Ian Cassel, LLC d/b/a MicroCapClub (“MicroCapClub,” “We”) provides an electronic publication to independent investors registered with MicroCapClub (“You,” “Your,” “Registrant”) containing MicroCapClub’s opinions on certain financial information, including, without limitation, information on securities and securities markets (“Information”). The Information is provided by MicroCapClub but may be based on information submitted by third party suppliers ( “Information Providers”). The Information is provided on this Web Site (the “Site”).

The Site is owned and presented by MicroCapClub as a service to the Registrants. Your use of the Site is expressly conditioned upon your acceptance of the Disclaimer, Terms of Use and Privacy Policy. By registering with us and by accessing the Site, you agree to be bound by, and accept, the Disclaimer, Terms of Use and Privacy Policy.

We reserve the right to refuse access to any Registrant who violates the law or the Disclaimer, Terms of Use or Privacy Policy.

MicroCapClub may modify, add or delete portions of the terms of this Disclaimer, Terms and Conditions and Privacy Policy from time to time in its sole discretion. We will post the changes on the Site. Your registration for the Information and continued receipt of Information from MicroCapClub constitutes acceptance of such modifications, which shall be effective immediately upon posting on the Site.

By subscribing to the Information, all Registrants agree and fully understand that the stock market, other securities markets, and all financial forums contain implicit and explicit risks. That being acknowledged, understood, and agreed, anyone who directly or indirectly uses the Site and/or Information shall hold MicroCapClub and any of its, members, officers, and affiliates harmles for any loss, injury, or damage resulting from the usage of the Site or any Information. All users of the Site, whether a Registrant or visitor, agree that they alone bear complete responsibility for their own investment research and investment decisions, and that they will not hold MicroCapClub or any of its affiliates liable for any decisions or outcomes from actions made by them or others based directly or indirectly upon the Information or any other material published by MicroCapClub.

DISCLAIMER

Investment Risk: MicroCapClub is not a registered investment advisor or broker-dealer, and is not licensed nor qualified to provide investment advice. In addition, there is no requirement that any of our Information Providers be registered investment advisors or broker-dealers and we do not represent or warrant that such Information Providers are registered investment advisors, broker-dealers or otherwise licensed or registered under applicable law. Nothing published by MicroCapClub should be considered personalized investment advice or investment services by MicroCapClub or the Information Providers. The Information is NOT a solicitation to BUY, SELL, or HOLD any securities mentioned, directly or indirectly, in the Information. Furthermore the Information should not be used as the basis for making any investment decision and you should consult your own independence financial investment advisor before making any such decision. Your own due diligence is of the utmost importance and highly recommended. Never buy stocks or other financial products based purely on the Information. Neither MicroCapClub nor any Information Provider guarantees any specific outcome or profit, as, among other things, the strategies or investments discussed may fluctuate in price or value and the investments or strategies mentioned on the Site or in the Information may not be suitable for you. This material does not take into account your particular investment objectives, financial situation or needs and is not intended as recommendations appropriate for you. You must make an independent decision regarding investments or strategies mentioned on the Site or the Information. Before acting on Information, you should consider whether it is suitable for your particular circumstances and seek advice from your own independent financial or investment advisor. YOU SHOULD VERIFY ALL CLAIMS, DO YOUR OWN DUE DILIGENCE AND/OR SEEK YOUR OWN PROFESSIONAL ADVISOR AND CONSIDER THE INVESTMENT OBJECTIVES AND RISKS BEFORE INVESTING IN ANY SECURITIES MENTIONED ON THE SITE OR IN THE INFORMATION. You specifically acknowledge that MicroCapClub will in no way be held liable for losses or gains arising out of any Information sent to you by MicroCapClub or subscribed by you from MicroCapClub, and you waive any such claims on your own behalf and on behalf of your successors, heirs and representatives. You further acknowledge that the Information is based on the opinions of MicroCapClub and has not been independently verified by MicroCapClub.

The material in the Information represents an assessment of the market environment at a specific time and is not intended to be a forecast of future events or a guarantee of future results. This information should not be relied upon by the Registrant as research or investment advice regarding the funds or any security in particular.

The strategies discussed are strictly for illustrative and educational purposes and should not be construed as a recommendation to purchase or sell, or an offer to sell or a solicitation of an offer to buy any security. There is no guarantee that any strategies discussed will be effective. The information provided is not intended to be a complete analysis of every material fact respecting any strategy. The examples presented do not take into consideration commissions, tax implications or other transactions costs, which may significantly affect the economic consequences of a given strategy.

Disclosure of Ownership: From time to time, MicroCapClub, its affiliates, members, officers or employees and/or any or all of Information Providers and/or their affiliates may, or may not, hold positions in one or more of the securities mentioned in the Information and may trade such positions in such securities at any time, without notification to you, based on information not available on the Site and, furthermore, MicroCapClub, its affiliates, members, officers or employees and/or any or all of Information Providers and/or their affiliates have no obligation to disclose such information to you at any time. They may also liquidate shares (or other securities) in profiled companies at any time without notice and at will. Such liquidation may have a negative impact on the securities being liquidated. There can be no assurances that (i) Information Providers’ goals, objectives, investment portfolio or strategies are consistent with your own investment objectives and (ii) that the Information Providers are continuing to pursue a strategy or investment decision contained in the Information.

Disclosure of Compensation: Sponsors advertising on the Site will directly compensate MicroCapClub for the right to display promotional materials on the Site.  Sales by our sponsors which result from advertising on the Site will encourage the sponsors to continue to advertise on the Site.  Therefore, MicroCapClub, its affiliates, members, officers or employees and/or any or all of Information Providers and/or their affiliates arguably have a financial incentive to recommend the securities and products of MicroCapClub sponsors.  However, the opinions expressed on MicroCapClub are independent of any third party payments and as a general policy, MicroCapClub, its affiliates, members, officers or employees and/or any or all of Information Providers and/or their affiliates may not express opinions on the basis of such compensation.

Information Source: MicroCapClub is not responsible for monitoring information provided by its Information Providers and sent to you in the Information. It is each Information Provider’s responsibility to make sure that any information is distributed in compliance with applicable law. You specifically acknowledge that MicroCapClub will in no way be held liable for any potential or actual violations of United States laws or applicable state laws, including without limitation any federal or state securities laws, based on Information sent to you by MicroCapClub. Forward Looking Statements: The Information and other information on the Site may contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. These statements can be identified by the fact that they do not relate strictly to historical or current facts. Forward-looking statements often include words such as “anticipates,” “estimates,” “expects,” “projects,” “intends,” “plans,” “believes” and words and terms of similar substance in connection with discussions of future operating or financial performance. Any forward-looking statements made by MicroCapClub speak only as of the date on which they are made and MicroCapClub is under no obligation to, and expressly disclaims any obligation to, update or alter its forward-looking statements, whether as a result of new information, subsequent events or otherwise.

TERMS OF USE

Copyright and Trademark: Except where otherwise indicated, the Site and all text, images, graphics, photographs, drawings, designs, audio, video, data, software, files, trademarks, service marks, trade names, and other information contained on the Site, are the exclusive property of MicroCapClub. You may not reproduce, copy, retransmit, or modify any of the content of the Site without the express written authorization of MicroCapClub.

Disclaimer of Warranty and Limitation of Liability: THE INFORMATION AND MATERIALS ON THIS SITE ARE PROVIDED ON AN “AS IS”, “AS AVAILABLE” BASIS. MICROCAPCLUB DOES NOT GUARANTY THAT THE INFORMATION OR ANY INFORMATION ON THE SITE IS ACCURATE OR CURRENT. MICROCAPCLUB MAKES NO WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, WITH RESPECT TO THE INFORMATION OR THE SITE. ALL IMPLIED AND STATUTORY WARRANTIES, INCLUDING BUT NOT LIMITED TO, THE WARRANTY OF MERCHANTABILITY, THE WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE, AND THE WARRANTY OF NON-INFRINGEMENT OF PROPRIETARY RIGHTS, ARE EXPRESSLY DISCLAIMED TO THE FULLEST EXTENT PERMITTED BY LAW. MICROCAPCLUB RESERVES THE RIGHT TO CHANGE THE CONTENT OF THE SITE AT ANY TIME WITHOUT NOTICE.
TO THE FULLEST EXTENT PERMITTED BY LAW, MICROCAPCLUB EXPRESSLY DISCLAIMS ALL LIABILITY FOR, AND YOU AGREE TO INDEMNIFY AND HOLD MICROCAPCLUB, ITS MEMBERS, OFFICERS, AND AFFILIATES HARMLESS FOR, ANY DAMAGES OR LOSSES AS A RESULT OF YOUR USE OF OR INABILITY TO USE THE SITE, THE INFORMATION OR MATERIALS YOU PROVIDE TO THE SITE, THE INFORMATION OR YOUR RELIANCE ON THE INFORMATION CONTAINED ON THE SITE, OR YOUR VIOLATION OF THESE TERMS OR APPLICABLE LAW.

Posting Materials on the Site: Registrants may post, upload, publish, submit or transmit text, information or other materials to be made available through the Site (“Registrant Content”). By making available any Registrant Content through the Site, you hereby grant to MicroCapClub a worldwide, irrevocable, perpetual, non-exclusive, transferable, royalty-free license, with the right to sublicense, to use, copy, adapt, modify, distribute, license, sell, transfer, publicly display, publicly perform, transmit, stream, broadcast and otherwise exploit such Registrant Content only on, through or by means of the Site. MicroCapClub does not claim any ownership rights in any such Registrant Content and nothing in these Terms of Use will be deemed to restrict any rights that you may have to use and exploit any such Registrant Content.

You acknowledge and agree that you are solely responsible for all Registrant Content that you make available through the Site. Accordingly, you represent and warrant that: (i) you either are the sole and exclusive owner of all Registrant Content that you make available through the Site or you have all rights, licenses, consents and releases that are necessary to grant to MicroCapClub the rights in such Registrant Content, as contemplated under these Terms of Use; and (ii) neither the Registrant Content nor your posting, uploading, publication, submission or transmittal of the Registrant’s Content or MicroCapClub’s use of the Registrant Content (or any portion thereof) on, through or by means of the Site will infringe, misappropriate or violate a third party’s patent, copyright, trademark, trade secret, moral rights or other intellectual property rights, or rights of publicity or privacy, or result in the violation of any applicable law or regulation.

You agree not to post, upload, publish, submit or transmit any text, graphics, information or other material that: (i) infringes, misappropriates or violates a third party’s patent, copyright, trademark, trade secret, moral rights or other intellectual property rights, or rights of publicity or privacy; (ii) violates, or encourages any conduct that would violate, any applicable law or regulation or would give rise to civil liability; (iii) is fraudulent, false, misleading or deceptive; (iv) is defamatory, obscene, pornographic, vulgar or offensive; (v) promotes discrimination, bigotry, racism, hatred, harassment or harm against any individual or group; (vi) is violent or threatening or promotes violence or actions that are threatening to any other person; or (vii) promotes illegal or harmful activities or substances.

PRIVACY POLICY

Privacy Policy: The Site allows users to register with MicroCapClub to receive periodic updates with Information. Registrants can register online, and are required to provide MicroCapClub with their e-mail address. By registering with MicroCapClub, you are consenting to have your personal data transferred to and processed in the United States. We will not share your personal information with third-parties. We will email you from time to time with general service-related announcements, but you can opt out of this if desired (please see the privacy features in registration).

Disclosure to Third Parties: We also may disclose your personal information as required by applicable law and may perform disclosures that are necessary or advisable to: (a) protect our rights, safety or property; (b) enforce the Terms of Use; (c) respond to your requests for customer service; (d) to comply with legal process; or (d) to comply with or as permitted by applicable laws and regulations. We reserve the right to transfer any and all information we collect from Site users to an affiliate, as well as to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or disposition of all or any portion of our business, assets, or stock (including without limitation in connection with bankruptcy or any similar proceedings) with or to such third party.

Links: The Site may include links to websites operated by third-parties. We endeavor to only link to reputable organizations; however, because these other sites are not hosted or controlled by us, we are not responsible for the privacy practices of those sites or the content provided thereon. Therefore, the privacy policies with respect to these areas may differ from those applicable to the Site, and we encourage you to review the privacy policies of those other websites. This Privacy Policy only applies to information we collect through the Site. You acknowledge and agree that these linked-to sites are not under the control of MicroCapClub and that MicroCapClub makes no warranties, endorsements, recommendations, or representations whatsoever concerning the content of these other sites.

Security Measures: MicroCapClub uses reasonable administrative, physical and electronic security measures to protect against the loss, misuse and alteration of your personally identifiable information. We periodically review the effectiveness of these security measures.
Please let us know any questions or comments you have related to privacy on MicroCapClub. We can be reached at the contact page.

Choice of Law: Any legal dispute arising out of your use of the Site will be governed by the laws of the United States of America and the Commonwealth of Pennsylvania without giving effect to rules governing choice of laws. Those who choose to access the Site from locations outside of the United States do so on their own initiative, and are responsible for compliance with local laws if and to the extent local laws are applicable. The Information provided by MicroCapClub is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject MicroCapClub to any registration requirement within such jurisdiction or country.

If you have any questions about the Site, the Disclaimer, Terms of Use, or the Privacy Policy, please direct them to the contact page.