XGlobal Holdings LLC FTC Disclosure & Transparency Policy

1. Purpose, Scope & Application

The XGlobal FTC Disclosure & Transparency Policy forms part of the legal, compliance, advertising, communications, and integrity framework governing promotional activity associated with XGlobal Holdings LLC and applicable XGlobal programs, platforms, services, participation pathways, partnerships, affiliate arrangements, referral activities, campaigns, publications, and related digital properties.

The principal purpose of this Policy is to require truthful, non-deceptive, adequately substantiated, transparent, and appropriately disclosed promotional communications.

This Policy applies to every person or entity that promotes, advertises, endorses, reviews, recommends, refers, publishes, markets, distributes, or otherwise communicates about XGlobal or an XGlobal-related activity where that communication is connected with a participation, affiliate, partner, referral, compensation, reward, commercial, promotional, or other material relationship.

This includes, without limitation, participants, affiliates, sub-affiliates, partners, publishers, creators, influencers, website operators, advertisers, agencies, contractors, promotional partners, referral participants, reviewers, ambassadors, and other authorized or unauthorized persons whose communications may reasonably be associated with XGlobal.

This Policy applies regardless of the communication medium, including websites, landing pages, search advertising, social media, email, text messaging, messaging applications, blogs, podcasts, livestreams, videos, images, presentations, reviews, comments, online communities, advertisements, direct communications, and offline promotional activity.

2. Definitions & Interpretation

For purposes of this Policy, unless the context requires otherwise:

• “XGlobal” means XGlobal Holdings LLC and, where applicable, its authorized subsidiaries, affiliates, platforms, brands, programs, services, and related entities.
• “Promotional Communication” means any communication that advertises, markets, recommends, endorses, refers to, reviews, promotes, or encourages participation in an XGlobal-related activity.
• “Promoter” means any person or entity creating, publishing, distributing, sponsoring, approving, directing, or materially participating in a Promotional Communication.
• “Material Connection” means a financial, employment, family, personal, business, referral, commission, reward, partnership, affiliate, contractual, promotional, or other relationship that could affect or reasonably be expected to affect the weight or credibility a consumer gives to a communication.
• “Disclosure” means a truthful statement communicating the existence and relevant nature of a Material Connection.
• “Earnings Claim” means any express or implied statement, image, testimonial, representation, example, lifestyle depiction, ranking, commission example, income statement, or other communication that conveys or implies an amount, level, likelihood, speed, predictability, or financial outcome that a participant may obtain.
• “Endorsement” includes a recommendation, testimonial, review, opinion, demonstration, social-media expression, or other communication that consumers are likely to believe reflects the opinions or experiences of someone other than the sponsoring advertiser.
• “Consumer” means an individual or entity that views, receives, evaluates, purchases, uses, or may reasonably be expected to respond to a Promotional Communication.

Headings are provided for convenience and do not limit the substantive meaning of any provision. Words in the singular include the plural where appropriate, and references to applicable law include amendments, replacements, successor provisions, and mandatory requirements applicable to the relevant conduct.

3. Material-Relationship Disclosures

A Promoter must disclose a Material Connection whenever the existence or nature of that connection would be material to a reasonable consumer's evaluation of the Promotional Communication and disclosure is required by applicable law, regulation, advertising standards, platform rules, or this Policy.

A Material Connection may include compensation, commissions, referral rewards, performance incentives, free or discounted services, partnership status, employment, agency relationships, contractual relationships, ownership interests, or other benefits of economic or reputational value.

• The Disclosure must accurately describe the relevant relationship.
• The Disclosure must not be false, incomplete, ambiguous, hidden, or misleading.
• The Promoter must not rely solely upon the assumption that consumers already know of the relationship.
• A Disclosure should be made in the same language as the Promotional Communication where reasonably practicable.
• The Disclosure must remain reasonably understandable to the intended audience.
• A platform's built-in disclosure mechanism does not automatically eliminate the Promoter's obligation to provide an adequate disclosure.

These examples are illustrative only. The appropriate wording depends upon the actual relationship, communication, jurisdiction, platform, audience, and applicable legal requirements.

4. Clear & Conspicuous Disclosure Standards

Where a Disclosure is required, it must be presented in a manner that a reasonable member of the intended audience is likely to notice, read, understand, and associate with the relevant Promotional Communication.

A Disclosure must not be defeated by its placement, presentation, timing, formatting, color, size, duration, language, surrounding content, hyperlinks, or other design characteristics.

5. Responsible Promotional Conduct

Every Promoter is responsible for ensuring that Promotional Communications are truthful, accurate, reasonably supported, non-deceptive, and consistent with the actual terms and characteristics of the XGlobal activity being promoted.

Promoters must:

• communicate honestly and in good faith;
• distinguish personal opinions and experiences from official statements of XGlobal;
• accurately describe products, services, programs, participation pathways, rewards, and qualification requirements;
• disclose Material Connections where required;
• avoid deceptive omissions and materially incomplete claims;
• avoid false urgency or scarcity;
• avoid guarantees that XGlobal does not actually provide;
• avoid unsupported financial, business, health, legal, regulatory, technological, or performance claims;
• comply with applicable privacy, intellectual-property, electronic-communications, advertising, consumer-protection, and platform requirements;
• use official XGlobal materials only in accordance with the authorization or instructions accompanying those materials.

A referral, affiliate, partner, publisher, or participant relationship does not by itself authorize a person to represent themselves as an officer, employee, legal representative, government authority, regulator, attorney, spokesperson, or authorized representative of XGlobal.

6. Reviews, Testimonials & Endorsements

Reviews, testimonials, endorsements, ratings, recommendations, case studies, success stories, and similar communications must reflect genuine experiences, opinions, or information and must not be fabricated, materially altered, or presented in a manner that creates a deceptive impression.

• A person must not claim personal experience with a product, service, or program that they have not actually experienced.
• A person must not claim results they did not actually obtain.
• A Promoter must not manufacture or purchase fake reviews, fake testimonials, fake followers, fake engagement, or fabricated consumer experiences.
• Negative reviews must not be suppressed or manipulated in order to create a materially misleading overall impression.
• Incentivized reviews must be handled in accordance with applicable law and applicable platform rules.
• A testimonial must not be used to imply that consumers generally should expect an outcome that is not reasonably representative without legally sufficient qualification and substantiation.
• Promoters must not instruct reviewers to express opinions that are not genuinely held.

8. Digital, Social Media & Affiliate Communications

Promotional communications made through digital channels remain subject to this Policy regardless of whether they are created personally, automatically, through an advertising agency, or through a third-party platform.

Promoters must apply appropriate disclosure and truthfulness standards to:

• websites and landing pages;
• affiliate links and referral links;
• social-media posts and stories;
• videos and livestreams;
• blogs and articles;
• podcasts;
• email and newsletters;
• text and messaging applications;
• search and display advertising;
• online communities and forums;
• comments and user-generated content;
• QR codes and promotional graphics;
• automated marketing communications; and
• other electronic or offline promotional channels.

An affiliate link should not be described merely as an “affiliate link” where that term would not reasonably communicate that the Promoter may receive compensation or another benefit. The disclosure should communicate the economic relationship in language the intended audience can reasonably understand.

10. Artificial Intelligence & Synthetic Media

Artificial intelligence, automated content-generation systems, synthetic media, avatars, voice cloning, image generation, automated testimonials, and similar technologies may not be used to create a materially deceptive impression about XGlobal or a person's relationship with XGlobal.

• AI-generated testimonials must not be presented as genuine human experiences when they are not.
• Synthetic voices or likenesses must not impersonate a real person without appropriate authorization.
• AI-generated earnings screenshots, payment records, testimonials, customer results, or success stories must not be represented as authentic records.
• AI-generated content remains subject to all requirements concerning truthfulness, substantiation, disclosure, intellectual property, privacy, and consumer protection.
• Automated systems must not be used to circumvent this Policy or create high-volume deceptive communications.

11. Children & Vulnerable Audiences

Promotional communications must be designed and distributed with appropriate consideration for children, minors, and other audiences requiring heightened legal or ethical protection.

Promoters must not knowingly exploit a child's lack of experience, knowledge, sophistication, or ability to understand commercial relationships.

Where applicable law imposes heightened requirements concerning child-directed advertising, consent, privacy, data collection, commercial communications, or endorsements, those requirements must be followed.

Promoters must not target minors with misleading income claims, unrealistic financial expectations, deceptive urgency, or representations designed to exploit financial vulnerability.

12. Claims Substantiation & Records

A Promoter making an objective claim about XGlobal, its services, programs, rewards, performance, capabilities, financial outcomes, or other material characteristics must have an appropriate factual basis for the claim before publication where such substantiation is required by applicable law or this Policy.

Depending upon the claim, substantiation may include reliable records, program terms, independently verifiable data, testing, documentation, calculations, or other competent evidence.

Personal experience or anecdotal belief does not automatically establish a sufficient basis for an objective claim concerning what consumers or participants generally can expect.

XGlobal may request reasonable documentation supporting a material Promotional Communication where necessary to investigate a complaint, regulatory inquiry, suspected violation, consumer protection issue, or material claim.

13. Monitoring & Compliance

XGlobal may establish reasonable compliance, training, monitoring, review, reporting, investigation, and enforcement procedures intended to protect consumers and the integrity of its ecosystem.

XGlobal may review publicly available Promotional Communications, communications submitted to XGlobal, communications associated with an XGlobal account or program, complaints, reports, and other information that XGlobal is lawfully entitled to obtain or review.

XGlobal may request that a Promoter correct, qualify, substantiate, withdraw, or remove a communication that reasonably appears to violate this Policy, applicable contractual terms, platform rules, or applicable law.

• Promoters must reasonably cooperate with legitimate compliance inquiries.
• Promoters must not destroy or falsify evidence relevant to an active investigation.
• XGlobal may preserve relevant records where reasonably necessary for legal, security, compliance, or investigative purposes.
• XGlobal may use reasonable risk-based monitoring rather than continuous review of every communication.

14. Violations & Corrective Action

A violation of this Policy may result in corrective, protective, contractual, administrative, or other lawful action depending upon the circumstances.

Measures may include:

• educational guidance or compliance instruction;
• correction, qualification, withdrawal, or removal of content;
• requests for substantiation;
• restriction of promotional privileges;
• suspension of referral or affiliate privileges;
• suspension of an account or participation status;
• termination of applicable participation rights;
• reversal, adjustment, withholding, or forfeiture of compensation associated with fraudulent, invalid, or non-compliant activity where authorized by applicable agreement and permitted by law; and
• referral to legal, regulatory, contractual, or other appropriate processes.

XGlobal may take immediate protective measures where reasonably necessary to address suspected fraud, consumer harm, regulatory risk, security threats, materially misleading communications, impersonation, unlawful activity, or other significant risks.

Where reasonably practicable, XGlobal may provide notice and an opportunity to respond. However, advance notice is not required where doing so could compromise an investigation, security measure, regulatory obligation, legal requirement, or consumer protection measure.

Nothing in this Policy limits any remedy otherwise available to XGlobal under an applicable agreement or applicable law.

15. Participant Responsibility & Indemnification

Each Promoter is independently responsible for Promotional Communications that the Promoter creates, publishes, directs, approves, distributes, or materially contributes to, subject to applicable law and any applicable agreement.

A Promoter must not assume that an XGlobal referral relationship, participation status, training resource, promotional material, platform feature, or compensation arrangement transfers the Promoter's legal obligations to XGlobal.

To the maximum extent permitted by applicable law and any applicable agreement, a Promoter may be responsible for losses, claims, liabilities, penalties, costs, expenses, or damages arising from the Promoter's unlawful, fraudulent, deceptive, unauthorized, or materially non-compliant Promotional Communications.

Nothing in this Section makes a Promoter an employee, agent, partner, joint venturer, legal representative, or fiduciary of XGlobal unless a separate written agreement expressly establishes such a relationship.

16. International Legal Standards

XGlobal operates within an international digital environment in which Promotional Communications may reach consumers in multiple jurisdictions. Promoters are responsible for considering the laws and advertising requirements applicable to the audience, communication, activity, and jurisdiction involved.

Where a mandatory requirement of applicable law imposes a higher or different standard than this Policy, the mandatory requirement applies to the extent required by law.

References to particular regulators or jurisdictions are illustrative compliance references and do not mean that every identified law or authority applies to every person, transaction, communication, or program.

Nothing in this Policy constitutes a representation that XGlobal has obtained approval, certification, endorsement, registration, authorization, or exemption from any regulator or governmental authority unless expressly stated in a separate official document supported by the applicable authority.

17. Policy Updates & Amendments

XGlobal may modify this Policy from time to time to reflect changes in applicable law, regulatory guidance, advertising standards, platform requirements, technology, business models, services, participation structures, consumer-protection expectations, or internal compliance procedures.

Updated versions may be published through the XGlobal Legal Center or another official XGlobal communication channel.

Unless applicable law or an applicable agreement requires otherwise, the updated version will apply prospectively from its stated effective date.

No amendment will be interpreted as retroactively authorizing conduct that was unlawful when performed or eliminating rights that cannot lawfully be modified retroactively.

18. General Legal Provisions

18.1 Governing Law. Unless a separate applicable agreement provides otherwise, questions concerning the interpretation of this Policy shall, to the maximum extent permitted by applicable law, be governed by the laws of the State of Delaware, United States, without giving effect to conflict-of-law principles that would require application of another jurisdiction's law.

18.2 Mandatory Laws. The governing-law provision does not exclude mandatory consumer, privacy, advertising, employment, regulatory, or other protections that cannot lawfully be excluded under the law applicable to the relevant person or transaction.

18.3 Severability. If any provision is determined to be unlawful, invalid, or unenforceable, it shall be modified or limited to the minimum extent necessary where legally permissible, and the remaining provisions shall remain in effect to the maximum extent permitted by law.

18.4 No Waiver. Failure by XGlobal to enforce a provision on one occasion does not constitute a waiver of its right to enforce that provision later or to enforce another provision.

18.5 No Third-Party Approval. This Policy does not constitute approval, certification, or endorsement by the Federal Trade Commission, any state regulator, any foreign regulator, any advertising authority, or any other governmental or private organization.

18.6 No Legal Advice. This Policy establishes XGlobal's compliance requirements and contractual standards where incorporated into an applicable agreement. It is not legal advice to any participant, promoter, advertiser, partner, or consumer.

18.7 Electronic Records. To the extent permitted by applicable law, electronic publication, acceptance, acknowledgement, records, timestamps, account records, and other electronic evidence may be used to establish notice, acknowledgement, or applicable contractual acceptance.

18.8 Survival. Provisions concerning responsibility, confidentiality, intellectual property, records, indemnification, limitations, dispute resolution, governing law, and other provisions that by their nature should survive termination shall survive to the extent permitted by applicable law.

18.9 Entire Compliance Framework. This Policy supplements rather than automatically replaces any applicable Terms of Use, Affiliate Agreement, Partner Agreement, Compensation Plan, Privacy Policy, Refund Policy, Tax Policy, Advertising Policy, or other governing XGlobal agreement. Where an applicable agreement establishes a stricter lawful requirement, the stricter requirement applies to the extent legally permissible.