Acceptable Use Policy

investordataroom.com Acceptable Use Policy Version: 1.0.0 Effective date: the effective date recorded for this version in the Platform Legal Ledger at publication. Operator: Mikasa Labs LLC ("we", "us"). 1. Scope and Role 1.1 What this Policy is. This Acceptable Use Policy (the "Policy" or "AUP") states what may not be done on or through the Services. It is incorporated by reference into the investordataroom.com Platform Terms of Service (the "Terms") and binds every Customer and every Authorized User. A copy of the current version of this Policy is available from Mikasa Labs LLC on request at the address in Section 11. Capitalized terms not defined here have the meanings given in the Terms. If this Policy conflicts with the Terms, the Terms control; for the processing of Customer Personal Data, the Data Processing Addendum controls over both. 1.2 Mikasa Labs LLC's role. Mikasa Labs LLC is a neutral technology provider, hosting conduit, and data processor. Mikasa Labs LLC does not pre-screen, review, edit, curate, or endorse Customer Data, and nothing in this Policy obligates Mikasa Labs LLC to monitor the Services. Responsibility for content rests with the Customer and the Authorized User who submitted it, and no action or inaction by Mikasa Labs LLC under this Policy shifts that responsibility to Mikasa Labs LLC. 1.3 Who "you" means. "You" means the Customer and each Authorized User, individually and collectively. The Customer is responsible for ensuring that its Authorized Users comply with this Policy. 2. Your Responsibility for Content 2.1 You are responsible for everything you submit to, publish on, store in, or transmit through the Services, including documents, project descriptions and updates, financial and funds-flow figures, job-creation figures, media, links, and embedded content. Submitting content through the Services does not transfer any responsibility for it to Mikasa Labs LLC, and Mikasa Labs LLC's provision of hosting is not a review, approval, or endorsement of it. 3. Prohibited Content You will not use the Services to host, publish, store, distribute, link to, or make available content that: 3.1 Unlawful or infringing content. - Violates applicable law. - Infringes or misappropriates any copyright, trademark, patent, trade secret, or right of publicity or privacy. Copyright complaints follow Section 13 of the Terms. - Is defamatory or tortiously false. - Is child sexual abuse material, sexually exploits minors, or is non-consensual intimate imagery. Content of this kind is removed and reported to authorities as required by law, without prior notice. - Unlawfully harasses, threatens, or incites violence against any person or group. 3.2 Non-compliant securities content. - Constitutes an offer or sale of securities that is not registered and not within a valid exemption, or that violates the conditions of a claimed exemption. - Omits disclosures required by applicable securities law, or is materially misleading, fraudulent, or otherwise actionable under anti-fraud provisions of applicable securities law. - Constitutes general solicitation or general advertising where the claimed exemption for the offering prohibits it. - Promotes market manipulation or any scheme to defraud investors. - Offers or purports to provide regulated investment, brokerage, advisory, or fund-administration services by a person that lacks any required registration or license. - Offers interests to persons to whom the offer is unlawful, including persons in sanctioned jurisdictions. 3.3 Deceptive content. - Misrepresents the identity, registrations, licenses, personnel, track record, or performance of the publishing Customer or any offering. - Contains fabricated or falsified financial statements, capital accounts, funds-flow figures, job-creation figures, or performance metrics. - Impersonates any person or entity or misrepresents an affiliation. - States or implies that Mikasa Labs LLC or investordataroom.com verifies, endorses, sponsors, co-publishes, or stands behind the Customer, its content, or any offering or investment. 3.4 Malicious content. - Malware, viruses, worms, trojans, ransomware, or any code designed to disrupt, damage, or gain unauthorized access to any system or data. - Phishing content or credential-harvesting pages. - Content designed to exploit a vulnerability in the Services or any third-party system. 4. Securities Offering Constraints 4.1 Gated audience only. The Services are designed as an access-gated environment: offering documents and Customer Content pages are available only to signed-in Authorized Users the Customer has authorized, and limited branding and display images (for example, a logo or a project display image) are served without authentication for page rendering. You will not use the Services to conduct general solicitation or general advertising where the exemption claimed for an offering prohibits it. You will not attempt to make gated Customer Content publicly available, including by publishing credentials, sharing accounts, or otherwise circumventing the access gating. The Customer is responsible for ensuring that any material it places in branding or display images is consistent with the exemptions it claims and with applicable law. 4.2 No intermediary use. You will not use the Services, or request or configure them, in any way that involves Mikasa Labs LLC soliciting or recommending an investment, introducing or matching investors and issuers, negotiating terms, effecting or facilitating a securities transaction, handling or holding funds or securities, or performing accreditation, suitability, or anti-money-laundering checks. You will not represent to any person, in any offering material, filing, or communication, that Mikasa Labs LLC performs any of those functions or is a broker-dealer, investment adviser, finder, placement agent, or promoter of any offering. 4.3 Promoter registration. The Customer is solely responsible for compliance with promoter registration and disclosure requirements applicable to its offerings, including EB-5 program requirements for direct and third-party promoters, and for the conduct of its promoters. You will not identify Mikasa Labs LLC as a promoter, agent, or representative of the Customer or any offering. 4.4 Paid promotion disclosures. If any content on the Services describes a security and any person received or will receive consideration for that description, the Customer is responsible for including the disclosures required by applicable law. Mikasa Labs LLC authors no offering descriptions and receives no consideration for describing any security. 4.5 Investor-facing accuracy. Job-creation figures, funds-flow presentations, and project updates are Customer statements to its Investors. The Customer must have a reasonable basis for them and must correct material errors promptly. 5. Data Restrictions 5.1 Restricted identity documents (pilot). The most sensitive identity document types are out of scope for the Services and must not be uploaded. You will not upload: passports; visas; immigration petitions (for example, Form I-526 or Form I-829 filings); or documents containing a full Social Security number or full taxpayer identification number. The Services may refuse or remove such uploads where they are identified as such, but this restriction applies whether or not it is technically enforced in a given case. 5.2 Other prohibited data. You will not upload or submit: payment card numbers or other cardholder data; health records or other data subject to health-privacy law; biometric identifiers; personal data of children; or government-issued identifiers beyond what the Services are designed to hold, unless Mikasa Labs LLC has agreed in writing to a specific category. 5.3 Lawful basis and notices. The Customer must have a lawful basis, and must have given any legally required notices and obtained any legally required consents, for all Customer Personal Data it causes to be processed on the Services. 5.4 Cross-border gate. The Customer will not submit Customer Personal Data relating to any individual who is located outside the United States or who is not a United States citizen or national, unless and until a Data Processing Addendum, including any applicable cross-border transfer terms, is in effect between the Customer and Mikasa Labs LLC (Section 10.4 of the Terms). 6. Prohibited Activities You will not: - Access or attempt to access any account, tenant, data, or system that you are not authorized to access, or exceed your authorized access. - Probe, scan, or test the vulnerability of the Services, or conduct penetration testing, load testing, or security research against the Services, without Mikasa Labs LLC's prior written consent. Suspected vulnerabilities should be reported under Section 8. - Bypass or attempt to bypass authentication, multi-factor authentication, session controls, rate limits, anti-abuse attestation, document access controls, or any other technical protection of the Services. - Share credentials, transfer an account, or allow any other person to use your account. - Scrape, harvest, crawl, or bulk-download data from the Services, or aggregate data across tenants, except as the Services are designed to permit for your own authorized data. - Reverse-engineer, decompile, or disassemble the Services, except to the extent this restriction is prohibited by applicable law. - Use the Services to send unlawful, deceptive, or unsolicited communications, or use invitation and notification features other than to reach individuals with whom the Customer has an existing relationship. - Interfere with the integrity, performance, or availability of the Services, including by imposing an unreasonable load, or use the Services to build or operate a competing service. - Introduce malicious code into the Services, or use the Services to distribute it. - Submit reports under Section 8 in bad faith, or knowingly submit materially false takedown or abuse claims. - Use the Services in violation of export control or sanctions law, or resell, sublicense, or provide the Services to third parties except as expressly agreed with Mikasa Labs LLC in writing. 7. Enforcement 7.1 Reactive posture. Mikasa Labs LLC does not pre-screen, monitor, or proactively moderate Customer Data. Mikasa Labs LLC reviews content or conduct when it receives a credible report, a legal notice or lawful government request, or an infrastructure or security signal (for example, malware detection or abuse of rate limits). This posture is intentional and consistent with Mikasa Labs LLC's role as a hosting conduit and processor. 7.2 Available actions. On review, Mikasa Labs LLC may take the action it reasonably considers appropriate, including: taking no action; requesting correction by the Customer; removing or disabling access to specific content; suspending an Authorized User or a tenant; terminating access under Section 14 of the Terms; and preserving records or making disclosures where required by law. Enforcement actions taken through the Services are recorded in Mikasa Labs LLC's audit logs. 7.3 Notice. Except where prompt action is required (for example, child-safety material, active malware, ongoing fraud, a credible threat to the security or availability of the Services, or legal compulsion), or where notice would frustrate a lawful investigation, Mikasa Labs LLC will notify the affected Customer and give a reasonable opportunity to respond or remedy before or promptly after acting. 7.4 No obligation, no waiver. Nothing in this Policy obligates Mikasa Labs LLC to detect or act on any particular violation, and Mikasa Labs LLC's exercise or non-exercise of enforcement discretion in one case is not a waiver as to any other case and does not create any duty to any person. 8. Reporting 8.1 Where to report. Report suspected violations of this Policy, illegal content, security vulnerabilities, or abuse to legal@investordataroom.com. Copyright infringement notices should follow Section 13 of the Terms. 8.2 What to include. A useful report identifies the content or conduct (URL, tenant, document title, or similar locator), describes the concern, includes supporting evidence where available, and provides contact information for follow-up. Mikasa Labs LLC reviews reports promptly; the report handling in Section 7 then applies. 9. Suspension and Termination Violations of this Policy are enforced through Section 14 of the Terms, including its notice, cure, and emergency provisions. Suspension restricts access but preserves data; termination is followed by data return and deletion under Section 15 of the Terms. 10. Changes to This Policy Mikasa Labs LLC publishes each version of this Policy to the Platform Legal Ledger with a version identifier and effective date, and gives notice of material changes as described in Section 21 of the Terms. The ledger record is the authoritative text of each version. Continued use of the Services after the effective date of a revised version constitutes acceptance of it. 11. Contact Questions about this Policy may be sent to legal@investordataroom.com or to Mikasa Labs LLC, 37010 Dusterberry Way 546, Fremont, CA 94536.