Composer Maestro Program - Terms and Conditions / Conduct Rules

Effective Date: June 11, 2025

Terms & Conditions

1.  Acceptance of the Agreement

By submitting an application to, or otherwise participating in, the Composer Maestro Program offered by Composer Securities (the “Program”), you (“Maestro,” “you,” or “your”) agree to be bound by these Terms & Conditions (the “Agreement”) and any additional guidelines, rules or policies referenced herein.  If you do not agree to all of the terms, do not participate in the Program.

Composer Securities LLC is a broker-dealer registered with the SEC and member of FINRA / SIPC. Composer Securities LLC and Composer Technologies Inc. are separate but affiliated companies. 

2.  Definitions

• “Affiliate Revenue” – the compensation payable to you for Qualified Referrals, as defined in §4.1.
• “Qualified Referral” – a new Composer user who (i) clicks your unique Maestro referral link, (ii) completes a new account registration with Composer, (iii) purchases a yearly Trading Pass subscription.
• “Content” – any posts, videos, articles, threads, live streams, or other materials you create or distribute that reference Composer, the Program, or your Maestro referral link.
• “Dashboard” – Composer’s online portal via Tolt.io where Maestros can view referral statistics and payment timeline information.

3.  Eligibility & Application

1. Minimum Age. You must be at least 18 years old and the age of majority in your jurisdiction.
2. Residency. The Program is open only to natural persons legally residing in the United States of America.
3. Account Standing. You must (i) hold or open a Composer brokerage account in good standing, and (ii) pass any applicable know‑your‑customer (KYC) or anti‑money‑laundering (AML).

4. Program Benefits & Compensation

4.1 Affiliate Revenue

• You will earn $100 USD for each Qualified Referral.
• Referral attribution is determined solely through Composer’s tracking systems
• Payouts are aggregated monthly and credited to your individual taxable Composer account or other approved method within 30 days following month‑end, provided you have accrued at least $100 USD in unpaid Affiliate Revenue. Lesser balances roll forward.
• You are responsible for any banking fees, foreign exchange costs, and all taxes associated with Affiliate Revenue.
• Earned revenue is capped at $1,000 USD under this agreement. After reaching this limit, you will need to enter into a personalized, separate agreement with Composer.

4.2 Referred User Reward

Each eligible user referred under the Program who purchases a yearly Trading Pass and deposits at least $200 USD into their Composer account within 30 days will receive a one‑time $50 USD credit applied directly to that account.

4.3 Early‑Access Features

Composer may grant you beta access to unreleased products or data (“Beta Features”). You acknowledge that Beta Features are confidential and may be modified or withdrawn at any time. Feedback you provide becomes Composer’s property without additional compensation.

4.4 Composer Swag

From time to time, Composer may ship promotional merchandise (“Swag”). Swag is offered "as‑is,” may not be exchanged for cash, and Composer is not liable for lost or delayed shipments.

4.5 Community Spotlight

High‑performing Maestros may be featured in Composer marketing channels at Composer’s sole discretion. Composer may edit, reproduce, and distribute spotlight Content without further approval.

5. Content Standards & Posting Requirements

1. Posting Cadence. At minimum, create two (2) original pieces of Content per calendar month on any of: X (Twitter), LinkedIn, YouTube, Substack, Reddit, TikTok, TradingView, or a comparable platform.
2. Content Purpose and Focus. The primary objective of the Program is to showcase Composer’s platform features and educate audiences on algorithmic trading concepts.
3. Required Disclosures. Each post containing promotional statements or referral links must clearly disclose the material connection, e.g., “#ComposerPartner,” “Sponsored by Composer,” or similar language compliant with FTC 16 CFR §255 and applicable securities regulations. For a comprehensive understanding of your obligations, please consult the "Conduct Rules for Influencers and Brand Representatives" provided in full at the conclusion of this document.
4. Prohibited Content. You must not:
   • Provide personalized investment advice or guarantee returns;
   • Make false, misleading, or unsubstantiated claims about Composer, financial performance, or regulatory status;
   • Promote a specific Composer trading strategy
   • Violate any third‑party intellectual‑property, privacy, or platform terms.
   • For a comprehensive understanding of your obligations, please consult the "Conduct Rules for Influencers and Brand Representatives" provided in full at the conclusion of this document.
5. Quality Control & Content Pre-Approval. 

   • All Content produced in advance of posting, including, but not limited to, blog posts, advertisements, and videos, must be submitted to Composer for prior written approval before publication.

     Such Content can only be published after Composer confirms in writing that the post has been approved.

   • Dynamic, extemporaneous posts (e.g., real-time exchanges or conversations with other users) do not require advanced approval but must still comply with all disclosure and content requirements outlined in this Agreement.
   • Composer may request edits or removal of any Content it deems non‑compliant. Failure to comply within 48 hours may result in suspension (§11).
   • For a comprehensive understanding of your obligations, please consult the "Conduct Rules for Influencers and Brand Representatives" provided in full at the conclusion of this document.

6. Intellectual‑Property Rights

1. Composer IP. All Composer trademarks, logos, and proprietary materials are and remain the exclusive property of Composer. Subject to this Agreement, Composer grants you a limited, non‑exclusive, revocable license to display Composer IP solely in lawful Program‑related Content.
2. Your IP. You retain ownership of your original Content but grant Composer a perpetual, worldwide, royalty‑free license to use, reproduce, adapt, publish, translate, and distribute such Content (with attribution) for marketing and promotional purposes.

7. Compliance & Legal Disclaimers

1. No Advisory Relationship. You acknowledge you are not acting as a licensed financial advisor, broker‑dealer, or investment manager in connection with the Program.
2. Regulatory Compliance. You agree to comply with all applicable laws, including securities regulations, advertising standards, FTC endorsement guidelines, and platform‑specific rules.

8. Independent‑Contractor Status

Participation in the Program does not create any employment, joint‑venture, agency, or franchise relationship. You have no authority to bind Composer.

9. Confidentiality

You may receive non‑public information about Composer, including Beta Features, product roadmaps, or financial data (“Confidential Information”). You must protect Confidential Information using at least reasonable care and may use it only to fulfill Program obligations.

10. Taxes & Financial Responsibility

You are solely responsible for reporting and paying any federal, state, provincial, or local taxes arising from Affiliate Revenue or Swag. Consult your tax advisor.

11. Term, Suspension & Termination

1. Term. This Agreement begins on the Effective Date and continues until terminated.
2. Voluntary Termination. Either party may terminate participation at any time upon written notice.
3. Cause. Composer may suspend or terminate you immediately for (i) breach of this Agreement, (ii) non‑compliant or misleading Content, (iii) inactivity (no qualifying posts for ≥60 days), or (iv) actions that could harm Composer’s reputation.
4. Effect of Termination. Upon termination, (a) all licenses granted hereunder cease, (b) pending or future payments for unqualified referrals are forfeited, and (c) §§6, 7, 9, 12‑16 survive.

12. Representations, Warranties & Indemnity

You represent and warrant that (i) you have full right and authority to enter into this Agreement, (ii) your Content does not infringe any third‑party rights, and (iii) you will comply with all applicable laws. You agree to indemnify, defend, and hold harmless Composer, its affiliates, and their officers, directors, and employees from any claims, damages, or liabilities arising out of your breach or misconduct.

13. Limitation of Liability

To the fullest extent permitted by law, Composer will not be liable for any indirect, incidental, consequential, special, or exemplary damages arising from or relating to the Program, even if advised of the possibility of such damages. Composer’s aggregate liability will not exceed total Affiliate Revenue paid to you in the twelve (12) months preceding the claim.

14. Governing Law & Dispute Resolution

This Agreement is governed by the laws of the State of Delaware, USA, without regard to conflict‑of‑law principles. You consent to personal jurisdiction and waive any objection to venue.

15. Modifications to the Agreement

Composer may update these Terms at any time by posting the revised version to the Dashboard or emailing you. Continued participation after the effective date of changes constitutes acceptance.

16. Entire Agreement & Severability

This Agreement constitutes the entire agreement between the parties concerning the Program and supersedes all prior discussions. If any provision is found unenforceable, the remainder will remain in full force. Failure to enforce any right is not a waiver.

CONDUCT RULES FOR INFLUENCERS AND BRAND REPRESENTATIVES

Composer Securities LLC aims to ensure that communications made by our Brand Representatives are fair, balanced, and not misleading, and comply with the advertising rules that apply to us.

1. Approval Requirements

Posts that are produced in advance of posting, such as blog posts, advertisements, videos, etc. must be submitted to us and can be published only after we confirm with you in writing that the post has been approved.

Dynamic, extemporaneous posts, such as those published as part of a real-time exchange or conversation with other users, do not require our advanced approval. All posts, however, must comply with the disclosures and content requirements set below.

2. Required Disclosures 

[This section is taken directly from “Disclosures 101 for Social Media Influencers”, published by the Federal Trade Commission (FTC). For more information: FTC.gov/influencers]

If you endorse a product through social media, your endorsement message should make it obvious when you have a relationship (“material connection”) with the brand. A “material connection” to the brand includes a personal, family, or employment relationship or a financial relationship – such as the brand paying you or giving you free or discounted products or services.Telling your followers about these kinds of relationships is important because it helps keep your recommendations honest and truthful, and it allows people to weigh the value of your endorsements. As an influencer, it’s your responsibility to make these disclosures, to be familiar with the Endorsement Guides, and to comply with laws against deceptive ads. Don’t rely on others to do it for you.

1. When to Disclose

• Disclose when you have any financial, employment, personal, or family relationship with a brand.
  • Financial relationships aren’t limited to money. Disclose the relationship if you got anything of value to mention a product.
  • If a brand gives you free or discounted products or other perks and then you mention one of its products, make a disclosure even if you weren’t asked to mention that product. 
  • Don’t assume your followers already know about your brand relationships.
  • Make disclosures even if you think your evaluations are unbiased. 
• Keep in mind that tags, likes, pins, and similar ways of showing you like a brand or product are endorsements. 
• If posting from abroad, U.S. law applies if it’s reasonably foreseeable that the post will affect U.S. consumers. Foreign laws might also apply. 
• If you have no brand relationship and are just telling people about a product you bought and happen to like, you don’t need to declare that you don’t have a brand relationship. 

2. How to Disclose 

• Make sure people will see and understand the disclosure. 
• Place it so it’s hard to miss.
  • The disclosure should be placed with the endorsement message itself. 
  • Disclosures are likely to be missed if they appear only on an ABOUT ME or profile page, at the end of posts or videos, or anywhere that requires a person to click MORE. 
  • Don’t mix your disclosure into a group of hashtags or links. 
  • If your endorsement is in a picture on a platform like Snapchat and Instagram Stories, superimpose the disclosure over the picture and make sure viewers have enough time to notice and read it. 
  • If making an endorsement in a video, the disclosure should be in the video and not just in the description uploaded with the video. Viewers are more likely to notice disclosures made in both audio and video. Some viewers may watch without sound and others may not notice superimposed words. 
  • If making an endorsement in a live stream, the disclosure should be repeated periodically so viewers who only see part of the stream will get the disclosure.
• Use simple and clear language.
  • Simple explanations like “Thanks to Acme brand for the free product” are often enough if placed in a way that is hard to miss. » So are terms like “advertisement,” “ad,” and “sponsored.”
  • On a space-limited platform like Twitter, the terms “AcmePartner” or “Acme Ambassador” (where Acme is the brand name) are also options.
  • It’s fine (but not necessary) to include a hashtag with the disclosure, such as #ad or #sponsored.
  • Don’t use vague or confusing terms like “sp,” “spon,” or “collab,” or stand-alone terms like “thanks” or “ambassador,” and stay away from other abbreviations and shorthand when possible.
  • The disclosure should be in the same language as the endorsement itself. 
• Don’t assume that a platform’s disclosure tool is good enough, but consider using it in addition to your own, good disclosure. 6 Disclosures 101 for Social Media Influencers 

3. What Else to Know

• You can’t talk about your experience with a product you haven’t tried.
• If you’re paid to talk about a product and thought it was terrible, you can’t say it’s terrific. 
• You can’t make up claims about a product that would require proof the advertiser doesn’t have – such as scientific proof that a product can treat a health condition. 

3. Content Requirements

As a Brand Representative, you are asked to post about the many benefits we offer but you are strictly prohibited from making any claim not approved by us. You are encouraged to highlight our benefits, which are mentioned on our website and social media channels, where you can find examples of content we have created. Posts should not be restricted only to comments that cast Composer Securities in a positive light. Language should be fair and balanced.

IMPORTANT: You may not post any content that promises financial gain in any investment.

1. Do not talk about how much money you’ve made or discuss investment returns in any way (either in the past or in the future). You also cannot promise that anybody will achieve certain returns.
   • Unacceptable Caption: “I made $1,000 last week using the FIRM app. It’s made me so much money. I average a 25% return a month and it just keeps going up! You could make $1,000 a week as well.”
   • Acceptable Caption: “With FIRM, you can invest in the stock market starting with just $1.”

2. Do not talk about how much money you have the potential to put away.
   • Unacceptable Caption: “You could put away $500 a year if you sign up for the FIRM app!”
   • Acceptable Caption: “FIRM gives you the opportunity to learn how to make your money work for you. The FIRM app is a great way to get started on your financial journey.”

3. Do not use superlative language, such as “greatest,” “easiest,” “best,” “most.” 
   • Unacceptable Caption: “FIRM is the best financial app today! It’s the easiest way to invest. It’s the most powerful way to change your financial health.”
   • Acceptable Caption: “FIRM is a great way to learn about [INVESTING/BORROWING/ETC.]. It makes [INVESTING/BORROWING/ETC.] easy, and can help improve your financial knowledge.”

4. Do not make exaggerated or over-promissory statements.
   • Unacceptable Caption: “FIRM will make you rich! It will change your life! You’ll have access to every stock under the sun!” 
   • Acceptable Caption: “FIRM can help you get started on investing, and has over [NUMBER OF AVAILABLE PRODUCTS, ETC.].”

5. Do not make statements that cannot be substantiated.
   • Unacceptable Caption: “Everybody loves FIRM! It’s the most innovative app available today!”
   • Acceptable Caption: “FIRM makes it easy to get started with [INVESTING/BORROWING/ETC.].”

4. Prohibited Content

Your websites, social media profiles must not include nudity, vulgar language, illegal activity, hate speech, political commentary, or anything else that a reasonable person would find inappropriate.

If you use any false claims, you will be held solely liable for that claim as we will not be held liable. 

We have the right to monitor your websites and social media accounts to determine whether you are in following these requirements.

We have the right to require you to remove any posts or references online or in public, made by you at any time. 

5. No Spam

Mass unsolicited emailing or messaging (i.e. spamming) is strictly prohibited.

6. Approved Social Media Sites

Approved social media sites include:

1. X (Twitter), 
2. LinkedIn
3. YouTube
4. Substack 
5. Reddit
6. TikTok
7. TradingView 
8. or a comparable platform

You will be notified of any additional approved social media sites as they become available. 

You must notify us of the social media outlet you use and add us as a friend/follower.