DISCLOSURES AND DETAILS

Disclaimer:

Augury Research is not a registered investment adviser and the information on this website is for information, discussion, and educational purposes only. It does not constitute a recommendation to purchase or sell any financial instruments or other products. Investment decisions should not be made with this website and one should take into account the investment objectives or financial situation of any particular person or institution.

Investors should obtain advice based on their own individual circumstances from their own tax, financial, legal, and other advisers about the risks and merits of any transaction before making an investment decision, and only make such decisions on the basis of the investor’s own objectives, experience, and resources. The information contained on this site is based on generally-available information and, although obtained from sources believed to be reliable, its accuracy and completeness cannot be assured, and such information may be incomplete or condensed. Investments in financial instruments or other products carry significant risk, including the possible total loss of the principal amount invested. This website does not purport to identify all the risks or material considerations that may be associated with entering into any transaction. This website accepts no liability for any loss (whether direct, indirect, or consequential) that may arise from any use of the information contained in or derived from this website.

By downloading from, or viewing material on, this website you agree to the following Terms of Service. You agree that the use of AUGURY RESEARCH LLC’s research is at your own risk. In no event will you hold AUGURY RESEARCH LLC or any affiliated party liable for any direct or indirect trading losses caused by any information on this website. This report is not investment advice or a recommendation or solicitation to buy any securities. AUGURY RESEARCH LLC is not registered as an investment advisor in any jurisdiction. 

You agree to do your own research and due diligence before making any investment decision with respect to securities discussed herein. You represent to AUGURY RESEARCH LLC that you have sufficient investment sophistication to critically assess the information, analysis, and opinions in this report. You further agree that you will not communicate the contents of this report to any other person unless that person has agreed to be bound by these same terms of service.

You should assume that as of the publication date of the reports found on this website, AUGURY RESEARCH LLC stands to profit in the event the issuer’s stock declines. We may buy, sell, cover, or otherwise change the form or substance of its position in the issuer. AUGURY RESEARCH LLC disclaims any obligation to notify the market of any such changes.

Our research and reports include forward-looking statements, estimates, projections, and opinions prepared with respect to, among other things, certain accounting, legal, and regulatory issues the issuer faces and the potential impact of those issues on its future business, financial condition, and results of operations, as well as more generally, the issuer’s anticipated operating performance, access to capital markets, market conditions, assets, and liabilities. Such statements, estimates, projections, and opinions may prove to be substantially inaccurate and are inherently subject to significant risks and uncertainties beyond AUGURY RESEARCH LLC’s control.

Our research and reports express our opinions, which we have based upon generally available information, field research, inferences, and deductions through our due diligence and analytical process. AUGURY RESEARCH LLC believes all information contained herein is accurate and reliable and has been obtained from public sources we believe to be accurate and reliable. However, such information is presented “as is,” without warranty of any kind, whether express or implied. AUGURY RESEARCH LLC, makes no representation, express or implied, as to the accuracy, timeliness, or completeness of any such information or with regard to the results to be obtained from its use. All expressions of opinion are subject to change without notice, and AUGURY RESEARCH LLC is not obligated to update or supplement any reports or any of the information, analysis, and opinion contained in them.

Legal

If you would like to adjust, access, remove, or opt-out your personal data at any time, please email your request to us directly at tyler.dupont@auguryresearch.com.

Terms of Service

Last Revised: October 6, 2023

The following terms and conditions (the “Terms of Service” or “Agreement”) constitute an agreement between you, whether as a casual visitor or a registered user (“User”, “you” or “your”) and Augury Research LLC, and its affiliates, successors and assigns (“Augury Research”, “us”, “our” or ‘we”), the owner and operator of the www.auguryresearch.com, auguryinvest.com, and auguryinvest.chat websites (collectively, the “Sites”) and all content and features contained therein, as well as Augury Research newsletter, email notifications or any related applications provided by us (collectively, the “Services”), regarding your use of Augury Research LLC and/or Services. BY ACCESSING THE SITE, UTILIZING ANY OF THE SERVICES AND/OR REGISTERING WITH US, YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THESE TERMS OF SERVICE INCLUDING OUR PRIVACY POLICY, WHICH IS INCORPORATED HEREIN BY REFERENCE.

Modifications to the Terms of Service

Augury Research, in its sole and absolute discretion, may make changes or modifications to the Site or to this Agreement (including any policies or agreements which are incorporated by reference herein) at any time and without prior notice to you, and such changes or modifications shall be effective immediately upon posting to this Site. You acknowledge and agree that (i) Augury Research may notify you of such changes or modifications by posting them to this Site and (ii) your use of this Site or the Services after such changes or modifications have been made (as indicated by the “Last Revised” date at the top of this page) shall constitute your acceptance of this Agreement as last revised. In addition, Augury Research may occasionally notify you of upcoming changes or modifications to this Agreement by email. We, therefore, recommend that you keep your account information, including, but not limited to, your email address, current.

Eligibility; Registration

This Site and the Services found at this Site are available only to Users who can form legally binding contracts under applicable law. By using this Site or the Services found at this Site, you represent and warrant that you are at least eighteen (18) years of age.

If you are visiting this Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information (including your User information) across international boundaries. By visiting this Site and communicating electronically with us, you consent to such transfers.

You may be asked to register in order to use certain Services including, but not limited to, Augury Research’s newsletters. You agree to provide accurate, current, and complete information about yourself as requested or directed on the Services and to promptly update this information to maintain its accuracy. Augury Research has the right to suspend or terminate your registration and to refuse any and all current or future use of the Services if it suspects that such information is inaccurate or incomplete.

Your Use of the Site and Services

You acknowledge and agree that:

 

Your use of the Site and the Services, including any content you submit, will comply with this Agreement and all applicable local, state, national and international laws, rules and regulations. You will not impersonate another User, or collect or harvest (or permit anyone else to collect or harvest) any User Content (as defined below) or any non-public or personally identifiable information about another User or any other person or entity without their express prior written consent. You will not use this Site or the Services in a manner (as determined by Augury Research in its sole and absolute discretion): that is illegal, infringing, defamatory, harassing, abusive; that violates the privacy or publicity rights of another User or any other third party, or that is otherwise objectionable. You will not use this Site or the Services for hate speech, hate crimes or violence. You will not use this Site or the Services: to send spam or other unsolicited bulk email; for computer or network hacking or cracking; or to transmit any viruses, worms, bugs, Trojan horses or other code, files or programs designed to, or capable of, disrupting, damaging or limiting the functionality or security of the Site or the Services. You will not copy or distribute in any medium any part of the Site or the Services, except where expressly authorized by Augury Research. You will not access Augury Research Content or User Content (as those terms are defined below) through any technology or means other than through this Site itself, or as Augury Research may designate. You will not use this Site or the Services found at this Site, including any of Augury Research’s related technologies, for any commercial use without Augury Research’s express prior written consent.

Augury Research reserves the right to modify, change, or discontinue any aspect of this Site or the Services found at this Site at any time.

Intellectual Property

The content on this Site and the Services found at this Site, including without limitation the text (such as the articles found on our blog or in our daily newsletter), software, scripts, source code, API, graphics, photos, sounds, music, videos and interactive features and the trademarks, service marks and logos contained therein (“Augury Research Content”), are owned by or licensed to Augury Research in perpetuity, and are subject to copyright, trademark, and/or patent protection in the United States and foreign countries, and other intellectual property rights under United States and foreign laws. Augury Research Content is provided to you “as is”, “as available” and “with all faults” for your information and personal, non-commercial use only and may not be downloaded, copied, reproduced, distributed, transmitted, broadcast, displayed, sold, licensed, or otherwise exploited for any purposes whatsoever without the express prior written consent of Augury Research. No right or license under any copyright, trademark, patent, or other proprietary right or license is granted by this Agreement. Augury Research reserves all rights not expressly granted in and to Augury Research Content, this Site and the Services found at this Site, and this Agreement do not transfer ownership of any of these rights.

The Site and the Services have been specially designed to present Augury Research Content in a unique format and appearance. We are concerned about the integrity of Augury Research Content when it is viewed in a setting created by a third party that includes advertising or other materials that we have not authorized to be displayed with our content. Neither you nor any third party shall make use of Augury Research Content in any manner that constitutes an infringement of our rights, including copyright, or that has not been authorized by us.

Our Use of User Content

Some of the features of this Site or the Services found at this Site may allow Users to view, post, publish or share their ideas, opinions, preferences or feedback (e.g., through a “like” or “comment” function) relating to Augury Research’s news articles or current events (“User Content”). By posting or publishing User Content to this Site or to the Services found at this Site, you represent and warrant to Augury Research that: (i) you have all necessary rights to distribute User Content, either because you are the sole author and owner of the User Content and have the right to distribute the same, or because you have the appropriate distribution rights, licenses, consents, and/or permissions to use, in writing, from the copyright or other owner of the User Content; and (ii) you do not violate the rights of any third party. You shall be solely responsible for any and all of your User Content and the consequences of, and requirements for, distributing it.

Augury Research has no obligation, either express or implied, to treat your User Content as confidential, to develop or use your User Content and no compensation is due to you or to anyone else for any intentional or unintentional use of your User Content. You acknowledge and agree that Augury Research may be working on the same or similar content, it may already know of such content from other sources, it may simply wish to develop this (or similar) content on its own, or it may have taken / will take some other action.

If you post or publish your User Content to this Site, you authorize Augury Research to use the intellectual property and other proprietary rights in and to your User Content to enable inclusion and use of the User Content in the manner contemplated by this Site and this Agreement. Accordingly, you hereby grant Augury Research a worldwide, non-exclusive, royalty-free, sublicensable (through multiple tiers), and transferable license to use, reproduce, distribute, prepare derivative works of, combine with other works, display, and perform your User Content in connection with this Site and Augury Research’s business, including without limitation for promoting and redistributing all or part of this Site in any media formats and through any media channels without restrictions of any kind and without payment or other consideration of any kind, or permission or notification, to you or any third party. The above licenses granted by you in your User Content terminate within a commercially reasonable time after you remove or delete your User Content from this Site. You understand and agree, however, that Augury Research may retain (but not distribute, display, or perform) server copies of your User Content that have been removed or deleted unless you expressly request full removal of your User Content.

With your permission, Augury Research may access your email contacts and send emails on your behalf. We only store the email addresses you share, and only for email sending purposes.

Our Monitoring of User Content

Augury Research reserves the right, but has no obligation, to pre-screen User Content and decide whether any item of User Content is appropriate and/or complies with this Agreement. Augury Research may remove any item of User Content and/or terminate a User’s access to this Site or the Services found at this Site for posting or publishing any material in violation of this Agreement, or for otherwise violating this Agreement (as determined by Augury Research in its sole and absolute discretion), at any time and without prior notice. If Augury Research terminates your access to this Site or the Services found at this Site, Augury Research may, in its sole and absolute discretion, remove and destroy any data and files stored by you on its servers.

Copyright Infringement

Augury Research has adopted the following general policy toward copyright infringement in accordance with the Digital Millennium Copyright Act (“DMCA”). It is Augury Research’s policy to (a) block access to or remove material that it believes in good faith to be copyrighted material that has been illegally copied and distributed by any of our advertisers, affiliates, content providers or Users; and (b) remove and discontinue service to repeat offenders.

Written Notification. Augury Research will respond to notices of alleged infringement regarding third-party material sent pursuant to and in accordance with the DMCA, which may include Augury Research removing or disabling access to Third Party material claimed to be the subject of infringement or other activity. Written notification must be submitted to the Designated Agent at the address identified in Address for Notice section below. All notices sent to Augury Research regarding matters other than informing Augury Research that a party’s copyrighted material may have been infringed as a result of third party materials will not receive a response through this process. In order to be effective, your infringement notification must include the following:

A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed; Identification of the copyrighted work claimed to have been infringed, or if multiple copyrighted works at a single web site are covered by a single notification, a representative list of such works at that web site; Identification of the material (i.e., the third party materials) that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit Augury Research to locate the material; Information reasonably sufficient to permit Augury Research to contact the complaining party, such as an address, telephone number, and if available, an electronic mail address at which the complaining party may be contacted; A statement, as follows: “I have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law”; and A statement, as follows: “The information in this notification is accurate, and under penalty of perjury, I swear that I am the copyright owner or that I am authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.”

Upon receipt of a valid written notification containing the information as outlined above, Augury Research shall, (1) remove or disable access to the Third Party Content that is alleged to be infringing; (2) forward the written notification to the alleged infringer (the “Subscriber”); (3) take reasonable steps to promptly notify the Subscriber that it has removed or disabled access to the Third Party Content.

Counter Notification. To be effective, a Counter Notification must be a written communication provided to Augury Research’s Designated Agent that includes substantially the following:

A physical or electronic signature of the Subscriber; Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled; A statement, as follows: “I swear under penalty of perjury that it is my good faith belief that the material identified above was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled”; and The Subscriber’s name, address, and telephone number, and a statement that the Subscriber consents to the jurisdiction of Federal District Court for the judicial district in which the Subscriber’s address is located, or if the Subscriber’s address is outside of the United States, for any judicial district in which Augury Research may be found, and that the Subscriber will accept service of process from the person who provided notification or an agent of such person.

Upon receipt of a valid Counter Notification containing the information as outlined above, the DMCA provides that the removed material will be restored or access re-enabled and Augury Research will comply with this requirement within a reasonable time (or as otherwise required by law), provided Augury Research’s Designated Agent has not received notice from the original complaining party that an action has been filed seeking a court order to restrain Subscriber from engaging in infringing activity relating to the material on Augury Research’s network or system.

Links to Third-Party Websites

This Site and the Services found at this Site may contain links to third-party websites that are not owned or controlled by Augury Research. These links are provided solely as a convenience to you and do not constitute an endorsement by Augury Research of the content on such websites nor of the business practices of those operating those websites. Augury Research has no control over and assumes no responsibility for the content, terms, and conditions, privacy policies, or practices of any third-party websites. In addition, Augury Research does not censor or edit the content of any third-party websites. By using this Site or the Services found at this Site, you expressly release Augury Research from any and all liability arising from your use of any third-party website. Accordingly, Augury Research encourages you to be aware when you leave this Site or the Services found at this Site and to review the terms and conditions, privacy policies, and other governing documents of each other website that you may visit.

Indemnity

To the maximum extent permitted by law, you agree to indemnify and hold harmless Augury Research, its and affiliates, and their directors, officers, managers, employees, shareholders, agents, and licensors, from and against all claims, demands, disputes, losses, expenses, damages, and costs, including reasonable attorneys’ fees, arising out of or in relation to these Terms or your use of the Services. Augury Research reserves the right to assume the exclusive defense of any claim for which we are entitled to indemnification under this Section. In such event, you shall provide us with such cooperation as is reasonably requested by us.

Paid Services

Billing Policies: Certain aspects of the Service may be provided for a fee or other charge. If you elect to use paid aspects of the Service, you agree to the Pricing and Payment Terms, as we may update them from time to time. Augury Research LLC. may add new services for additional fees and charges, or amend fees and charges for existing services, at any time in its sole discretion. Any change to our pricing or payment terms shall become effective in the billing cycle following notice of such change to you as provided in the Pricing and Payment Terms.

You may cancel your Augury Research LLC account at any time; however, there are no refunds for cancellation after the date of purchase. If you cancel before the end of your billing cycle you will have access to your account for the remainder of the billing cycle. In the event that Augury Research LLC suspends or terminates your account or this Agreement for your breach of this Agreement, you understand and agree that you shall receive no refund or exchange for any unused time on a subscription, any license or subscription fees for any portion of the Service, any content or data associated with your account, or for anything else.

4.C. Payment Information; Taxes.

All information that you provide in connection with a purchase or transaction or other monetary transaction interaction with the Service must be accurate, complete, and current. You agree to pay all charges incurred by users of your credit card, debit card, or other payment method used in connection with a purchase or transaction or other monetary transaction interaction with the Service at the prices in effect when such charges are incurred. You will pay any applicable taxes, if any, relating to any such purchases, transactions or other monetary transaction interactions.

No Professional Advice

If the Service provides professional information (for example, financial, legal or medical), such information is for informational purposes only and should not be construed as professional advice. No action should be taken based upon any information contained in the Service. You should seek independent professional advice from a person who is licensed and/or qualified in the applicable area.

Disclaimer of Warranties and Limitation of Liability

Your access to and use of these Services is at your sole risk. If you are dissatisfied with any of the materials contained on the Site or in the Services, or with any of these Terms, your sole and exclusive remedy is to discontinue accessing and using the Site and/or Services.

THE SERVICES ARE AVAILABLE “AS IS.” AUGURY RESEARCH DOES NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE. THERE MAY BE DELAYS, OMISSIONS, INTERRUPTIONS, AND INACCURACIES IN THE NEWS, INFORMATION, OR OTHER MATERIALS AVAILABLE THROUGH THE SERVICES. WE DO NOT MAKE ANY WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION, THOSE OF NON-INFRINGEMENT, MERCHANTABILITY, AND FITNESS FOR A PARTICULAR PURPOSE, WITH RESPECT TO THE SERVICES OR ANY INFORMATION OR GOODS THAT ARE AVAILABLE OR ADVERTISED OR SOLD THROUGH THE SERVICES. WE DO NOT PROVIDE OR AUTHORIZE THE PROVISION OF MEDICAL, LEGAL, OR OTHER PROFESSIONAL ADVICE THROUGH THE SERVICES, AND SO WE DISCLAIM ANY RESPONSIBILITY FOR THE ACCURACY OR RELIABILITY OF MEDICAL, LEGAL, OR OTHER PROFESSIONAL INFORMATION THAT IS CONTAINED WITHIN THE SERVICES; RATHER THAN RELYING ON THIS INFORMATION, YOU SHOULD SEEK ADVICE FROM A QUALIFIED PROFESSIONAL. WE DO NOT MAKE ANY REPRESENTATIONS REGARDING, NOR DO WE ENDORSE THE ACCURACY, COMPLETENESS, TIMELINESS, OR RELIABILITY OF ANY ADVICE, OPINION, STATEMENT, OR OTHER MATERIAL OR DATABASE DISPLAYED, UPLOADED, OR DISTRIBUTED IN THE SERVICES OR AVAILABLE THROUGH LINKS IN THE SERVICES. WE RESERVE THE RIGHT TO CORRECT ANY ERRORS OR OMISSIONS IN THE SERVICES. ALTHOUGH WE INTEND TO TAKE REASONABLE STEPS TO PREVENT THE INTRODUCTION OF VIRUSES, WORMS, “TROJAN HORSES,” OR OTHER DESTRUCTIVE MATERIALS TO THE SERVICES, WE DO NOT GUARANTEE OR WARRANT THAT THE SERVICES OR MATERIALS THAT MAY BE DOWNLOADED FROM THE SERVICES DO NOT CONTAIN SUCH DESTRUCTIVE FEATURES. WE ARE NOT LIABLE FOR ANY DAMAGES OR HARM ATTRIBUTABLE TO SUCH FEATURES. IF YOU RELY ON THE SERVICES OR ANY MATERIALS AVAILABLE THROUGH THE SERVICES, YOU DO SO SOLELY AT YOUR OWN RISK.

Augury Research, its affiliates, and their directors, officers, managers, employees, shareholders, agents, and licensors are not liable for incidental, indirect, consequential, special, punitive, or exemplary damages of any kind, including lost revenues or profits, loss of business, or loss of data, in any way related to the Services or for any claim, loss, or injury based on errors, omissions, interruptions, or other inaccuracies in the Services (including without limitation as a result of breach of any warranty or other term provided in these Terms). Any claim against us shall be limited to the amount you paid, if any, for use of the Services.

Limitation of Liability in Certain States

CERTAIN STATE LAWS IN THE UNITED STATES DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTIES OR THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES. IF THESE LAWS APPLY TO YOU, SOME OR ALL OF THE ABOVE DISCLAIMERS, EXCLUSIONS OR LIMITATIONS MAY NOT APPLY TO YOU, AND YOU MIGHT HAVE ADDITIONAL RIGHTS. IN SUCH STATES, OUR LIABILITY AND THAT OF OUR THIRD PARTY CONTENT PROVIDERS AND OUR AND THEIR RESPECTIVE AGENTS SHALL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW.

Arbitration

Except for disputes arising from an alleged violation of intellectual property rights or breach of confidentiality, for which the injured party may suffer irreparable harm and may seek a restraining order, preliminary injunctive relief, an injunction, specific performance or other equitable relief and/or legal remedies, and actions to enforce the decisions of the arbitrators, for which action may be taken in any court of competent jurisdiction, in the County of West Palm Beach, in the State of Florida, and you hereby consent to (and waive all defenses of lack of personal jurisdiction and forum non conveniens with respect to) waive the right to trial by jury in any such action or proceeding that takes place relating to or arising out of this Agreement, all disputes arising out of or related to this Agreement, including the scope, the construction or application of this Agreement, shall be resolved by arbitration in accordance with the commercial arbitration rules of the American Arbitration Association then in force. Any controversy or claim shall be arbitrated on an individual basis and shall not be consolidated in any arbitration with any claim or controversy of any other party, unless agreed to by Augury Research at it sole discretion. The arbitration hearings and all meetings pursuant to this section shall be held in West Palm Beach, in the State of Florida. If the parties cannot agree upon a single arbitrator within twenty (20) calendar days after demand by either of them, each party shall select one arbitrator knowledgeable about Internet commerce in Florida, and notify the other of its selection, and such two arbitrators shall select a third from a list of arbitrators (with knowledge of the Internet industry) qualified by the American Arbitration Association in Florida. If this procedure for selecting arbitrators fails, then a neutral arbitrator based in New York with knowledge of Internet commerce in Florida shall be selected by the American Arbitration Association to resolve the dispute. The arbitrator(s) shall conduct a hearing within sixty (60) days after their selection. A majority of the arbitrators (if there is more than one pursuant to this clause) shall determine the decision/award, which shall be rendered within ten (10) days after the completion of the hearing. The decision of the arbitrator(s) shall be final and binding upon the parties both as to law and to fact, and shall not be appealable to any court in any jurisdiction. The parties shall share the expenses of the arbitrators equally. Nothing in any indemnification provision hereunder shall be construed as having any bearing on the award of attorney’s’ fees or arbitrators’ fees under this section.

Messaging Policy

Introduction

This Messaging Policy applies to SMS, MMS, and WhatsApp messaging channels used by Augury Research. We aim to ensure that messages reach recipients without hindrance from filtering or blockers. To achieve this, we work to prevent and eliminate unwanted messages, ensuring compliance with applicable laws, communication industry guidelines, and standards of fairness and decency.

Scope

All messaging facilitated through our platform is classified as Application-to-Person (A2P) messaging and is subject to this policy, which includes regulations and prohibitions on:

  • Consent (opt-in)

  • Revocation of consent (opt-out)

  • Sender identification

  • Messaging usage

  • Filtering evasion

  • Enforcement

This policy applies to all customers using Augury Research's messaging channels. Compliance with this policy is mandatory for all messaging activities.

Consent / Opt-In

What is Proper Consent?

  • Consent must not be procured, transacted, or traded, e.g., it cannot be secured through third-party phone lists.

  • Consent requirements include obtaining agreement from the recipient before sending the first message. The recipient must be made aware of the type of messages they will receive. Consent records, such as signed documents or timestamps, must be kept.

Consent Requirements:

  • Consent must be obtained before sending the first message.

  • An initial message should be sent within a reasonable timeframe after obtaining consent, or reaffirmation of consent is needed.

  • Consent is specific to the sender and the particular campaign; it cannot be used for other brands or campaigns.

  • Proof of opt-in consent must be retained according to local regulations or best practices, even after the end-user opts out.

Alternative Consent Scenarios:

  1. Contact Initiated by an Individual:

    • If an individual initiates contact, you may respond to their message. The individual’s inbound message constitutes consent for that conversation only.

  2. Informational Content Based on Prior Relationship:

    • Messages can be sent to individuals with whom you have a prior relationship, provided they have given their phone number, taken an action to trigger communication, and have not opted out. Examples include appointment reminders, receipts, one-time passwords, and order confirmations.

Periodic Messages and Ongoing Consent:

  • For ongoing messages, offer a clear reminder of how to unsubscribe using standard opt-out language and respect the recipient’s preferences regarding frequency of contact.

  • Reconfirm consent periodically as required by local regulations and best practices.

Identifying Yourself as the Sender

  • Every message must clearly identify the sender, except in follow-up messages of an ongoing conversation.

Opt-Out

  • The initial message must include opt-out instructions, such as "Reply STOP to unsubscribe."

  • Recipients must be able to revoke consent at any time using standard opt-out keywords (STOP, UNSUBSCRIBE, CANCEL, END, QUIT).

  • After opting out, one final message confirming the opt-out may be sent, but no further messages are allowed unless consent is obtained again.

Usage Limitations

Content Restrictions:

  • Prohibited content includes anything illegal, harmful, unwanted, inappropriate, or posing a threat to the public, even if legally permissible.

  • Examples include messages related to cannabis, prescription medication offers, hate speech, harassment, fraud, malicious content, and content designed to evade detection.

Prohibited Practices:

  • Evading detection mechanisms, such as intentionally misspelt words or non-standard opt-out phrases.

  • Snowshoeing, or spreading similar messages across many phone numbers to evade detection.

  • Sending messages inconsistent with the registered use case for 10DLC campaigns.

Violation Detection and Handling

  • We work in good faith to bring customers back into compliance when violations are detected. However, we reserve the right to suspend or remove access for non-compliance or legal violations, sometimes with limited notice for serious violations.

Recent Updates

  • Effective July 5, 2023, messages to US phone numbers from unregistered 10DLC numbers will be blocked gradually, with a complete block after August 31, 2023.

  • A new vetting process for A2P Campaign registrations includes a one-time $15 campaign vetting fee, effective January 26, 2023.

A2P 10DLC Registration

  • Businesses must register for A2P 10DLC to send long-code messages to US carriers.

  • Registration involves brand and campaign registrations, which influence message throughput based on a Trust Score assigned by The Campaign Registry.

Best Practices for Campaign Approval

  • Ensure campaign registrations are thorough and accurate.

  • Avoid prohibited content and practices.

  • Provide real, working websites for opt-in.

  • Collect consumer consent appropriately and include opt-out language in sample messages.

Miscellaneous

Nothing in this Agreement shall be deemed to confer any third-party rights or benefits. This Agreement shall be binding upon and inure to the benefit of the parties hereto and their respective heirs, successors and assigns. This Agreement shall be governed by and construed in accordance with the laws of the State of Florida without regard to conflict of laws principles. The titles and headings of this Agreement are for convenience and ease of reference only and shall not be utilized in any way to construe or interpret the agreement of the parties as otherwise set forth herein. Each covenant and agreement in this Agreement shall be construed for all purposes to be a separate and independent covenant or agreement. If a court of competent jurisdiction holds any provision (or portion of a provision) of this Agreement to be illegal, invalid, or otherwise unenforceable, the remaining provisions (or portions of provisions) of this Agreement shall not be affected thereby and shall be found to be valid and enforceable to the fullest extent permitted by law.

Contact Information

If you have any questions about this Agreement, please contact us via email tyler.dupont@auguryresearch or regular mail at the following address:

Augury Research LLC
455 NE 5th Ave., Suite D 238,
Delray Beach, FL 33483-08

Privacy Policy

Last Revised: October 9, 2019

Augury Research LLC (“Augury Research” “we” or “us”) is the owner and operator of the Site and the provider of the Services. Augury Research respects your privacy, and we created this privacy policy (the “Policy”) to explain how we collect, use and disclose your information when you access the Site and use the Services. The Policy is only applicable to our Site and our Services and not to any other website, service or online platform. Capitalized terms that are not defined in this Policy have the meaning given them in our Terms of Service. BY ACCESSING THE SITE, UTILIZING ANY OF THE SERVICES AND/OR REGISTERING WITH US, YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THIS POLICY, INCLUDING OUR TERMS OF SERVICE, WHICH ARE INCORPORATED HEREIN BY REFERENCE.

Types of Information Collected

Personal Information

Augury Research may ask you for some or all of the following types of information which may be identifiable to you when you register for our services, access various content or features, or directly contact the site: (i) contact information, such as your email address and name; (ii) your age; and (iii) information for the purpose of authenticating yourself or your account if we have reason to believe, in our sole discretion, that you may be violating site policies or for any other reason we deem necessary (collectively “Personal Information”). You are responsible for ensuring the accuracy of all Personal Information you submit to Augury Research.

We collect and store all Personal Information you submit to us voluntarily through registering with us or uploading or posting User Content through the Site or Services. If you are signed into your Tumblr, Twitter or Facebook account and you “like” or “comment” on Augury Research Content (such as the articles found on our blog) or other User Content, your Tumblr, Twitter or Facebook username will be displayed and so become available to the public. You agree that your username, likes, feedback, and any associated comments may become public information; we therefore urge you to exercise caution when deciding to disclose any Personal Information on the Site or through the Services.

Non-Personal Information

We may utilize cookies and other technologies, such as, web beacons (also known as “clear gifs” and “pixel tags”) to recognize you, customize your experience, and serve advertisements. Cookies are very small files placed on your computer, and they allow us to count the number of visitors to Augury Research and distinguish repeat visitors from new visitors. They also allow us to save User preferences and track User trends. We do not link cookies or web beacons to any Personal Information. We may also enable advertisers (such as AdRoll) and ad servers to promote third party products and/or services by placing advertisements on Augury Research. These advertisers and ad servers may use cookies and/or web beacons to monitor information related to served advertisements. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Policy covers the use of cookies by Augury Research and does not cover the use of cookies by any advertisers.

Information Collected Automatically

We automatically receive and collect information such as your IP address, the URLs of websites you arrive at Augury Research from or leave Augury Research to go to, your type of browser and language, access times, your email client, the content of any undeleted cookies that your browser previously accepted from us, your operating system, your mobile provider, your mobile device, and your ISP. We may use such information to better understand how Augury Research visitors use the Site, to analyze trends, administer the website, prevent fraud, and gather broad demographic information.

You can, at any time, change or withdraw your consent to the use of non-essential cookies on on our website using the link below.

Manage your consent

Our Use of Your Information

Our primary purpose in collecting information, both Personal Information and other, is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your information to:

Provide the services and customer support you request. Troubleshoot problems and prevent potentially prohibited or illegal activities. Customize, measure and improve our Services, content, and advertising. Tell you about our Services, targeted marketing, service updates, and promotional offers based on your communication preferences. Monitor and enforce our Terms of Service. Communicate with Users about products and/or services they may be interested in. Verify your eligibility to use the Site.

Our Disclosure of Your Information

Augury Research is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you. We may disclose Personal Information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.

We may also share your Personal Information with:

Service providers under contract who help with our business operations (we employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products and services to you). Certain of Augury Research’s program participants under confidentiality agreement, as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity. Other business entities, should we plan to merge with or be acquired by that business entity.

Marketing

We may combine your information with information we collect from other companies and use it to improve and personalize our services, content and advertising. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference by contacting us at tyler.dupont@auguryresearch.com.

No Spam or Spyware

We do not tolerate spam. Spamming is explicitly prohibited it by our Terms of Service. If you would like to report an incident of spamming or other unauthorized communications from other Users, please contact us at tyler.dupont@auguryresearch.com. We maintain the right to investigate such incidents and take suitable action.

Account Protection

The Personal Information we collect is stored on a secure, password-protected server and only authorized personnel have access to your information. We use industry-standard encryption technologies with respect to the receipt and transfer of Personal Information you submit. Nevertheless, despite our best efforts, no transmission over the Internet and no data storage method can be guaranteed to be safe 100% of the time. Augury Research cannot ensure or warrant the security of any information you transmit to Augury Research or guarantee that your end user data stored on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our industry standard physical, technical, or managerial safeguards. If you enter sensitive information we will encrypt such information using secure socket layer technology (SSL). The Site is hosted on servers in the United States. Accordingly, if you are located outside of the United States, the Personal Information you provide to us will be transferred to the United States. By submitting your Personal Information, you consent to its transfer and storage in the United States and its use in accordance with the purposes for which it was originally collected.

Email Communications

We may use your email to deliver Augury Research’s newsletter, as well as for other promotional (e.g., new product offerings, special offers by us) purposes. Email messages we send you may contain code that enables our database to track your usage of the emails we send you, such usage includes whether the email was opened and what links (if any) were clicked. If you send an email to us, we will collect your email address and the full content of your email, including attached files, and other information you provide. Additionally, you may be directed to third-party sites related to the topics discussed within the email message.

You may indicate your preference to opt out of receiving promotional communications by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly at tyler.dupont@auguryresearch.com. You acknowledge that it may take up to 10 days for us to process an opt-out request. Please note, however, that you cannot opt out of receiving transactional emails related to your account with us.

Third Parties

Except as otherwise expressly included in this Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others Users on our Site or on other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We are not responsible for any information we do not collect. We encourage you to ask questions before you disclose your Personal Information to others.

Children

Protecting the privacy of young children is especially important to us. For that reason, Augury Research does not knowingly collect or solicit Personal Information from anyone under the age of 13.

Changes to this Policy 

We reserve the right, at any time, to add to, change, update, or modify this Policy. Any such changes to this Policy will be posted here on our Site so we urge to please visit this page frequently. In all cases, use of information we collect is subject to the Policy in effect at the time such information is collected.