Legal Information, Privacy and Terms of Service, Communications, Representation, and Specific Service Conditions

This document (the “Document” or “FINANCERS Terms”) sets forth the general framework for using the FINANCERS website and FINANCERS Platform, the conditions applicable to informational and professional services offered by FINANCERS, the privacy notice regarding personal data processing, the electronic communications policy (including SMS and messaging), the representation and proxy conditions that the client may grant to FINANCERS, and the specific conditions of certain professional services (accounting and bookkeeping, outsourced CFO-type services, taxes, and non-legal documentary support services). By accessing the website, using the FINANCERS Platform and/or contacting FINANCERS through any available channel, you fully accept this Document. If you do not agree, you must not use these channels or hire services from FINANCERS. FINANCERS is a U.S.-based accounting firm for Latinos doing business with or in the United States. The “FINANCERS Platform” is a set of tools and technological services provided by third parties that FINANCERS engages to work with its clients and organize their information.

1. IDENTIFICATION OF THE CONTROLLER

AMERICA TRADING LLC, commercially operating under the name FINANCERS (hereinafter, “FINANCERS,” “we,” “us,” or “our”), is a U.S. accounting firm that primarily provides professional services related to entity formation, bank account opening, international tax advisory, accounting and bookkeeping (bookkeeping and reporting), preparation and filing of tax returns (tax filing and tax compliance), administrative and compliance support associated with corporate structures, outsourced CFO-type financial services (financial planning, models, dashboards, projections), and non-legal documentary and operational support services (forms, templates, surveys, and operational documentation). FINANCERS is especially focused on Latino individuals (freelancers, contractors, entrepreneurs, investors, and business owners) who do business with or for the United States from Latin America, Europe, or other jurisdictions, particularly non-resident foreign clients conducting international business who have U.S. filing and reporting requirements. Fictitious business name / trade name evidence documentation was attached via an escalation appeal related to an initial relationship rejection. FINANCERS is not a bank or financial institution and does not provide financial intermediation, trading, credit, loans, or other services commonly classified as “high-risk financial services.” FINANCERS is not a law firm and does not provide regulated legal advice or regulated investment advice; any references to legal or investment topics are for informational purposes only and must be validated by the client’s own advisors. Contact details: official website: financers.com.ar; email: admin@financers.com.ar; principal address (U.S.): 2420 1/2 K St, San Diego, CA 92102, United States.

2. DEFINITIONS AND SCOPE OF THIS DOCUMENT

For purposes of this Document, “Site” or “Website” means financers.com.ar and any institutional microsite used by FINANCERS to provide information about its services; “FINANCERS Platform” or “Platform” means the set of technological services, portals, forms, dashboards, CRM, ticketing systems, file storage systems, and other digital tools that FINANCERS makes available to users and clients, even if the technical infrastructure and software are provided and operated by third parties; “Client” or “User” means any individual or legal entity that browses the Site, uses the Platform, and/or hires services from FINANCERS. This Document combines, in a single text, the general framework for Site and Platform use, the privacy and data protection notice, the contact and messaging policy, the professional representation and proxy policy, and the specific service conditions (accounting and bookkeeping, CFO-type services, taxes, and non-legal documentary support). These conditions apply to anyone browsing the Site, using the FINANCERS Platform, contacting FINANCERS through available channels, and to clients or potential clients who hire or consider hiring professional services from FINANCERS. The specific professional relationship with each client is also governed by service letters, proposals, service agreements, or other specific documentation signed with that client (each a “FINANCERS Service Letter”); in case of conflict between this Document and a FINANCERS Service Letter, the Service Letter prevails for the relevant specific service.

3. ACCEPTANCE, UPDATES, AND CURRENT VERSION

Access to the Site, use of the FINANCERS Platform and/or FINANCERS contact channels implies full acceptance of this Document. If you do not agree with any provision, you must not use the Site, the Platform, nor provide your data. FINANCERS may modify or update these terms at any time; the current version will be the one published on the Site, indicating the last update date. Continued use of the Site, Platform, or services after changes are published means acceptance of the updated FINANCERS Terms.

4. NATURE OF FINANCERS SERVICES

FINANCERS is a U.S. accounting and tax firm for Latinos doing business with or in the United States. Our focus is accounting, tax compliance, and administrative support for structures used to work with and bill U.S.-based clients. Information on the Site, Platform, and social media or other channels is general and informational only and does not constitute personalized professional advice or specific financial, investment, legal, or tax recommendations. Any personalized recommendation is formalized only within a concrete professional relationship, through the corresponding FINANCERS Service Letter, and after analyzing the client’s particular case. FINANCERS does not manage third-party funds and does not provide gambling, adult content, tobacco or vaping sales, illegal drugs, weapons, or other activities restricted by messaging and advertising providers. Use of the Site, Platform, or submitting inquiries does not create an attorney–client relationship or a regulated investment advisor relationship. Business, legal, investment, and wealth decisions remain the client’s responsibility, and the client must use their own legal and financial advisors when appropriate.

5. GENERAL RULES FOR USING THE SITE AND FINANCERS PLATFORM

Users must use the Site and FINANCERS Platform diligently, lawfully, and respectfully, and must refrain from engaging in unlawful or fraudulent activities, violating FINANCERS’ or third-party rights (including intellectual property, personal data, honor, or image rights), attempting unauthorized access to systems, servers, databases, or other users’ accounts, or using contact channels to distribute spam or offensive, discriminatory, defamatory, illegal, or policy-violating content. FINANCERS reserves the right to restrict, suspend, or terminate access to the Site, Platform, or certain services if misuse or violation of these FINANCERS Terms is detected.

6. USER ACCOUNTS AND TECHNOLOGY PROVIDERS

Certain Platform functions (client portals, tracking dashboards, document uploads, e-signature flows, etc.) may require creating a user account. Users must provide truthful, complete, up-to-date information, keep credentials confidential, and immediately notify FINANCERS of any unauthorized use or suspected security breach. The Platform is not intended for minors under 18. By registering, the user represents being at least 18 and legally capable of contracting, and assumes responsibility for all activity under their account, even if performed by third parties using their credentials. The FINANCERS Platform is provided through third-party technological services (software providers, CRM, cloud storage, client portals, messaging or video-call systems, etc.). FINANCERS contracts these services and makes them available to users as work tools for accounting and tax services. The professional services relationship is always between the client and FINANCERS, even if parts of the experience rely on third-party technology. FINANCERS selects providers with professional criteria but does not control all technical aspects of their operation and cannot guarantee absolute availability, error-free performance, or absence of vulnerabilities. Subject to applicable law, FINANCERS is not responsible for losses solely caused by outages, policy changes, or security incidents attributable exclusively to third-party providers, beyond FINANCERS’ legal obligations regarding data protection and information security.

7. FINANCERS CONTACT, MESSAGING, AND SMS TERMS

FINANCERS may communicate with you via email, phone calls or video calls, SMS messages, messaging apps (e.g., WhatsApp when applicable), and commercial automation and CRM tools (email marketing systems, onboarding flows, reminders, etc.), operated wholly or partly by third-party providers. FINANCERS messages, including SMS and app messages, may be conversational (responses to inquiries), informational or administrative (deadlines, document requests, receipt confirmations, service status updates, meeting reminders), educational (articles, guides, best practices), and moderate commercial communications about FINANCERS services, always respecting the recipient’s right to opt out. FINANCERS does not use SMS or messaging to promote prohibited activities such as gambling, explicit sexual content, illegal drugs, weapons, tobacco/vaping, high-risk financial services, or the sale of contact lists.

7.1 SMS consent and purpose

FINANCERS will only send SMS messages when there is specific and verifiable consent from the phone number owner or another clear legal basis (e.g., essential communications for a contracted professional service). Consent may be collected via unchecked opt-in boxes in forms, explicit acceptance in FINANCERS Service Letters, client-initiated texts (“clients text us first”), or affirmative responses to messages explaining SMS conditions. Consent is freely given, informed, and revocable.

7.2 Types of SMS communications

If the client consents to receive FINANCERS SMS messages, they may receive: appointment/meeting reminders; service follow-ups; document requests; administrative confirmations; tax/compliance deadline notices; status updates; and conversational support messages. FINANCERS will not send illegal, misleading, discriminatory, or offensive SMS content, nor SMS for third-party marketing.

7.3 Message frequency

Message frequency may vary depending on the contracted service and tax calendars. For example, the client may receive up to [X] SMS messages per week related to appointments, reminders, billing, information requests, or service follow-up.

7.4 Carrier fees

FINANCERS does not charge additional fees for sending SMS. However, standard messaging and data rates may apply depending on the client’s mobile carrier plan. Rates may vary for domestic vs. international messages. FINANCERS is not responsible for carrier charges.

7.5 Opt-out

The client may stop receiving SMS at any time by replying “STOP” to any SMS. After processing, FINANCERS will discontinue non-essential or commercial messages to that number and may send a final confirmation of opt-out. The client may also request opt-out by emailing admin@financers.com.ar.

7.6 Help

If the client needs assistance, they may reply “HELP” (or “AYUDA”) to any FINANCERS SMS to receive basic support instructions and contact information, or reach out via financers.com.ar or admin@financers.com.ar.

7.7 Additional options

If the client does not want SMS communications, they may avoid selecting the SMS consent checkbox on forms or revoke consent at any time. Revocation does not affect the lawfulness of prior processing nor prevent FINANCERS from sending strictly necessary messages for legal or contractual compliance.

8. PRIVACY NOTICE AND PERSONAL DATA PROTECTION

FINANCERS may process identifying data (name, surname, ID, country of residence, etc.), contact data (email, phone number, messaging handles), professional/commercial data (activity, revenue, business description, corporate structure), data needed for accounting and tax services (bank statements, payment processor reports, accounting records, tax forms, partner and beneficial owner information), and navigation/usage data (IP address, device, browser, pages visited, times, cookies), as well as communication and marketing preferences. Data may be collected through Site/Platform forms, emails, calls/video calls, SMS or messaging apps, FINANCERS Service Letters and supporting documentation, third-party integrations (payment processors, banks, e-signature tools), analytics and advertising tools (Meta, Google, LinkedIn, X, YouTube, CRM, etc.), and cookies or similar technologies.

FINANCERS uses personal data to provide, manage, and improve contracted professional services; comply with legal and regulatory obligations (tax, accounting, AML, etc.); manage billing and payments; send service-related communications (reminders, document requests, deadline notices, confirmations); send educational content and moderate commercial communications when legally allowed; and improve user experience and internal processes. Depending on context, FINANCERS processes data based on contract performance or pre-contractual measures, legal obligations, legitimate interest balanced with your rights, or consent when required.

FINANCERS will keep personal data while a contractual or pre-contractual relationship exists, while necessary for the purposes collected, or while legal retention periods apply. Once those periods expire, data will be deleted or reasonably anonymized. FINANCERS does not sell or rent personal data. FINANCERS does not share mobile subscription data, SMS consent, or phone numbers with third parties or affiliates for marketing purposes. For clarity, we include the required statement: “Mobile subscription, SMS consent, and phone numbers will not be shared with third parties or affiliates for marketing purposes.” FINANCERS may share data with technology providers acting as processors (hosting, email, CRM, messaging, cloud storage, e-signature); with external professionals collaborating with FINANCERS (accountants, Enrolled Agents, CPAs, consultants) under confidentiality; with authorities when legally required; and with allied entities when necessary to deliver contracted services. Where international transfers occur, FINANCERS will seek appropriate safeguards under applicable law.

FINANCERS services are not directed to minors under 18. If data from a minor is detected without authorization, it will be reasonably deleted. You may exercise access, rectification, update, deletion, restriction, and objection rights, as well as other applicable rights, by emailing admin@financers.com.ar with your full name, the right you wish to exercise, and enough information to locate your record. FINANCERS may request additional information to verify identity and will respond within a reasonable legal timeframe.

9. COOKIES AND SIMILAR TECHNOLOGIES

FINANCERS may use cookies and similar technologies on the Site/Platform to enable basic technical operation, remember preferences, obtain anonymous navigation statistics, measure campaign effectiveness, and improve content. You may manage cookies through your browser settings and, when applicable, through Site banners/panels. Some strictly necessary cookies cannot be disabled without affecting essential features.

10. DIGITAL ADVERTISING, SOCIAL MEDIA, AND AUTOMATION

FINANCERS may use platforms such as Meta, Google, LinkedIn, X, YouTube, CRM systems, and other services to run ads and content, retargeting or directed campaigns, measure conversions, and automate onboarding, reminders, and follow-ups. Only limited and appropriate data will be used per purpose, respecting platform policies and applicable law. FINANCERS does not sell or share SMS consents or phone contact lists for third-party marketing. You may manage advertising and privacy preferences through each platform’s settings and any regional opt-out tools available.

11. PROFESSIONAL REPRESENTATION AND PROXIES

For certain services (tax filings, responses to tax authority letters, regulatory surveys, account/portal opening or management), clients may grant FINANCERS representation powers, authorizations, or platform accesses to act on their behalf with authorities, banks, payment processors, or other providers. These powers are intended to facilitate administrative procedures and do not imply FINANCERS ownership of the client’s entities, accounts, or assets. Unless otherwise agreed in writing, any mandate/proxy granted to FINANCERS will be specific and limited to the contracted service, will not be a general power, will not authorize discretionary control over client assets, will not authorize fund disposition or transfers without written client approval, and does not change the fact that ultimate responsibility for information accuracy and compliance lies with the client. Proxies may be instrumented via FINANCERS forms, official authority/bank documents, representation letters, or delegated access configurations in third-party platforms. They remain valid while services are ongoing unless revoked.

Clients may revoke proxies at any time with reasonable written notice. FINANCERS may also resign from proxies for reasonable causes (loss of trust, legal noncompliance indicators, nonpayment, conflicts, etc.), seeking a prudent transition period. If clients share credentials for third-party platforms, they represent being authorized to share them and accept FINANCERS will use them only for the professional engagement, with diligence and confidentiality. Some platforms prohibit credential sharing and require delegated access; configuring such access is the client’s responsibility. FINANCERS is not responsible for damages solely caused by third-party platform actions (blocks, policy changes, etc.). FINANCERS will not use proxies to evade KYC/AML controls, sanctions, legal restrictions, or to simulate identities/residencies/assets that do not reflect reality, and may refuse instructions that violate law, ethics, or regulation.

12. INTELLECTUAL PROPERTY AND MODEL DOCUMENTS

Site and Platform contents (texts, images, logos, trademarks, designs, compilations, software, templates, etc.) are owned by FINANCERS or used under license. Unauthorized reproduction, distribution, modification, or use is prohibited unless permitted by law or authorized in writing by FINANCERS. FINANCERS may provide forms, templates, checklists, letters, or other model documents (“FINANCERS Model Documents”) for internal client use. These documents are licensed on a non-exclusive, limited basis, cannot be resold, sublicensed, or offered as independent services, and are provided “as is” without warranty of automatic compliance with any jurisdiction’s specific laws. Clients must review and adapt model documents with their own legal/tax advisors before using them. Clients are advised to include a disclaimer such as: “This document is a working model that must be reviewed and adapted to the specific situation by professional advisors. It does not constitute legal or tax advice on its own.”

13. FEES, PAYMENTS, AND REFUNDS

FINANCERS fees are disclosed on the Site, commercial communications, and/or FINANCERS Service Letters and may be structured as fixed fees per service, hourly fees, recurring fees (monthly/annual subscriptions), or other written agreements. FINANCERS may update pricing for future services. For recurring/subscription services, changes apply to periods after reasonable notice, and continued use implies acceptance. Payments are made through available methods (credit card, bank transfer, ACH, payment platforms, etc.). For recurring services, clients authorize periodic charges until properly canceled. Unless a Service Letter states otherwise or mandatory law applies, payments are non-refundable; in recurring services, access usually continues until the end of the paid period.

14. SPECIFIC FINANCERS SERVICE CONDITIONS

For accounting/bookkeeping, FINANCERS may provide transaction recording, bank reconciliations, monthly closes, internal reporting, and accounting outputs for internal use and tax preparation inputs. Unless explicitly stated in a Service Letter, these services are not external audits or reviews, do not produce audited financial statements for third parties, and do not automatically certify GAAP/IFRS compliance.

For tax services (“FINANCERS Tax Services”), FINANCERS prepares and files tax returns and compliance for individuals and entities, resident or non-resident as applicable, per the relevant Service Letter (entity types, jurisdictions, periods, forms and surveys such as BE-13, BOI, etc.). Services rely on client-provided information; clients are responsible for providing complete, accurate, timely data, reviewing returns prior to filing, and reporting material changes. FINANCERS may work with Enrolled Agents, CPAs, or other tax professionals and may keep supporting documentation for legally required periods.

For outsourced CFO-type services (“FINANCERS CFO Services”), FINANCERS may provide strategic financial consulting, models, planning, forecasts, budgets, dashboards, and investment/funding support. Unless explicitly agreed, these services do not replace legal, audit, or regulated investment advisory services and do not automatically include tax filing or compliance. Decisions remain with the client’s management and FINANCERS does not guarantee outcomes. Deliverables become client property once paid, while FINANCERS retains ownership of methodologies and templates, licensing internal use to the client.

For non-legal documentary support (“FINANCERS Documentary Services”), FINANCERS may assist with document organization, standard templates, and administrative communications. This is not legal advice. Clients must obtain legal review for documents with significant legal effect and acknowledge FINANCERS is not a law firm.

15. LIMITATION OF LIABILITY AND INDEMNITY

To the maximum extent permitted by law, FINANCERS (including partners, directors, employees, contractors, and providers) shall not be liable for lost profits, loss of opportunity, data loss, indirect or consequential damages, special/punitive/exemplary damages, damages arising from use or inability to use the Site/Platform or third-party content, or damages linked to services not expressly contracted via a FINANCERS Service Letter. Where liability must be recognized and absent willful misconduct or gross negligence, FINANCERS’ total cumulative liability is capped at the total amount paid by you to FINANCERS in the twelve (12) months prior to the event giving rise to the claim. You agree to indemnify and hold FINANCERS harmless from third-party claims, costs, and expenses (including reasonable attorney fees) arising from your misuse of the Site/Platform/services, breach of these Terms or a Service Letter, false/incomplete/unlawful information or documentation you provide, or infringement of third-party rights.

16. GOVERNING LAW, DISPUTE RESOLUTION, AND JURISDICTION

Unless mandatory law or a Service Letter provides otherwise, this Document is governed by California law, United States, without prejudice to applicable conflict-of-law rules. FINANCERS and the client will seek amicable resolution of disputes. If unresolved, and where permitted, the parties may agree to confidential binding arbitration administered by a recognized institution seated in San Diego, California, in Spanish or English as agreed. To the extent permitted, parties waive participation in class or representative actions against FINANCERS, and any individual claim must be brought within one (1) year of the event giving rise to it. Where court action is necessary, parties submit to state and federal courts in San Diego, California, waiving other venues, without prejudice to any consumer rights in the user’s jurisdiction where mandatory law so provides.

17. CONTACT

For questions about this Document, FINANCERS Privacy Notice, FINANCERS Contact/Messaging/SMS Policy, FINANCERS Representation/Proxy Policy, or FINANCERS Specific Service Conditions, you may email admin@financers.com.ar. FINANCERS may request additional information to verify identity before processing requests related to personal data or sensitive documentation, to protect confidentiality and security.