This Acceptable Use Policy sets out the rules that govern how members may use the Equity Circle platform, community, events, and services. It is a legally binding document that forms part of every member's contract with Equity Circle. It has been designed to comply with the Online Safety Act 2023, UK GDPR, and all applicable consumer protection legislation, and to protect members, creators, and the wider community.

1. Introduction and Scope

1.1 Who We Are

Equity Circle is operated by Equity Circle Group Ltd (referred to in this Policy as "Equity Circle", "we", "us", or "our"). We operate a subscription-based community platform accessible via our mobile application and website at equitycirclegroup.com, providing education, community, productivity tools, and exclusive live events for ambitious young men aged 18 and over.

1.2 Purpose of This Policy

This Acceptable Use Policy ("AUP" or "Policy") sets out the standards of conduct we require from every person who accesses or uses our platform, community, events, digital products, and any related services (collectively, the "Platform"). This includes members, trial users, event attendees, guest users, creator partners, and any other party granted access to any part of Equity Circle.

This Policy exists for three purposes:

• To comply with our legal obligations under the Online Safety Act 2023, UK GDPR, the Consumer Rights Act 2015, and all other applicable legislation;

• To protect the safety, wellbeing, and experience of every person who uses the Platform; and

• To maintain the integrity and culture of the Equity Circle community.

1.3 Legal Status

This AUP forms part of your contract with Equity Circle. By creating an account, purchasing a membership, attending an event, or using any part of the Platform, you confirm that you have read, understood, and agree to be bound by this Policy. If you do not agree, you must not use the Platform.

1.4 Scope of Application

This Policy applies to:

• All use of the Equity Circle mobile application;

• All use of equitycirclegroup.com and any associated web properties;

• All community posts, messages, comments, and interactions within the Platform;

• All content uploaded, shared, or published via the Platform;

• All Equity Circle live events, run clubs, masterminds, and networking events, whether in-person or virtual;

• All interactions between members, creators, and Equity Circle staff; and

• All use of our AI-powered productivity tools and features.

1.5 Related Documents

This Policy must be read alongside our:

• Privacy Policy — governing how we collect, use, and protect your personal data;

• Cookie Policy — governing our use of cookies and tracking technologies;

• Terms & Conditions — governing the membership contract; and

• Subscription & Refund Policy — governing billing, cancellation, and refunds.

In the event of any conflict between this AUP and any other document, this AUP prevails in all matters relating to conduct and acceptable use.

2. Eligibility and Account Responsibility

2.1 Age Requirement

You must be 18 years of age or older to create an account or use the Platform. We do not knowingly permit access by persons under the age of 18. If we discover that a user is under 18, we will immediately suspend access and delete all associated personal data in accordance with our Data Retention Policy and UK GDPR obligations.

2.2 Account Accuracy

You must provide accurate, truthful, and complete information when creating your account and must keep that information up to date. You may not impersonate any other person, create a false identity, or misrepresent your affiliation with any person or organisation.

2.3 Account Security

You are solely responsible for maintaining the confidentiality and security of your login credentials. You must not share your account with any other person. You must notify us immediately at compliance@equitycirclegroup.com if you become aware of any unauthorised access to your account.

We will not be liable for any loss or damage arising from your failure to maintain the security of your credentials.

2.4 One Account Per Person

Each individual may hold only one Equity Circle account. Creating duplicate accounts to circumvent a suspension, access Founder Member pricing fraudulently, or for any other purpose is a material breach of this Policy.

3. Community Standards and Expected Conduct

3.1 Our Community Values

Equity Circle exists to give ambitious young men the structure, community, and tools to become who they are already capable of being. Our community standards exist to protect that environment. We expect every member to act with integrity, respect, and accountability — both online and at events.

3.2 Standards of Conduct

You must, at all times when using the Platform:

• Treat all members, creators, and Equity Circle staff with respect and dignity;

• Engage constructively and in good faith in community discussions;

• Provide honest and accurate information in all posts and interactions;

• Take responsibility for your own conduct and its effect on others;

• Respect the privacy of other members — do not share personal information about others without their consent;

• Comply with all applicable laws and regulations; and

• Honour the spirit of the Equity Circle community as well as the letter of this Policy.

3.3 Accountability Mechanic — Events

Equity Circle's exclusive live events are a core part of the membership experience. Members acknowledge that cancellation of their membership results in loss of access to events and event notifications. This is a product and community design decision, not a penalty. It is clearly disclosed at the point of purchase and forms part of the membership contract.

4. Prohibited Content and Behaviour

The following categories of content and behaviour are strictly prohibited on the Platform and at all Equity Circle events. These prohibitions apply to all posts, messages, images, videos, audio content, links, usernames, profile images, and any other material you upload, share, or communicate via the Platform.

4.1 Illegal and Criminal Content [ZERO TOLERANCE]

You must not create, upload, share, or distribute:

• Any content that constitutes, facilitates, incites, or glorifies any criminal offence under English law;

• Child Sexual Abuse Material (CSAM) or any content that sexually exploits or endangers minors — this triggers immediate referral to the National Crime Agency (NCA) and Internet Watch Foundation (IWF);

• Terrorist content, extremist propaganda, or content that supports, glorifies, or facilitates acts of terrorism, as defined by the Terrorism Act 2000 and Online Safety Act 2023;

• Content that facilitates human trafficking, modern slavery, or sexual exploitation;

• Non-consensual intimate images ("revenge porn") or any threat to share such content, contrary to the Criminal Justice and Courts Act 2015; and

• Fraudulent content, phishing material, or content designed to deceive others for financial gain.

4.2 Hate Speech and Discrimination [ZERO TOLERANCE]

You must not publish or share content that:

• Promotes, incites, or encourages hatred against any person or group based on a protected characteristic, including race, ethnicity, religion, sex, sexual orientation, gender reassignment, disability, age, pregnancy, or nationality, contrary to the Public Order Act 1986 and Equality Act 2010;

• Uses slurs, derogatory language, or dehumanising framing targeting any group; or

• Spreads or endorses conspiracy theories that target individuals or groups based on protected characteristics.

4.3 Harassment, Bullying, and Threatening Behaviour

You must not:

• Harass, intimidate, threaten, stalk, or bully any other user, creator, or member of Equity Circle staff, whether through direct messages, community posts, or any other means;

• Publish content that is designed to humiliate, shame, or cause distress to a specific individual;

• Make threats of violence or threats to damage another person's reputation or property;

• Engage in coordinated harassment of any individual; or

• Doxx any individual — meaning publishing private personal information about a person without their consent.

4.4 Misinformation and Harmful Content

You must not share:

• Medical misinformation — including false or unverified claims about health, medications, treatments, supplements, or mental health, where such claims could cause a user to take harmful action;

• Financial misinformation — including false claims about investments, returns, or opportunities that could mislead members;

• Content that encourages or glorifies eating disorders, extreme or dangerous dieting, self-harm, or suicide;

• Content that promotes the misuse of controlled substances or prescription medication; or

• Deliberately false information about Equity Circle, its founders, staff, or creator partners.

4.5 Spam, Commercial Activity, and Self-Promotion

You must not:

• Post unsolicited commercial content, spam, or repetitive promotional messages in community spaces;

• Promote competing subscription community products or services within the Platform;

• Solicit other members for money, investment, or paid services outside of designated spaces without prior written permission from Equity Circle;

• Use the community to recruit members into multi-level marketing (MLM) schemes, pyramid schemes, or similar models; or

• Post referral codes, affiliate links, or promotional discount codes for third-party products or services without prior written approval from Equity Circle.

4.6 Intellectual Property Infringement

You must not:

• Upload, share, or distribute content that infringes the copyright, trademark, or other intellectual property rights of any third party;

• Share course materials, video content, or educational content from the Platform outside the Platform without express written permission;

• Reproduce, scrape, or resell any Equity Circle content or creator content; or

• Use the Equity Circle brand, logo, or trademarks without prior written approval.

4.7 Platform Integrity

You must not:

• Attempt to gain unauthorised access to any part of the Platform, its infrastructure, or another user's account;

• Use bots, scrapers, crawlers, or automated tools to interact with the Platform;

• Interfere with, disrupt, or degrade the performance of the Platform;

• Attempt to reverse-engineer, decompile, or extract source code from the Platform; or

• Circumvent any security measure, access control, or content restriction on the Platform.

4.8 AI Tool Misuse

Our AI-powered productivity tools are provided to support members' personal development. You must not use these tools to:

• Generate content that violates any provision of this Policy;

• Attempt to manipulate, jailbreak, or circumvent the AI's safety settings;

• Generate content for distribution outside the Platform without permission; or

• Collect or harvest data about other members.

5. User-Generated Content

5.1 Your Responsibility for Content You Post

You are solely responsible for all content you post, upload, share, or publish on the Platform. Before posting any content, you confirm that:

• You have the right to share it — you own it or have a licence to use it;

• It does not violate any applicable law or any provision of this Policy;

• It does not infringe the rights of any third party; and

• It is accurate and not misleading.

5.2 Licence You Grant to Equity Circle

By posting content on the Platform, you grant Equity Circle a non-exclusive, royalty-free, worldwide licence to use, display, and distribute that content within the Platform for the purpose of operating the service. We do not claim ownership of your content. You may delete your content at any time, subject to retention obligations under UK GDPR.

Where you attend a live event and provide consent, your image or likeness may be captured and used for Equity Circle marketing purposes, including user-generated content (UGC) campaigns. Consent will be requested separately at the event.

5.3 Content We Do Not Moderate in Advance

As a user-to-user platform, Equity Circle does not pre-approve all user-generated content before it is published. We rely on automated tools, community reporting, and proactive moderation to identify and remove content that violates this Policy. This means you may occasionally see content before we have had the opportunity to remove it.

If you see content that you believe violates this Policy, you must report it immediately using the in-app reporting function or by emailing safety@equitycirclegroup.com.

6. Content Moderation and Enforcement

6.1 Our Moderation Approach

Equity Circle operates a three-layer content moderation system:

1. Automated detection — AI-assisted tools flag content containing prohibited keywords, categories, or signals for human review;

2. Community reporting — members can report content that they believe violates this Policy, triggering human review; and

3. Proactive human moderation — our moderation team conducts regular reviews of community spaces.

This system is designed to comply with our obligations under the Online Safety Act 2023, including our duty to have proportionate systems in place to identify and remove illegal content and content harmful to users.

6.2 Reporting Content

To report content that you believe violates this Policy:

• Use the in-app report function on any post or profile;

• Email safety@equitycirclegroup.com with a description and screenshot; or

• For urgent safety concerns, email urgent@equitycirclegroup.com marked URGENT.

We will acknowledge all reports within 24 hours and aim to make a moderation decision within 72 hours of receipt. For illegal content — including CSAM and terrorism-related content — we will act immediately.

6.3 Referrals to Authorities

We are legally required to, and will, refer certain categories of content to law enforcement and regulatory bodies without prior notice to the user involved. These include:

• All Child Sexual Abuse Material (CSAM) — referred to the National Crime Agency (NCA) and Internet Watch Foundation (IWF);

• Terrorist content — referred to the Counter Terrorism Internet Referral Unit (CTIRU); and

• Any content that presents an imminent risk to life — referred to emergency services.

6.4 Enforcement Actions

Depending on the nature and severity of a breach of this Policy, we may take one or more of the following actions:

6.5 Appeals Process

If you believe an enforcement action has been taken against your account in error, you have the right to appeal. To do so:

4. Email compliance@equitycirclegroup.com within 14 days of the enforcement action, with the subject line "AUP Appeal — [your username]";

5. Set out the grounds for your appeal clearly and include any relevant evidence; and

6. We will acknowledge your appeal within 5 working days and provide a decision within 20 working days.

Our decision on appeal is final. The appeals process does not affect your right to refer a complaint to a relevant regulatory body.

7. Data, Privacy, and Platform Monitoring

7.1 Monitoring of Platform Activity

In order to fulfil our obligations under the Online Safety Act 2023 and to enforce this Policy, Equity Circle monitors platform activity. This includes automated scanning of content, metadata analysis, and human review of reported content. By using the Platform, you consent to this monitoring as necessary for the operation of a safe community platform.

7.2 Personal Data

The personal data we collect about you, how we use it, and your rights as a data subject are set out in our Privacy Policy. By using the Platform, you agree that we may process your personal data in the ways described in the Privacy Policy, which forms part of your contract with us.

7.3 Member-to-Member Data

You may access limited profile information about other members through the Platform. You must not:

• Use any personal information about other members for any purpose other than engaging with them within the Platform;

• Copy, store, or share personal information about other members outside the Platform; or

• Attempt to identify the real-world identity of any member who has chosen not to disclose it.

7.4 AI Productivity Tools — Data Handling

Our AI-powered productivity tools (including habit trackers, goal logs, and daily prompts) process personal data about your goals, habits, and progress. This data is used solely to provide and improve the service. It is not sold to third parties and is not used to build advertising profiles. Full details are set out in our Privacy Policy and DPIA summary available on request.

8. Creator Partners

8.1 Additional Obligations

Creator partners — individuals who produce educational or community content for the Platform under a formal creator partnership agreement — are subject to this AUP in full and to the additional obligations set out in their Creator Partnership Agreement.

8.2 Content Standards for Creators

Creators must ensure that all content produced for the Platform:

• Is accurate, evidence-based, and not misleading;

• Complies with the ASA CAP Code and the UK Code of Non-broadcast Advertising;

• Does not make unsubstantiated health, fitness, financial, or performance claims;

• Clearly discloses any paid partnership, sponsorship, or commercial relationship in compliance with ASA guidance on influencer marketing;

• Does not promote, directly or indirectly, any product or service in a way that conflicts with Equity Circle's brand standards or partnership agreements; and

• Complies with all applicable trading standards legislation, including the Consumer Protection from Unfair Trading Regulations 2008.

8.3 Endorsements and Testimonials

Creators must not make false or misleading claims about results achievable through Equity Circle membership. Any results-based content must be genuine, representative, and properly caveated. Fabricated testimonials or misleading before-and-after content constitutes an Unfair Commercial Practice under the Consumer Protection from Unfair Trading Regulations 2008 and will result in immediate termination of the creator partnership agreement.

9. Live Events

9.1 Event Conduct

All provisions of this AUP apply to members attending Equity Circle live events, including run clubs, masterminds, networking events, and any other in-person or virtual gathering organised by or associated with Equity Circle. At events, you must additionally:

• Follow all reasonable instructions from Equity Circle staff, event hosts, and venue staff;

• Comply with the venue's own rules and conditions of entry;

• Not attend if you are under the influence of alcohol or any controlled substance in a way that affects your behaviour or the safety of others; and

• Behave in a manner consistent with the Equity Circle community values set out in Section 3.

9.2 Photography and Recording at Events

Equity Circle may capture photography and video footage at events for marketing and community purposes. By attending an event, you acknowledge this and consent to incidental capture. If you do not wish to be filmed or photographed, you must notify Equity Circle staff at the start of the event and we will make reasonable efforts to accommodate your preference.

You must not record other attendees without their express consent. Recording of course content, speaker sessions, or masterminds for distribution outside the Platform is strictly prohibited without prior written consent from Equity Circle.

9.3 Removal from Events

Equity Circle reserves the right to remove any attendee from an event who breaches this Policy or whose behaviour poses a risk to the safety or wellbeing of other attendees. Removal from an event does not entitle the member to a refund of their membership subscription.

10. Mental Health and Wellbeing

10.1 Our Commitment

Equity Circle was founded in recognition of the mental health crisis facing young men in the UK. We take the wellbeing of our members seriously. This section sets out how we approach mental health on the Platform.

10.2 Crisis Content

We have a zero-tolerance approach to content that:

• Glorifies, encourages, or provides instruction for self-harm or suicide;

• Promotes eating disorders or dangerous eating or exercise practices; or

• Constitutes crisis-level disclosure — where a member indicates they are in immediate danger.

If our moderation team identifies a crisis-level disclosure, we will respond using our Crisis Escalation Protocol, which includes directing the member to appropriate emergency services and crisis resources.

10.3 Signposting Resources

Equity Circle is a community platform, not a mental health service. We do not provide clinical or therapeutic support. If you or someone you know is struggling, please contact:

10.4 No Liability for Platform as Therapeutic Service

Nothing on the Equity Circle Platform constitutes medical, psychological, or therapeutic advice. Equity Circle is not a regulated health service and does not provide clinical support. If you require clinical support, please consult your GP or a qualified mental health professional.

11. Liability and Indemnity

11.1 Our Liability

Nothing in this Policy limits or excludes our liability for death or personal injury caused by our negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by law under the Consumer Rights Act 2015.

Subject to the above, Equity Circle shall not be liable for any loss or damage arising from content posted by other users on the Platform, your reliance on any user-generated content, or any conduct by another member online or at an event.

11.2 Your Indemnity

You agree to indemnify, defend, and hold harmless Equity Circle, its officers, directors, employees, and creator partners from any claim, loss, liability, cost, or expense (including reasonable legal fees) arising from your breach of this Policy, your use of the Platform, or your violation of any applicable law or third-party right.

12. Changes to This Policy

12.1 Our Right to Amend

We review this Policy at least annually and may update it at any time in response to legal, regulatory, or operational changes. We will notify you of material changes via the Platform and by email to the address registered to your account at least 14 days before the change takes effect. Your continued use of the Platform after a change takes effect constitutes your acceptance of the updated Policy.

12.2 Regulatory Changes

Where a change to this Policy is required by law — including requirements issued by Ofcom under the Online Safety Act 2023, the ICO under UK GDPR, or any other competent authority — the change may take effect immediately without prior notice.

13. Contact and Complaints

13.1 Contact Us

For questions about this Policy, to report a concern, or to raise a complaint, please contact us using the relevant channel below:

Email - info@equitycirclegroup.com

Post - Equity Circle Group Ltd, Floor 2, Cardinal House, Manchester, United Kingdom, M3 2LY

13.2 Regulatory Bodies

If you are not satisfied with our response to a complaint, you have the right to contact the relevant regulatory body:

• Information Commissioner's Office (ICO) — for data protection complaints: ico.org.uk or 0303 123 1113;

• Ofcom — for concerns about our compliance with the Online Safety Act 2023: ofcom.org.uk; and

• Advertising Standards Authority (ASA) — for concerns about advertising or promotional content: asa.org.uk.