss law): Legal obligation; legitimate interests.
• Produce and publish the Podcast: Schedule and record guests, edit, caption, and publish episodes and clips, keep records, answer listener questions. Legal basis (EU/UK/Swiss law): Contract (the Guest Terms); legitimate interests; consent where we ask for it.
• Business changes: Due diligence or transfer if the Publication is reorganized, merged, or sold. Legal basis (EU/UK/Swiss law): Legitimate interests.

We do not use subscriber information to offer or sell interests in the Frictionless Funds, and subscribing to the Publication does not make anyone a prospective fund investor in our records.

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. We do not build individual advertising profiles.

Where we rely on legitimate interests, our interest is in sharing our published work with people who have a real connection to our work, running a sustainable publication, protecting our content, and keeping the Service secure. We have weighed this against your interests and rights. Every email lets you unsubscribe with one click, and you can object at any time.

Where we rely on consent, you may withdraw it at any time. That does not affect processing that already took place.

4. How to stop our emails

You can unsubscribe at any time by clicking "unsubscribe" in any email or by writing to hello@frictionless.capital. We honor opt-outs promptly, and in all cases within 10 business days. We keep only the minimum record needed to make sure you are not contacted again.

5. How we share information

We share personal information only as follows:

• Service providers (processors) who handle data on our behalf under contract, including:
  • beehiiv, Inc. — website hosting, newsletter delivery, subscriber management, analytics, and subscriber login;
  • Stripe, Inc. and its affiliates — payment processing and fraud prevention (see Section 6);
  • Google LLC (Google Workspace) — email for replies and support, and document storage;
  • Vercel, Inc. — hosting for frictionless.capital and its newsletter signup form;
  • Storyblok — content management for the frictionless.capital website;
  • Affinity — contact management, for business contacts only;
  • Riverside (Riverside.fm) — Podcast recording, storage, and production, and any editing, transcription, captioning, or translation tools we use.
• Publishing platforms: YouTube (Google LLC), Spotify, Apple Podcasts, and X, where we publish the Podcast and clips. These platforms are not our processors for listener data; they are independent controllers of their users' data, and publishing on them makes the episode public.
• Professional advisers such as lawyers, accountants, auditors, insurers, and fund administrators, where needed, under duties of confidentiality.
• Payment networks and card issuers, to prove your agreement to our Terms and to automatic renewal, and to respond to a payment dispute you raise with your bank.
• Authorities and legal process: when we believe in good faith that disclosure is required by law, subpoena, or regulation, or needed to protect the rights, property, or safety of FCM, our readers, or others, to enforce our Terms or intellectual property, or to investigate fraud or security issues.
• Business transfers: to a buyer, successor, or affiliate in a reorganization, merger, sale, or transfer of the Publication, subject to this policy.
• With your consent or at your direction.

We may share aggregated or de-identified information (for example, total subscriber counts or open rates) that cannot reasonably identify you.

We do not sell personal information, we do not "share" it for cross-context behavioral advertising (as those terms are defined under California law), and we do not rent or give our list to advertisers or sponsors. If we run sponsored content in the future, sponsors will not receive your personal information unless you choose to give it to them.

6. Payment processing by Stripe

Payments are handled by Stripe. When you pay, you give your payment details directly to Stripe. Stripe uses them to process payments, prevent fraud, and meet its own legal obligations, and for some of those purposes Stripe acts as an independent controller under its own privacy policy (stripe.com/privacy). Payouts from subscriptions are paid through beehiiv and Stripe to FCM.

7. Cookies, tracking pixels, and analytics

7.1 Website. The research.frictionless.capital website is run by beehiiv and uses cookies and similar technologies that are:

• strictly necessary: to keep you logged in, remember your preferences, secure the site, and process subscriptions; and
• analytics: to count visits, understand traffic sources, and measure what is read.

If we add advertising or retargeting cookies or pixels, we will update this policy and ask for consent where required. Where the law requires consent for non-essential cookies (for example, in the EU and UK), we ask for it, and where we show a cookie notice you can change your choice there. You can also block or delete cookies in your browser; the site may not work properly without strictly necessary cookies. We treat a recognized Global Privacy Control (GPC) signal as a request to opt out of any sale or sharing where the law requires.

7.2 Emails. Our emails contain a small tracking pixel and tracked links, which tell us whether an email was opened and which links were clicked, together with device and approximate location data. We use this to measure readership, improve the Publication, protect paid Content, and keep our list healthy (for example, by removing addresses that never open our emails). You can limit this by turning off automatic image loading in your email client or by using a mail-privacy feature; links will still work. If you are in the EEA, the UK, or Switzerland and do not want us to track opens, tell us at hello@frictionless.capital and we will try to accommodate you.

7.3 frictionless.capital. The newsletter signup form on frictionless.capital sends your email address to beehiiv to subscribe you. The website is hosted by Vercel, which, like any host, processes request data such as IP addresses to deliver and secure the site, and its content is managed in Storyblok.

7.4 Podcast players and platform embeds. If our website embeds a player or video from YouTube, Spotify, Apple Podcasts, or X, that platform may set cookies or collect data when the player loads or plays, under its own policy. Platform links and share buttons work the same way.

8. International transfers

FCM is based in the United States, and our providers process data in the United States and other countries. If you are in the European Economic Area, the United Kingdom, Switzerland, or another country with data-transfer rules, your information will be transferred to and processed in countries that may not offer the same level of protection as your own. Where required, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses (with the UK Addendum or UK International Data Transfer Agreement where relevant), a recipient's certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions where applicable, or another lawful transfer basis. You can ask us for more information about these safeguards.

9. How long we keep information

• Subscriber data: while you are subscribed, and for up to 24 months after you unsubscribe or your account becomes inactive, after which we delete or de-identify it.
• Suppression list: if you unsubscribe or ask us to stop contacting you, we keep your email address and opt-out date on a suppression list for as long as we send email, so we do not contact you again. This is the one record we keep after a removal request, and we keep it because the law requires us to honor opt-outs.
• Paid subscription and payment records: for 7 years after the transaction, to meet tax, accounting, and legal obligations.
• Agreement and consent records (for example, Terms acceptance and automatic-renewal consent): for at least 3 years after the agreement, or 1 year after your subscription ends, whichever is longer, and longer if needed for a legal claim.
• Podcast recordings: published episodes and clips stay public indefinitely as part of our archive. Raw and unedited recordings and Riverside project files are kept for 3 years after publication, or until we delete them. Records of Guest assent to the Guest Terms (the booking confirmation, calendar invitation, and session logs) are kept for as long as the episode is published and for 6 years after, even if other raw files are deleted sooner.
• Correspondence: for up to 3 years, unless needed longer for a legal reason.
• Analytics data: as set by our providers, typically up to 26 months, or in aggregated form.

We may keep information longer where the law requires or where we need it to establish, exercise, or defend legal claims.

10. Security

We use reasonable administrative, technical, and organizational measures to protect personal information, including access controls and the use of providers with recognized security programs. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a data breach affects you, we will notify you and regulators where the law requires.

11. Your choices

• Unsubscribe: click "unsubscribe" in any email. We will still send transactional messages about a paid subscription (such as receipts, renewal, price-change, and security notices) while it is active.
• Cancel a paid subscription: see our Terms of Service, Section 7.
• Update your details: through your account on the website or by emailing us.
• Cookies: use the cookie banner or your browser settings.

12. Your rights

Depending on where you live, you may have some or all of these rights. We will honor reasonable requests from any subscriber where we can, even if the law does not require it.

12.1 EEA, UK, and Switzerland. You have the right to: access your personal data; correct it; delete it; restrict its processing; receive it in a portable format; object at any time to processing for direct marketing (which we will honor) and object to other processing based on legitimate interests; and withdraw consent at any time. You also have the right to complain to your local data-protection authority (for example, in the UK, the Information Commissioner's Office, ico.org.uk; in Switzerland, the Federal Data Protection and Information Commissioner). We would appreciate the chance to address your concern first.

12.2 California and other U.S. states. If a state privacy law applies to our processing of your information, you may have the right to: know what personal information we have collected about you, its categories, sources, purposes, and the categories of recipients; access a copy; correct inaccuracies; delete it; opt out of the sale or sharing of personal information and of targeted advertising (we do not do either); limit the use of sensitive personal information (we do not collect it); and not be discriminated against for exercising your rights. In the last 12 months we collected the categories described in Section 2 (identifiers, commercial information such as subscription and purchase history, internet or other electronic network activity, approximate geolocation, and inferences about content interests), from the sources in Sections 2 and 4, for the purposes in Section 3, and disclosed them for business purposes only to the categories of recipients in Section 5. California residents may also request information about disclosures for direct-marketing purposes under California Civil Code § 1798.83; we do not make such disclosures. You may use an authorized agent; we may ask for proof of the agent's authority. If we deny your request, you may appeal by replying to our decision; if we deny your appeal, you may contact your state attorney general.

12.3 Canada. You may withdraw your consent to our commercial electronic messages at any time and we will process your request within 10 business days. If you believe you did not consent, tell us, and we will remove you and look into how your address came to us. You may also ask to access or correct your personal information.

12.4 Other countries. If you live elsewhere (for example, Türkiye, the United Arab Emirates, Brazil, or Australia), you may have similar rights under local law, and you may contact us to exercise them.

12.5 How to make a request. Email hello@frictionless.capital with the subject line "Privacy request" from the email address you subscribed with, or write to us at the address in Section 1. We may need to verify your identity before acting. We will respond within the time the law requires (generally one month under GDPR, or 45 days under California law), and may extend that where the law allows. Requests are free unless they are manifestly unfounded or excessive.

12.6 Your rights and our Terms. Nothing in our Terms of Service, including its arbitration agreement and its limits on liability, limits any right you have under privacy law that cannot be waived, or your right to complain to a regulator.

12.7 Podcast appearances. If you appeared in an episode, you may ask us to correct a factual error or, in a particular case, to remove your appearance, by emailing hello@frictionless.capital. The Guest Terms (see Section 2.1) give us the right to publish the recording, so we are not obliged to remove an episode, and the law (including freedom-of-expression exceptions) may allow us to keep it. We will review requests in good faith, will honor any request that the law requires us to honor, and will not use your personal information in the recording for anything unrelated to publishing the Podcast. Removal from our own channels does not remove copies held by platforms or others, and you must ask those platforms separately.

13. Children

The Service (including the Podcast) is intended for adults aged 18 and over. It is not directed to children, and we do not knowingly collect personal information from anyone under 18 (or under 16 in the EU/UK). If you believe a child has given us personal information, contact us and we will delete it.

14. Third-party sites

The Service links to other websites, podcast platforms, and social networks (such as X, YouTube, Spotify, and Apple Podcasts). Their privacy practices are governed by their own policies, not this one.

15. Changes to this policy

We may update this policy. We will post the new version with an updated date and version number, and if the changes are material we will tell you by email or on the Service before they take effect. We will not use personal information we already hold for a materially new purpose without telling you first and, where the law requires, getting your consent. Where the law requires your consent to a change, we will ask for it.

16. Contact us

Questions, requests, or complaints about privacy:

Frictionless Capital Management LLC
1000 Brickell Ave, Ste 715, PMB 2237
Miami, FL 33131, USA
Email: hello@frictionless.capital (subject: "Privacy")

beehiiv's own privacy policy (beehiiv.com/privacy), which is linked automatically at the bottom of posts, describes how beehiiv handles data for its own purposes. This Privacy Policy describes how FCM, as the publisher, handles your information.

The short version (please read)

By accepting our invitation, booking a time, or joining a recording for the Frictionless podcast, after we have told you about these Terms in the booking confirmation, you agree to them. In plain words:

• We may record you and publish and use the recording, anywhere, forever, including your name, voice, face, bio, and company name and logo, in the podcast, clips, ads, and promotion.
• You are not paid, and you are not paying us. We are not obliged to publish.
• We control the edit. You cannot review or approve it, but we will not knowingly alter your words to say something you did not say.
• You promise not to share confidential or material non-public information, not to solicit investments, and to tell us about conflicts.
• We and our funds may hold positions in companies discussed, including yours. Your appearance is not an endorsement either way.
• You release us from claims about the recording and how we use it (except fraud and willful misconduct), and your remedy is money damages, not an order to take the episode down.
• If you do not agree, do not join. Tell us at hello@frictionless.capital and nothing will be recorded.

1. Who, what, and how you agree

1.1. These Guest Terms (the "Terms") are an agreement between Frictionless Capital Management LLC, a Delaware limited liability company registered to do business in Florida, 1000 Brickell Ave, Ste 715, PMB 2237, Miami, FL 33131 ("FCM," "we," "us"), and you, the person who appears or may appear on the Frictionless podcast (and any other show FCM publishes, together the "Podcast"). If you appear for, or give us the name of, a company you work for or own ("Your Company"), "you" includes Your Company where these Terms deal with its name, logo, or information.

1.2. You agree to these Terms by accepting the invitation, booking or confirming a time (for example through Calendly), or joining the recording link or room, or taking part in the recording, after we have given you notice of these Terms. The notice is a line in our booking confirmation and calendar invitation that says: "By joining, you agree to our Guest Terms" with a link to these Terms. You agree to them even if you have not signed anything. No signature is needed. If you have not seen that notice (for example, someone else booked for you), tell us before you join and we will send it; if you join and take part, you are treated as having agreed, and we may rely on the confirmation and invitation we sent as evidence of notice.

1.3. Consideration. In exchange for your appearance, we give you the audience and promotion of the Podcast, and we make the promises we make in these Terms (including Sections 4, 8, and 12.2).

1.4. If you do not agree, do not accept or join, or tell us before the recording starts, and we will not record. You can also stop at any time by telling us. What was recorded before you told us is covered by these Terms.

1.5. Authority; others. You promise that you are at least 18 years old, that you can accept these Terms (including for Your Company, if you use its name or logo), and that doing so does not break any agreement or any policy of your employer. If you bring anyone else into a recording (for example, a colleague on camera), you will tell them about these Terms before they join; each person who joins and continues is bound by them.

2. Recording and your consent to it

2.1. You consent to being recorded, in audio and video, by us and our tools and vendors (including Riverside), from when you join until the session ends, and to the Recording being used as these Terms allow. You understand that you are being recorded, and that some laws, including Florida's, require every person on a recorded call to consent. By accepting the invitation and joining after the notice in our booking confirmation, you give that consent, and you may withdraw it for the rest of a session at any time by telling us to stop recording.

2.2. If you are told or can see (for example, from a recording indicator on screen) that the session is being recorded, and you continue, that continuing is also your consent.

2.3. If you are in a place whose law requires something more for recording or for use of your recording (for example, a specific notice or consent), tell us before you join and we will deal with it before recording.

3. What you give us

3.1. Permission. You give FCM and its licensees, successors, and assigns an irrevocable, perpetual, worldwide, royalty-free, fully paid-up, transferable, and sublicensable license (non-exclusive, and, to the extent the law and your rights allow, exclusive) to record, edit, cut, reorder, caption, translate, summarize, transcribe, adapt, excerpt, reproduce, distribute, publicly perform, display, stream, sell, license, and otherwise use and monetize the recording and everything in it (the "Recording"), in all media now known or later developed, on any platform (including YouTube, Spotify, Apple Podcasts, X, RSS, our websites, and clips), and in advertising and promotion of the Podcast, FCM, and its business.

3.2. Name and likeness. You give the same rights in your name, voice, image, likeness, signature, biography, job title, social handles, and the name and logo of Your Company (your "Likeness") as they appear in the Recording and in materials made to promote the Podcast. This is your express consent, written and oral, for purposes of Fla. Stat. § 540.08 and similar laws. We will not use your Likeness to state or suggest that you endorse a product, token, or investment other than the Podcast itself, except as shown in the Recording or with your separate approval.

3.3. Ownership. To the extent you own any copyright or other right in the Recording, you assign it to FCM, and to the extent it cannot be assigned, the license in Section 3.1 applies. You waive any moral rights to the fullest extent the law allows. If any part of this Section is not effective without a signed writing, the license in Section 3.1 still applies as a non-exclusive license, and you agree that the manner of your agreement (Section 1.2) is your adoption of these Terms as a signed record to the fullest extent the law permits.

3.4. No compensation; no obligation. You are not paid for appearing and you are not paying for it. Neither of us owes the other a fee, royalty, or credit. We do not have to publish the Recording, publish it by a date, publish all of it, or keep it published. If you or Your Company have paid or been paid by anyone (including FCM or a host) in connection with an appearance, tell us before recording. A sponsorship will be set out in a separate written agreement and disclosed to the audience.

4. No editorial control

We have sole editorial and creative control over the Podcast and the Recording, including topics, questions, edits, titles, thumbnails, clips, captions, sponsor placement, and the order and context in which anything you say is used. You have no right to review, approve, or change the Recording. We may use machine tools (including AI-assisted transcription, translation, captioning, and clip selection), and they may make errors. We will not knowingly edit your words so that they say something you did not say.

5. Your statements and promises

You promise that:

• (a) You own, or have the right to say, everything you say on the Podcast, and it will not infringe anyone's rights or be unlawful.
• (b) You will not disclose material non-public information about any company or security, and no contract, employer policy, or law stops you from saying what you plan to say. Do not share anything confidential to you, Your Company, your employer, your investors, or anyone else unless you have permission to make it public.
• (c) You will not give personalized investment advice, solicit investments, or promote the purchase or sale of any security or token (including your own company's) on the Podcast, and will not ask listeners to invest. If Your Company is raising money, tell us before recording.
• (d) You will tell us before recording about any conflict: any position you or Your Company hold in an asset or company you may discuss, any payment or benefit received or promised for talking about it, and any relationship with FCM, its funds, or its portfolio companies. We may disclose what you tell us.
• (e) What you say about facts will be accurate to the best of your knowledge, and you will say when something is opinion.

6. What you acknowledge

• (a) FCM, its funds, the hosts, and their affiliates may hold positions in the companies, tokens, and assets discussed, including portfolio companies and Your Company, and may buy, sell, or change them at any time, without telling you or the audience.
• (b) You are not an employee, agent, or affiliate of FCM or any of its funds. Your appearance is not an endorsement of you or Your Company by FCM or any fund, or of FCM or any fund by you, and we may say so.
• (c) The Podcast is general information and commentary. It is not investment, tax, or legal advice, and it is not an offer of interests in any fund.
• (d) The Podcast is distributed on third-party platforms and may be copied, clipped, and shared by others whom we do not control. Once published, the Recording cannot be fully withdrawn.
• (e) We handle personal information about you as our Privacy Policy describes (research.frictionless.capital/privacy).

7. Release

To the fullest extent permitted by law, you release and agree not to sue FCM, the Frictionless funds and their managers, the hosts, and their respective members, partners, officers, employees, contractors, licensees, and platform distributors (the "Released Parties") for any claim arising from the recording, editing, publication, distribution, or promotion of the Recording or your Likeness as these Terms allow, including claims for defamation, false light, invasion of privacy, publicity, copyright, or breach of contract, and including claims arising from edits, cuts, context, titles, captions, thumbnails, clips, or the reaction of listeners. This does not cover our fraud or willful misconduct, or any right the law does not allow you to release in advance. You waive the benefit of any law (including California Civil Code § 1542) that would limit this release to claims you know about now.

8. Limited remedies

If we breach these Terms, your remedy is a claim for money damages. You will not seek to stop, take down, or change the Podcast, the Recording, or any use of it by injunction, rescission, or similar relief. The total liability of the Released Parties for all claims related to the Recording and these Terms is limited, to the fullest extent permitted by law, to US$100. If a court does not allow part of this Section, the rest of these Terms still applies, and the limit applies to the greatest extent allowed. We may, at our discretion and with no obligation, consider a good-faith request to correct a factual error or to remove your Likeness from future clips.

9. Indemnity

You will defend and reimburse the Released Parties for third-party claims, and the losses and reasonable legal fees from them, to the extent they arise from your breach of Section 5, including a statement of yours that infringes or defames a third party or discloses material non-public or confidential information. This does not apply to anything we add or change after recording.

10. Governing law and courts

10.1. These Terms are governed by the laws of the State of Delaware, without regard to conflict-of-law rules. If a court holds that Delaware law cannot be applied to a claim, Florida law applies to that claim, and the rest of these Terms is unaffected.

10.2. Any lawsuit about these Terms or the Recording must be brought only in the state or federal courts located in Miami-Dade County, Florida, and you and FCM consent to their jurisdiction and venue. EACH OF US WAIVES TRIAL BY JURY to the fullest extent permitted by law.

10.3. Any claim must be started within one year after it arises, to the fullest extent permitted by law (if one year is not allowed, the shortest period the law allows applies).

11. Our record of your agreement

We keep records of how we gave you notice and how you agreed, including the booking confirmation and calendar invitation and the notice line and link in them, the time you booked and joined, the version of these Terms in effect, and session logs (such as your IP address). We may use them as evidence that you received notice and agreed.

12. Changes; copies

12.1. The version of these Terms posted at the link in your booking confirmation on the day of your recording is the version that applies to that Recording. We may update the Terms for future recordings. A change does not apply to a recording already made.

12.2. We will send you a copy of these Terms and of any version that applied to your recording if you ask.

13. General

These Terms are the entire agreement about their subject (our website Terms of Service do not otherwise apply to you as a guest unless you have separately agreed to them). If a provision is not enforceable, it is narrowed to the minimum extent needed and the rest stays in force; if the one-year limit, the remedy limit, or the release is not enforceable as to a claim, it is limited to the greatest extent allowed, and nothing else is affected. Sections 3 to 13 survive. We may assign these Terms; you may not. Notices go to hello@frictionless.capital (for us) and to the email address you used with us (for you). Our contact is Frictionless Capital Management LLC, 1000 Brickell Ave, Ste 715, PMB 2237, Miami, FL 33131, USA.