HASHTAG INFLUENCER AND HASHTAG BIO LLC
These provisions supplement the Privacy Policy, Terms of Use, Use of Funds Policy, Anti-Money Laundering Policy, Sanctions Policy, and other compliance policies adopted by Hashtag Influencer Pte. Ltd., Hashtag Bio LLC, and those subsidiaries and affiliates that expressly adopt these provisions.
Hashtag Influencer is a creator accountability, transparency, verification, technology, marketing, and business-services platform.
Our principal purpose is to create greater accountability and transparency among creators, influencers, brands, fans, businesses, agencies, and other participants in the creator economy.
Unless expressly stated otherwise in connection with a separately regulated service, Hashtag Influencer and Hashtag Bio LLC are not fintech companies, cryptocurrency companies, cryptocurrency exchanges, banks, broker-dealers, money transmitters, investment advisers, trust companies, payment processors, custodians, or financial institutions.
The Company does not hold itself out as providing banking, securities brokerage, cryptocurrency exchange, money transmission, investment management, or other regulated financial services unless the applicable service is separately provided through an appropriately licensed or authorized entity.
Technology used by the Company, including blockchain, digital ledgers, wallets, APIs, verification technologies, artificial intelligence, or other digital infrastructure, does not change the fundamental nature of the Company's business into a cryptocurrency or financial-services business merely because such technology may be incorporated into a product or recordkeeping system.
The Company's mission is centered upon creator accountability, commercial transparency, verification, responsible brand relationships, transaction documentation, campaign accountability, and improved trust within the creator economy.
The Company may provide technology and administrative systems that document campaign participation, contractual relationships, services performed, payments, certifications, creator activities, licensing rights, intellectual property, engagement information, and other business records.
Where blockchain or similar technology is used, its principal purpose may include verification, record integrity, provenance, transparency, certification, or auditability.
The use of such technology does not necessarily mean that a cryptocurrency is being issued, sold, exchanged, or promoted.
Hashtag Bio LLC may serve as the designated United States corporate treasury and payment-administration entity for authorized Company and affiliate transactions, subject at all times to applicable licensing requirements and regulatory limitations.
Hashtag Bio LLC may receive Company revenue, investment capital, contractual payments, licensing revenue, franchise revenue, technology payments, administrative fees, platform fees, commissions, or other legitimate business proceeds where legally appropriate.
Hashtag Bio LLC may administer payments and disbursements relating to Company operations and authorized contractual obligations.
Nothing in these provisions authorizes Hashtag Bio LLC to conduct regulated money transmission, banking, securities brokerage, cryptocurrency exchange, custody, investment management, or another regulated financial activity without obtaining any license or authorization required by applicable law.
The Company intends, where appropriate, to use established third-party banks, payment processors, payment platforms, payroll providers, merchant-service providers, money-transfer providers, financial institutions, licensed payment companies, and other regulated or appropriately authorized vendors to execute payment functions.
Where a transaction requires a regulated payment function, the Company may direct the transaction through an appropriately licensed third-party provider rather than performing the regulated activity itself.
The third-party provider may independently require identification, KYC, KYB, beneficial-ownership information, source-of-funds documentation, tax information, sanctions screening, transaction information, or other compliance information.
Users agree to cooperate with reasonable compliance requirements imposed by such providers.
The Company's relationship with a third-party payment provider does not mean that the Company owns, controls, guarantees, or assumes the regulatory responsibilities of that independent provider.
The Company may charge legitimate contractual fees for technology, platform access, creator services, campaign administration, licensing, franchise services, transaction administration, verification, marketing, management, intellectual property access, consulting, subscription services, or other Company services.
The applicable Company fee should be disclosed through an agreement, order, invoice, campaign terms, subscription terms, transaction statement, or other appropriate commercial documentation.
Where legally permissible, the Company may collect its contractual fee before directing the remaining amount to the applicable recipient through a third-party payment provider.
The Company's collection of a legitimate contractual fee for its own services should not be interpreted as the Company providing banking, money-transmission, brokerage, or investment-management services.
The Company may work with third-party employment, Employer of Record, Professional Employer Organization, payroll, contractor-management, tax, benefits, HR compliance, workforce-management, and similar service providers where appropriate.
The Company may use platforms such as Deel or other appropriately selected HR and workforce-compliance providers for international contractor, employment, payroll, Employer of Record, or related compliance functions where commercially and legally appropriate.
The Company does not represent that every creator, influencer, ambassador, contractor, or participant is an employee.
Employment and contractor classifications shall depend upon the actual legal relationship, applicable agreement, jurisdiction, and governing law.
The Company shall endeavor to distinguish Company funds from funds contractually payable to creators, influencers, vendors, brands, contractors, or other counterparties.
Funds shall be accounted for according to the applicable agreement and Company accounting procedures.
Where funds are processed through a third-party payment provider, settlement timing may depend upon that provider, the banking system, compliance review, currency conversion, transaction verification, fraud review, sanctions review, chargebacks, or other factors outside the Company's direct control.
Company funds may be used only for legitimate and authorized business purposes.
Authorized purposes may include operations, payroll, contractors, professional services, technology, infrastructure, intellectual property, patents, licensing, offices, facilities, real estate, marketing, sales, business development, acquisitions, strategic investments, international expansion, franchise development, legal expenses, accounting expenses, compliance, taxes, insurance, vendors, customer acquisition, and other properly authorized corporate expenses.
Material expenditures should be supported by commercially reasonable documentation and appropriate corporate authorization.
Company funds shall not knowingly be used for bribery, kickbacks, fraud, money laundering, terrorist financing, sanctions evasion, personal expenditures unrelated to Company business, unauthorized related-party transactions, false invoices, unlawful payments, or other illegal activities.
The Company maintains a risk-based approach intended to prevent its platforms, accounts, business relationships, and services from being knowingly used for money laundering, terrorist financing, fraud, corruption, sanctions evasion, or other financial crime.
The Company may conduct identity verification, business verification, beneficial-ownership verification, sanctions screening, politically exposed person screening, adverse-media review, source-of-funds review, source-of-wealth review, transaction review, or enhanced due diligence where appropriate.
The Company may rely upon appropriately qualified third-party compliance providers to conduct some or all of these procedures.
The Company may request information or documentation reasonably necessary to verify a user, business, investor, creator, brand, transaction, payment, source of funds, beneficial owner, contractual relationship, or business purpose.
Failure to provide reasonably requested compliance information may result in a transaction being delayed, restricted, rejected, or terminated.
The Company or its third-party providers may delay or place an administrative hold on a transaction where reasonably necessary to investigate suspected fraud, verify identity, confirm banking information, investigate a chargeback, verify source of funds, conduct sanctions screening, resolve a contractual dispute, respond to legal process, protect Company or customer assets, or comply with applicable law.
A compliance hold is not a forfeiture of funds.
Funds subject to a hold shall be released, returned, transferred, or otherwise handled according to the applicable agreement, law, banking requirement, provider requirement, or final resolution of the matter.
The Company reserves the right to refuse, suspend, cancel, or terminate a transaction or business relationship where the Company reasonably believes that proceeding could violate applicable law, sanctions, Company policy, contractual requirements, payment-provider requirements, banking requirements, intellectual-property rights, fraud controls, or legitimate compliance standards.
The Company may also refuse transactions involving materially false, misleading, incomplete, unverifiable, or suspicious information.
Refund eligibility depends upon the nature of the product, service, campaign, subscription, licensing arrangement, technology service, professional service, or transaction purchased.
Where a separate written agreement contains a specific refund, cancellation, termination, milestone, or payment provision, that agreement shall govern.
A customer requesting a refund should submit the request to legal@hashtaginfluencer.com or through another refund channel expressly designated by the Company.
The request should identify the customer, transaction, amount, date, service purchased, reason for the requested refund, and supporting information reasonably necessary to evaluate the request.
The Company will review refund requests in good faith.
A refund may be approved where a payment was duplicated, made in error, charged incorrectly, associated with a service the Company did not provide, required by applicable consumer-protection law, or otherwise determined by the Company to qualify for reimbursement.
Refunds ordinarily will not be provided for services already fully performed, non-refundable third-party expenses already incurred, completed professional work, consumed technology services, completed licensing periods, delivered digital services, completed campaign work, or other amounts expressly identified as non-refundable in the applicable agreement, except where applicable law requires otherwise.
Where only a portion of the contracted service has been performed, the Company may determine whether a partial refund, service credit, replacement service, corrective performance, or another commercially reasonable remedy is appropriate.
Approved refunds should ordinarily be returned through the original payment method or another legally permissible method approved by the Company and applicable payment provider.
Refund timing may be affected by banks, card networks, payment processors, currency conversion, compliance review, or other third-party processing requirements.
Nothing in this Refund Policy limits a non-waivable consumer right provided by applicable law.
Customers should contact the Company before initiating an unnecessary chargeback so that the Company has a reasonable opportunity to investigate and resolve the issue.
The Company reserves the right to provide banks, payment processors, card networks, or other authorized parties with contracts, invoices, communications, transaction records, delivery records, verification information, and other evidence reasonably necessary to respond to a payment dispute.
Fraudulent chargebacks or knowingly false payment disputes may result in suspension or termination of services and recovery of amounts lawfully owed to the Company.
The Company is committed to reviewing legitimate complaints concerning its services, transactions, privacy practices, payments, creators, campaigns, intellectual property, contractual obligations, compliance procedures, or conduct.
Complaints may be submitted to:
The complaint should contain sufficient information to permit a reasonable investigation, including the complainant's name, contact information, relevant transaction or account information, description of the issue, relevant dates, requested resolution, and supporting documentation where available.
The Company may acknowledge the complaint, request additional information, investigate the matter, consult relevant personnel or professional advisers, and provide a response or proposed resolution within a commercially reasonable period.
Material legal or compliance complaints may be referred to the Company's external legal counsel, including Dentons where applicable to the particular matter.
The Company may identify a specific responsible attorney or partner after confirming the attorney's current role, office, authority, and engagement for the relevant matter.
Until such confirmation is made, official legal correspondence should be directed to legal@hashtaginfluencer.com, which may forward the matter to the appropriate Company representative or external counsel.
Where a user, customer, creator, brand, investor, vendor, employee, contractor, partner, or other participant violates an applicable agreement, Company policy, law, intellectual-property right, compliance requirement, or payment obligation, the Company may exercise any lawful and proportionate remedy available under the applicable agreement and law.
Such remedies may include requesting corrective action, requiring additional documentation, restricting functionality, temporarily suspending an account, placing a lawful administrative hold on a transaction, declining a transaction, terminating services, terminating a contractual relationship, cancelling access rights, withholding unpaid Company services, recovering amounts lawfully owed, seeking reimbursement, offsetting amounts where contractually and legally permitted, referring a matter to a third-party payment provider, preserving evidence, conducting an internal investigation, notifying insurers, referring a matter to counsel, pursuing mediation or arbitration where agreed, seeking injunctive relief, pursuing damages, or commencing appropriate judicial proceedings.
Where legally required or appropriate, the Company may cooperate with banks, payment providers, regulators, courts, law-enforcement authorities, governmental agencies, auditors, or other competent authorities.
No remedy provision authorizes the Company to confiscate, retain, freeze, or dispose of another person's funds contrary to applicable law or contractual rights.
Customers and users may submit complaints, request correction of an error, request an eligible refund, challenge an unauthorized transaction, exercise applicable privacy rights, request contractual dispute resolution, or pursue other remedies available under the applicable agreement or law.
Nothing in these Terms eliminates or restricts rights that cannot lawfully be waived.
Where the Company administers a relationship between a creator and brand, the Company may provide documentation, transaction records, campaign records, verification records, or other administrative assistance to help resolve a dispute.
Unless expressly agreed otherwise, the Company does not guarantee the conduct, performance, solvency, audience, results, sales, engagement, or contractual performance of an independent creator, brand, advertiser, customer, vendor, or other third party.
Transactions conducted through a third-party bank, payment provider, HR provider, payroll provider, Employer of Record, compliance provider, or other external service may also be governed by that provider's terms, refund rules, dispute procedures, compliance requirements, and legal obligations.
Where the third party controls the disputed funds or transaction, the Company may be required to coordinate the remedy through that provider.
The Company may correct clerical, accounting, billing, technical, or administrative errors.
Where an error results in an overpayment or underpayment, the Company may make an appropriate correcting payment, refund, credit, invoice, or accounting adjustment consistent with applicable law and the governing agreement.
Privacy complaints and requests may be submitted to legal@hashtaginfluencer.com.
The Company shall review applicable privacy rights according to the jurisdiction governing the relevant individual and processing activity.
The Company may require reasonable identity verification before disclosing, correcting, deleting, transferring, or otherwise acting upon personal information.
Suspected unauthorized account access, payment fraud, identity theft, data compromise, or other security incidents should be reported promptly to the Company.
The Company may restrict access, reset credentials, preserve records, notify relevant providers, investigate the incident, and take other appropriate remedial action.
Where legally required, the Company shall provide notifications to affected individuals, governmental authorities, regulators, or other required parties.
No Company representative, creator, intermediary, consultant, vendor, franchisee, licensee, or other person acting for the Company may offer, promise, authorize, request, receive, or provide a bribe, kickback, improper payment, or other unlawful benefit.
Transactions involving government officials, licenses, permits, international operations, mining rights, franchises, agents, consultants, or other higher-risk relationships may be subject to enhanced review.
Employees, contractors, creators, partners, and other stakeholders may report suspected fraud, corruption, misuse of funds, financial crime, material privacy violations, or other serious misconduct to legal@hashtaginfluencer.com.
The Company prohibits retaliation against a person for making a good-faith report of suspected unlawful conduct.
Knowingly making a materially false allegation may itself constitute misconduct.
Material transactions involving founders, directors, managers, officers, employees, members, shareholders, family members, controlled entities, or other related parties should be disclosed and appropriately documented.
The Company may require disinterested approval, independent valuation, Board approval, legal review, investor disclosure, or other controls depending upon the transaction.
The Company intends to maintain commercially reasonable records of material receipts, disbursements, contracts, invoices, investment capital, intellectual-property transactions, payments, refunds, chargebacks, complaints, approvals, and other material corporate transactions.
Where appropriate, technology may be used to create tamper-resistant or independently verifiable records.
Such technology is used for accountability and transparency and does not, by itself, make the Company a cryptocurrency company or financial institution.
Where commercially practicable, the Company shall separate responsibility for initiating, approving, releasing, reconciling, and reviewing material payments.
Material transactions may require multiple approvals based upon the Company's internal authorization matrix.
Changes to material beneficiary or banking instructions may be subject to independent verification.
The Company may use telephone verification, multifactor authentication, written confirmation, identity verification, bank verification, or other controls before approving a material change to payment instructions.
The Company may conduct reasonable due diligence on material payment providers, HR providers, payroll providers, compliance providers, brokers, professional advisers, technology vendors, franchise partners, agents, intermediaries, and other important service providers.
The level of review may depend upon the provider's function, access to data or funds, jurisdiction, regulatory status, transaction value, and associated risk.
The Company may maintain alternative banking, technology, communication, data-recovery, payment, and operational arrangements intended to preserve business continuity following an outage, cyber incident, banking disruption, natural disaster, provider failure, or other material interruption.
The Company cannot guarantee that a bank, payment provider, payroll company, HR provider, card network, correspondent bank, government authority, or other independent third party will approve or complete a particular transaction.
A transaction may be delayed or rejected because of regulatory review, sanctions screening, banking policy, insufficient documentation, technical failure, fraud prevention, jurisdictional restrictions, or other circumstances outside the Company's reasonable control.
Nothing provided through HashtagInfluencer.com, Hashtag Bio LLC, or an affiliated service should be interpreted as personalized investment, securities, banking, cryptocurrency, tax, or financial advice unless expressly provided through a separately authorized professional engagement.
The Company is not organized for the principal purpose of buying, selling, exchanging, brokering, speculating in, or operating an exchange for cryptocurrencies or virtual currencies.
If blockchain, tokenization, digital wallets, stablecoins, or other digital-asset technologies are considered or used in the future, the applicable activity shall be separately evaluated for regulatory compliance before implementation.
The Company may decline to implement a proposed digital-asset activity where management or counsel determines that licensing, securities, commodities, money-transmission, sanctions, tax, custody, or other regulatory requirements have not been satisfactorily addressed.
The Company shall periodically review its products, payment flows, treasury operations, geographic expansion, and third-party relationships to determine whether a change in business activities creates additional regulatory obligations.
Where a license or registration becomes legally required, the Company shall obtain the applicable authorization, modify the service, use an appropriately licensed third-party provider, or discontinue the regulated activity until the legal requirements are satisfied.
The Company intends to cooperate with legitimate requests from its banks, payment providers, auditors, legal counsel, regulators, and governmental authorities.
The Company may provide information concerning beneficial ownership, source of funds, investment capital, use of funds, transactions, counterparties, contracts, intellectual property, corporate authorization, and other matters where disclosure is legally permitted and reasonably necessary.
These provisions should be read together with the Company's Privacy Policy, Terms of Use, Refund Policy, AML and Financial Crime Policy, Sanctions Policy, Use of Funds Policy, applicable customer or creator agreement, investment agreement, campaign agreement, licensing agreement, and other applicable definitive contracts.
Where a separately executed definitive agreement contains more specific commercial terms, the definitive agreement shall generally govern the contractual relationship, subject to applicable law.
Questions, complaints, refund requests, privacy requests, compliance concerns, suspected fraud, security concerns, and legal notices may initially be submitted to:
Hashtag Influencer / Hashtag Bio LLC
Legal & Compliance
Email: legal@hashtaginfluencer.com
Material matters may be referred to the Company's appropriate officers, Board representatives, compliance personnel, insurers, auditors, external legal counsel, including Dentons where engaged for the relevant matter, or competent governmental authorities as appropriate.
Hashtag Influencer and Hashtag Bio LLC are built around creator accountability, transparency, verification, responsible commercial relationships, and auditable business practices.
The Company's use of banks, licensed payment providers, HR and workforce-compliance providers, professional advisers, technology providers, and other third-party specialists is intended to allow the Company to focus on its core creator-economy business while regulated or specialized functions are performed by appropriately qualified third parties where required.
The Company does not seek to avoid financial regulation by outsourcing regulated activities. Where applicable law requires the Company itself to obtain a license, registration, authorization, or approval, the use of a third-party provider shall not be treated as a substitute for such requirement.
The Company's policy is to conduct business transparently, document material transactions, protect creator and customer interests, maintain appropriate financial controls, investigate legitimate complaints, provide appropriate remedies, cooperate with lawful regulatory requirements, and continuously improve its compliance framework as the business expands.