ADVISOR AGREEMENT: Advisor Atlas Leads

Terms of Service

The agreement between you (the advisor or advisor firm) and Advisor Atlas Leads. These Terms govern every account, every lead purchase, every auto-buy rule, and every payment on the marketplace.

Version 2.1.1 (Annuity-Only Scope, Option B Two-Checkbox Consent) Effective date: 2026-06-02 Operator: The Retirement Atlas LLC, an Indiana limited liability company, operating Advisor Atlas Leads as a DBA of the same entity that operates the The Retirement Atlas ("Advisor Atlas Leads," "AAL," "we," "us," "our") Contact: legal@advisoratlasleads.com

Changes vs Version 1.0: time-limited exclusivity hold replaced with a permanent one-buyer-per-lead, no-resale rule (Section 7); Texas Mini-TCPA (SB 140) explicitly named (Sections 11, 20); indemnification expanded with explicit state-by-state mini-TCPA naming and non-cap carve-out (Section 20); new insurance/COI requirement (Section 11A); TCPA operating requirements expanded (Section 11); state privacy laws list expanded (Section 10); third-party-beneficiary cross-reference to TRA consumer ToS Section 17 arbitration carry-over (Section 21). Scope narrowed in v2.0 to annuity referrals only: SEC Marketing Rule, Investment Advisers Act, FINRA, broker-dealer, and non-annuity insurance references removed (Section 4 eligibility requires annuity-line authority, Section 12 narrowed to annuity-specific product compliance with NAIC SAT as primary regime, Section 13 narrowed, Section 20 indemnification narrowed). Purchase-time scope confirmation added (new Section 5A) requires advisor to affirm annuity-only use at every purchase.

1. About these Terms and how you accept them

These Terms of Service ("Terms") govern your access to and use of Advisor Atlas Leads, the website at advisoratlasleads.com, the marketplace, and any related services (collectively, "AAL"). The Privacy Policy is incorporated by reference.

You accept these Terms by checking the consent box on the signup form, by accessing the marketplace as a returning advisor, or by purchasing a lead. The consent box reads:

By checking this box and clicking [Sign up], I represent that I am a state-licensed insurance producer holding current annuity-line authority (also referred to in some states as life-and-annuity authority) in good standing in every state in which I will receive leads through this marketplace; that I am authorized to act on behalf of the firm I am signing up; and that I agree to AAL's Terms of Service and Privacy Policy. I understand that this marketplace is exclusively for the discussion of annuity-based retirement income solutions with matched consumers, that I will use leads purchased through this marketplace solely in my annuity-producer capacity, and that I will not use leads purchased here to solicit fee-based investment advisory services, securities-related services, non-annuity insurance products (including life insurance, long-term care insurance, disability insurance, or health insurance) outside the explicit interest expressed by the consumer, or any other engagement outside the scope of annuity discussion. I understand that lead purchases are non-refundable except under the limited circumstances described in Section 8, that I must independently comply with TCPA (including state mini-TCPAs in Florida, Washington, Oklahoma, Texas, and any other applicable state), GLBA, the NAIC Suitability in Annuity Transactions Model Regulation as adopted in the consumer's state, state annuity advertising, illustration, and replacement rules, and every other law applicable to my outreach, that I will maintain Certificate-of-Insurance coverage as required in Section 11A, and that AAL does not supervise, control, or vouch for me to the consumers introduced through the marketplace.

If you do not agree, do not check the box and do not use the marketplace.

2. What AAL is and what AAL is not

Advisor Atlas Leads is a per-lead marketplace operator. Nothing more. AAL operates the marketplace that lists anonymized consumer leads forwarded from The Retirement Atlas ("TRA"), accepts purchases from qualifying advisors, releases the consumer's contact information to the one advisor that purchases a given lead, and bills the advisor for that purchase.

AAL is not:

a registered investment adviser, investment adviser representative, or solicitor;
a broker-dealer or registered representative;
an insurance producer or insurance agency;
a Certified Financial Planner, financial planner, accountant, attorney, bank, trust company, or other financial institution;
a co-fiduciary, co-adviser, joint venture partner, agent, or representative of yours or of any advisor on the marketplace;
a supervisor of, or party responsible for, any communication, recommendation, advice, sale, transaction, fee, product, or other conduct that takes place between you and a consumer whose lead you purchased through the marketplace.

The marketplace surfaces, including the matching score, the briefing narrative, the planning trail, and the price list, are tools for you to evaluate inventory. They are not investment advice, suitability determinations, or compliance review of any kind.

3. Where the leads come from

Every lead on AAL originates with a consumer who has used the The Retirement Atlas planning journey, opted in to be matched with a partner firm, and given TRA the consent described in TRA's Terms of Use. TRA forwards an anonymized payload to AAL over an HMAC-signed bridge. The anonymized listing you see on the marketplace contains things like asset bands, state, age, journey stage, score signals, and a headline. It does not contain the consumer's name, email, phone number, or any other direct identifier.

When you purchase a lead, AAL releases the consumer's contact information and the contents of the consumer's plan to you. The release happens by HMAC-signed unlock callback to TRA at the moment of purchase. From that point forward, your relationship with the consumer is between you and the consumer.

AAL does not generate leads, does not pre-screen consumers for suitability or fit, does not vouch for the accuracy of any consumer-provided input, and does not warrant that any particular lead will convert, close, or produce any particular outcome.

4. Eligibility

To open an account on AAL you must represent and warrant that:

You are at least 18 years of age, a resident of the United States, and authorized to bind the firm on whose behalf you are signing up;
You (or the firm) are currently licensed as a state-licensed insurance producer holding annuity-line authority (sometimes referred to as life-and-annuity authority, depending on the state) in every state in which you intend to receive leads through this marketplace, and you hold every additional state-level appointment, carrier appointment, product-specific certification, and continuing-education credit required to discuss and sell the annuity products you intend to offer in each such state;
You and the firm are in good standing with every state Department of Insurance whose authority you fall under, and you are not currently subject to any unresolved disciplinary action, license suspension, license revocation, statutory bar, or supervisory order that would affect your ability to serve consumers through the marketplace;
You are not subject to (i) any pending or final state insurance commissioner disciplinary action, (ii) any criminal conviction for fraud, dishonesty, breach of fiduciary duty, or theft within the prior ten (10) years, (iii) any bankruptcy filing within the prior five (5) years, or (iv) any pending consumer arbitration, class action, or material civil litigation arising from your insurance sales conduct;
AAL does not enroll registered investment advisers, investment adviser representatives, broker-dealers, or registered representatives in their securities capacity. If your only license is a securities license, you are not eligible to use this marketplace. If you hold a securities license in addition to a state insurance producer license with annuity-line authority, your use of this marketplace is limited to your annuity-producer capacity, and you will not solicit fee-based investment advisory services, securities-related services, or non-annuity insurance products (life, long-term care, disability, or health) from any consumer matched through this marketplace using the marketplace data, unless the consumer separately initiates an independent engagement with you in that other capacity outside the scope of, and not facilitated by, this marketplace;
You will only mark a state in your "licensed states" profile if you are actually licensed as an insurance producer with annuity-line authority in that state for the annuity products you intend to discuss with leads from that state;
Your authorization to act on behalf of the firm covers checkout, billing, and the wallet-debit authorizations in Section 6;
You will notify AAL within five (5) business days of any event that would cause any of the above representations to become inaccurate, including license suspension, state DOI inquiry, enforcement action, customer complaint resulting in regulatory disclosure, criminal charge, bankruptcy filing, or material civil litigation alleging insurance misconduct.

AAL may verify any of the above through public insurance registries (NIPR, the NAIC State Based Systems producer lookup, and state Department of Insurance lookups), through third-party background-check providers, or directly with you. AAL verifies each advisor's insurance producer license, active annuity-line authority, and carrier appointment status at least annually via NIPR (nipr.com), with the verification record filed in AAL's compliance file. Advisors who fail re-verification or who have license status changes between cycles are suspended from receiving new leads pending review. AAL may decline or revoke account access at any time, with or without cause.

AAL is not a "promoter" under SEC Rule 206(4)-1. AAL's marketplace excludes registered investment advisers and broker-dealers in their advisory or securities capacities from eligibility. AAL verifies advisor licenses through NIPR and state Department of Insurance lookups only; AAL does not query the SEC Investment Adviser Public Disclosure database or FINRA BrokerCheck as a condition of eligibility. Section 5A purchase-time scope confirmation requires every advisor to affirm annuity-producer capacity at every purchase. Together these three structural protections place the marketplace outside the SEC Marketing Rule's promoter classification.

5. What you can buy on AAL

You can purchase a single non-exclusive (in the sense of: not a long-term retainer) but one-buyer-per-lead right to receive a consumer's contact information and plan contents for the purpose of discussing insurance and annuity solutions with that consumer. Each lead is sold to exactly one insurance specialist.

One buyer per lead. Once a lead is purchased by a specialist, the marketplace marks it "purchased" and no other specialist can buy it.
No exclusivity beyond the lead. The consumer is free to use other planning tools, talk to other professionals, and engage anyone they choose. The one-buyer rule does not extend to any future conduct by the consumer.
No subscription. You pay per lead. There is no monthly minimum, no recurring license fee, and no guaranteed lead volume.
No contract term. You may close your account at any time under Section 22. We may close it for cause under the same section.
Scope of use. Each lead may be used solely to evaluate, pursue, and maintain an insurance or annuity sales engagement with the matched consumer. The lead may not be used to solicit fee-based investment advisory services, securities-related services, or any other engagement outside the scope of insurance and annuity discussion.

5A. Purchase-time scope confirmation

At the moment of every lead purchase (whether manual or auto-buy), you confirm to AAL, by completing the purchase, that:

(a) you are purchasing the lead in your state-licensed insurance producer capacity;

(b) you intend to use the lead to discuss insurance and annuity solutions with the matched consumer;

(c) you will not use the lead, the consumer's contact information, the consumer's plan contents, or the consumer's marketplace listing data to solicit fee-based investment advisory services, securities-related services, or any other engagement outside the scope of insurance and annuity discussion;

(d) you are purchasing this lead in your annuity-producer capacity only. If you hold any other license (including a securities license), any later consumer engagement with you outside the annuity-producer capacity is an unrelated engagement that the consumer must separately initiate, and that engagement is not facilitated by or attributable to AAL.

If AAL reasonably believes you have used any lead in violation of this Section 5A, AAL may immediately suspend your account, treat the breach as cause for termination under Section 22, invoke Section 20 indemnification for any consumer claim or regulatory inquiry arising from your scope breach, and report the breach to your primary state Department of Insurance and to any carrier with whom you hold an appointment for an annuity product purchased by the matched consumer.

6. Pricing, the wallet, and the auto-buy authorization

Per-lead pricing. Each lead is priced according to the matrix published on /browse at the time of purchase: a 5-tier (by estimated liquid assets) by 2-intent (planning vs. hot) base price, adjusted by a journey-signal multiplier that reflects how far the consumer has progressed, and bounded by a fixed price floor and ceiling. Prices do not drop as a lead ages, and AAL does not resell or re-list leads (see Section 7). The price displayed on the lead row at the time you click "Buy" is the price you pay.

Wallet model. AAL operates a pre-paid wallet. You top up by credit or debit card or other payment method we accept; lead purchases (manual and auto-buy) debit your available balance. Bulk top-ups earn bonus credit per the ladder published on /billing.

Auto top-up authorization (optional). If you enable auto top-up, you authorize AAL to charge the payment method you have on file, on a recurring basis, to bring your wallet balance back to the target you set whenever it drops below the floor you set. You can disable auto top-up at any time from /billing.

Auto-buy authorization (optional). If you enable any auto-buy rule, you authorize AAL to purchase matching leads on your behalf and to debit your wallet at the published price for each purchase, up to the monthly cap you set. Auto-buy purchases are final at the moment they occur and are subject to the same refund window in Section 8 as manual purchases. You can pause or delete any rule at any time from /autobuy.

Taxes. Prices are exclusive of any sales, use, value-added, or similar tax. You are responsible for any such tax. We may add tax to your charges where we are required to collect it.

Payment processor. Card payments are processed by Stripe, Inc. Your card information is collected and stored by Stripe under its own terms and privacy policy; AAL does not receive or store full card numbers.

7. One buyer per lead: no resale or re-match

At the moment of purchase, the lead leaves the marketplace inventory permanently. It is sold to you and to you alone, and AAL does not, at any time and under any circumstances, resell, re-match, re-list, or otherwise transfer the consumer's information from that lead to any other advisor. There is no release window. There is no aging mechanic that returns the consumer to inventory. There is no AAL-side process by which a second advisor can buy this lead.

You are expected to make good-faith, timely contact with the consumer. If you do not intend to work a lead, do not buy it. AAL does not police your post-purchase contact cadence; the one-buyer rule and your professional obligations under TCPA, state mini-TCPAs, and state insurance regulation are the operative constraints.

If the consumer requests revocation, suppression, or deletion after your purchase, AAL handles that through suppression of the consumer's record and, where AAL's contractual error window applies, through wallet refund under Section 8. AAL does not handle consumer opt-outs by reselling the lead to a different advisor.

The one-buyer-per-lead rule is a recordkeeping and marketplace-operations rule. It does not restrict the consumer's own future conduct. The consumer is free to use other planning tools, talk to other professionals, and engage anyone they choose, per Section 5.

8. Refund window and bad-lead criteria

Lead purchases are generally non-refundable. We will, however, credit your wallet for any purchase that meets all of the following criteria, provided you submit a written dispute to disputes@advisoratlasleads.com within fourteen (14) days of the purchase:

The email address provided by the consumer hard-bounces on a test send, OR
The phone number provided by the consumer (where contact by phone is permitted) is disconnected, reassigned, or otherwise fails to reach the consumer named in the lead, OR
The consumer informs you, in writing or by phone (with a contemporaneous note), that the lead is fraudulent, that the consumer never opted in, or that the consumer's identity was used without their authorization, OR
The lead is a duplicate of a lead you have already purchased in the prior 90 days, where the duplicate is the result of a AAL or TRA error rather than the consumer re-engaging, OR
The lead is suppressed (consumer opt-out, CCPA/CPRA deletion, GDPR erasure, court order, TRA-side compliance action) within 72 hours of the purchase, before you have had a reasonable opportunity to engage.

We decide refund requests within ten (10) business days, based on our review of the facts. Our decision is final. We do not refund based on lack of conversion, lack of fit determined after a reasonable attempt to engage, or the consumer's decision not to retain you.

9. Outcome reporting

You agree to record an outcome on each lead you purchase within thirty (30) days of the purchase. Outcomes are one of: "engaged," "closed," "not a fit," or "unresponsive." For "closed" outcomes, you agree to report a good-faith estimate of the net worth or AUM being managed under the engagement, for the purpose of the marketplace's aggregate ROI dashboard and any feedback signal to TRA.

Outcome data is forwarded to TRA over the bridge so TRA can measure how well its planning journey converts. Outcome data is not used to identify the consumer to any other advisor and is not published in any advisor-identifying form.

Failure to report outcomes does not, by itself, breach these Terms. Persistent non-reporting may result in lower ranking in auto-match queues and may, in AAL's discretion, trigger account review.

10. Handling consumer information after purchase

The information you receive at purchase, namely the consumer's name, email, phone number (if permitted), state, plan contents, and discovery answers, is nonpublic personal information within the meaning of the Gramm-Leach-Bliley Act ("GLBA") and applicable state financial privacy laws. You agree, with respect to that information:

to handle it under your firm's written information security program, in compliance with the GLBA Safeguards Rule (16 C.F.R. Part 314), state insurance privacy regulations modeled on the NAIC Insurance Information and Privacy Protection Model Act, and any other privacy law applicable to your firm and to the consumer's state;
to comply with every state comprehensive privacy law applicable to your processing of the consumer's information, including without limitation the California Consumer Privacy Act and California Privacy Rights Act, the California Financial Information Privacy Act, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, the Texas Data Privacy and Security Act, the Oregon Consumer Privacy Act, the Montana Consumer Data Privacy Act, the Iowa Consumer Data Protection Act, the Delaware Personal Data Privacy Act, the New Hampshire Privacy Act, the Tennessee Information Protection Act, the Indiana Consumer Data Protection Act, the Minnesota Consumer Data Privacy Act, the New Jersey Data Privacy Act, the Kentucky Consumer Data Protection Act, the Nebraska Data Privacy Act, the Maryland Online Data Privacy Act, the Rhode Island Data Transparency and Privacy Protection Act, and any other state comprehensive privacy law in effect at the time of processing;
not to share it with any third party other than your firm, your firm's service providers under appropriate contracts, the consumer themselves, or as required by law;
not to use it for any purpose other than evaluating, pursuing, or maintaining a professional engagement with the consumer introduced through the marketplace;
to honor any opt-out, deletion, correction, or access request the consumer makes, in the time required by the applicable privacy law;
to notify AAL within seventy-two (72) hours of any actual or reasonably suspected unauthorized disclosure of the consumer's information that you receive from AAL, at security@advisoratlasleads.com.

The above survives termination of these Terms.

11. TCPA, telemarketing, and the consumer's contact permissions

Each lead on the marketplace carries an explicit "allowed contact methods" flag forwarded from TRA. The consumer's TCPA consent has been captured by TRA only where the flag includes "phone." Where the flag is "email only," the consumer has not consented to phone or text outreach.

You agree:

(a) Honor the contact-permissions flag exactly. No phone calls or text messages to any consumer whose flag is "email only," regardless of how that consumer's number was obtained.

(b) Comply with the federal Telephone Consumer Protection Act ("TCPA"), including its rules on autodialed and prerecorded calls and texts, AI-generated calls, STOP and HELP keyword handling, calling-time restrictions, the National Do Not Call Registry, and 47 C.F.R. § 64.1200(d) internal DNC procedures.

the Florida Telephone Solicitation Act, Fla. Stat. § 501.059;
the Washington Mass Telephone Practices Act, RCW 19.158;
the Oklahoma Telephone Solicitation Act of 2022, 15 Okla. Stat. § 775C.1 et seq.;
the Texas Telephone Solicitation Act and Texas Business and Commerce Code Sections 301–305 (Texas Mini-TCPA, as amended by Texas SB 140 effective September 1, 2025), including the expanded SMS/MMS coverage, the quiet hours requirement, the ADAD consent requirement, the registration requirements of Section 302, and the Texas Deceptive Trade Practices Act as it interacts with Section 304; and
any other state mini-TCPA, telemarketing law, do-not-call registry, or consumer-protection statute in any state in which you contact leads.

(d) Comply with the CAN-SPAM Act for any commercial email you send the consumer.

(e) Written consent capture and records. Where the lead's contact-permissions flag is "phone-allowed" and that consent was captured by TRA, you may rely on TRA's consent only to the extent the consent disclosure explicitly authorizes the manner of contact you propose to use. You are responsible for confirming the scope of the captured consent before initiating any call or text and for re-capturing any consent that does not extend to your intended use. You will maintain consent records, including the date and time of consent, the disclosure version, the source of consent, and any identifying information collected at consent, for at least five (5) years from the date of the most recent contact. You will produce these records to AAL within five (5) business days of AAL's reasonable request.

(f) DNC scrubbing cadence. You will maintain a written DNC policy and procedures compliant with 47 C.F.R. § 64.1200(d), maintain an internal DNC list of consumers who have requested no further contact, scrub against the National DNC Registry at the cadence required by law (currently every thirty-one (31) days), and scrub against any applicable state DNC registry on the cadence required by the state.

(g) Calling hours. You will not call or text any lead outside the calling hours permitted by federal law (8:00 AM to 9:00 PM in the lead's local time zone), the calling hours permitted by the lead's state of residence (Florida and Texas each have specific quiet-hour rules under their mini-TCPAs), or the lead's individually expressed preferences.

(h) STOP and HELP handling. You will honor any STOP, UNSUBSCRIBE, "stop calling me," "remove me," or equivalent revocation request from a lead within one (1) business day. You will respond to HELP messages with the information required by FCC rules.

(i) Caller identification. In the first communication with each lead, you will disclose: (i) your name and firm name; (ii) your role as a state-licensed insurance producer with annuity-line authority; (iii) the purpose of the call or text (to discuss annuity-based retirement income solutions); (iv) that the introduction was made through Advisor Atlas Leads, a referral service for licensed annuity specialists; (v) that you paid a referral fee for the introduction; and (vi) that you earn commission on any annuity product the consumer may purchase and that there is no obligation. The disclosure must comply with any state annuity advertising rule that imposes a more specific disclosure obligation.

(j) Acknowledgment of state law stacking. You acknowledge that several states, including Texas, permit a single call or text to give rise to claims under both federal TCPA and the applicable state mini-TCPA, that statutory damages may stack, and that you accept full responsibility for managing this exposure.

AAL is not the calling party for TCPA purposes, does not dispatch calls or texts on your behalf, and does not vouch for the accuracy of any phone number a consumer enters into TRA. Compliance is yours.

11A. Insurance requirements and Certificate of Insurance

You will maintain, throughout the term of this Agreement and for two (2) years thereafter, the following insurance coverage with insurers having an A.M. Best rating of A- VIII or better:

(a) Cyber liability with limits of at least $1,000,000 per occurrence / $1,000,000 aggregate, with an affirmative carve-back or endorsement covering claims under the federal Telephone Consumer Protection Act and all applicable state mini-TCPAs, including the Texas Mini-TCPA. Fallback option. If no available carrier offers an affirmative TCPA carve-back at the required limits, advisor may substitute broader cyber coverage at $3,000,000 aggregate limits with written advance approval from AAL. Approval is granted at AAL's reasonable discretion and is contingent on advisor providing evidence of the carrier's underwriting policy and the broader coverage's specific TCPA treatment.

(b) Errors and omissions / professional liability with limits of at least $1,000,000 per occurrence / $1,000,000 aggregate, covering your activities as a state-licensed insurance producer with annuity-line authority in connection with the recommendation and sale of annuity products to leads purchased through this marketplace, and explicitly extending to claims arising under the NAIC Suitability in Annuity Transactions Model Regulation and any state best-interest standard for annuity transactions;

You will provide AAL with a Certificate of Insurance evidencing the above coverage on or before the date your first lead is released, will name AAL and The Retirement Atlas LLC as Certificate Holders, will provide thirty (30) days' written notice of any cancellation or material adverse change, and will provide a renewal Certificate of Insurance within fifteen (15) days of each anniversary.

Failure to maintain compliant insurance is a material breach. AAL may suspend marketplace access immediately upon any lapse and may treat the lapse as cause for termination under Section 22.

12. Annuity product-side compliance

When you discuss or sell any annuity product to a consumer introduced through the marketplace, you agree to comply with:

the NAIC Suitability in Annuity Transactions Model Regulation as adopted in the consumer's state, including the duty to act in the consumer's best interest, the disclosure of cash and non-cash compensation, the documentation of the basis for any recommendation, the documentation of any material conflicts of interest, the supervision and training requirements, and the records-retention obligations thereunder;
the state best-interest standard for annuity transactions adopted by the consumer's state (the NAIC SAT revised model has been adopted in a majority of U.S. states; the specific implementing regulations vary by state and you are responsible for tracking the version in force in each state where you write business);
state annuity advertising rules, including any rule requiring conspicuous disclosure of paid-referral arrangements;
state annuity replacement and 1035-exchange rules applicable to the product you are proposing, where the consumer holds a comparable existing annuity, life insurance policy, or other replaceable product;
state annuity illustration rules applicable to the product you are proposing, including the duty to deliver the carrier-prepared illustration in the form required by your state and to obtain the signed acknowledgment of receipt;
state annuity disclosure rules, including any state-specific "buyer's guide" delivery requirement and the cooling-off / free-look period disclosure;
state senior-protection annuity rules and any state-specific over-65 / vulnerable-adult protections;
carrier-specific annuity training, product-specific certification, and continuing-education requirements applicable to the products you sell;
state-level annuity continuing education requirements;
the surplus-lines and producer-of-record requirements applicable in the consumer's state, where relevant;
all other product-side suitability, best-interest, advertising, illustration, replacement, disclosure, and senior-protection rules applicable to your conduct toward the consumer.

AAL does not pre-qualify any consumer for any annuity product. The fact that an annuity reference appears in the consumer's planning trail or marketplace listing is not a recommendation by AAL that the product is suitable, appropriate, or in the consumer's best interest. Suitability and best-interest determinations are yours, not ours.

Scope acknowledgment. You acknowledge that this marketplace is exclusively for the discussion of annuity-based retirement income solutions. You will not use any lead purchased through this marketplace to solicit fee-based investment advisory services, securities transactions, securities-related advice, or non-annuity insurance products (including life insurance, long-term care insurance, disability insurance, or health insurance), unless the consumer separately and on their own initiative requests information about such other products and services outside the scope of, and after, the annuity discussion for which the marketplace introduction was made. If you hold securities licenses or non-annuity insurance authority, those licenses and authorities are irrelevant to your purchase of leads through this marketplace.

No twisting. No churning. You expressly agree that you will not engage in twisting (inducing a consumer to surrender, exchange, or replace an existing annuity, life insurance policy, or other insurance contract through misrepresentation, incomplete comparison, or material omission, primarily to earn a new commission) or churning (the unnecessary or repeated replacement of a consumer's annuity or insurance contracts, whether initiated by you or coordinated with the consumer, that primarily benefits the producer rather than the consumer). Both practices are prohibited under the NAIC Suitability in Annuity Transactions Model Regulation Section 6 (Duties of Insurers and of Insurance Producers, including the duty to act in the consumer's best interest with respect to any annuity recommendation), the NAIC Replacement of Life Insurance and Annuities Model Regulation Sections 6 and 7 (Producer Duties Pertaining to Replacements and Insurer Duties), and the state laws of every U.S. state. A single substantiated incident of twisting or churning involving a consumer matched through AAL is cause for immediate termination of this Agreement without refund of any prepaid fees, full invocation of Section 20 indemnification for any consumer claim or regulatory inquiry arising from the incident, reporting of the incident by AAL to your primary state Department of Insurance and to any carrier with whom you hold an appointment for the affected product, and permanent prohibition on rejoining this marketplace.

14. Acceptable use

You agree not to:

resell, re-share, sublicense, broker, syndicate, or otherwise transfer any consumer information you receive through the marketplace to any third party other than as expressly permitted in Section 10;
use any consumer information for a purpose unrelated to evaluating, pursuing, or maintaining a professional engagement with the consumer introduced through the marketplace, including but not limited to bulk marketing of unrelated products or services;
scrape, mirror, harvest, automatically extract, reverse engineer, or otherwise programmatically extract listings, pricing, scores, or any other marketplace data outside the purchase flow;
attempt to access another advisor's account, wallet, rules, or purchases;
use the marketplace to defraud, mislead, threaten, harass, or unlawfully discriminate against any consumer;
use AAL to identify a consumer for any purpose other than the introduction that the consumer agreed to in TRA's consent language, including ad targeting, data enrichment for third parties, or training of any machine learning model or large language model;
misrepresent to any consumer that you have been vetted, approved, endorsed, supervised, or otherwise certified by AAL beyond the contractual eligibility representations in Section 4.

15. Account security

You are responsible for keeping your account credentials confidential and for all activity that occurs under your account, including auto-buy purchases. Notify us promptly at security@advisoratlasleads.com if you suspect any unauthorized access. If we reasonably suspect compromise, we may suspend the account, reverse any auto-buy purchases that occurred after the compromise, and require re-authentication before the account resumes.

16. Lead data we retain

AAL retains the anonymized lead inventory, the price and score history, your purchase history, your auto-buy rules, your outcome reports, and all bridge audit logs for as long as we need them to operate the marketplace and to defend any dispute. We do not retain consumer PII after delivery to the purchasing advisor beyond what is necessary for billing, fraud detection, and audit. TRA, not AAL, is the system of record for consumer PII.

On a consumer's deletion request to TRA, TRA marks the lead suppressed on the bridge; AAL hides the listing from the marketplace, redacts any anonymized references where required, and retains the audit trail of the request and the action taken.

17. Confidentiality

The marketplace mechanics, the pricing formula, the scoring composition, the auto-buy queue logic, and any non-public information about other advisors' activity are AAL's confidential information. You agree not to disclose it to any third party other than your firm's legal, accounting, or compliance advisors under appropriate confidentiality, except as required by law.

18. No warranties

To the maximum extent permitted by law, AAL is provided on an "AS IS" and "AS AVAILABLE" basis without warranties of any kind, express, implied, or statutory, including warranties of merchantability, fitness for a particular purpose, accuracy, non-infringement, or quiet enjoyment. AAL does not warrant that the marketplace will be uninterrupted, timely, error-free, or free of viruses or other harmful components.

AAL does not warrant the quality, accuracy, completeness, suitability, conversion rate, AUM-closed rate, or any other attribute of any lead. The match score, the pricing matrix, and the briefing narrative are informational only.

19. Limitation of liability

To the maximum extent permitted by law:

(a) AAL and its affiliates, officers, employees, agents, suppliers, and licensors will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenues, data, business, goodwill, or other intangible losses, arising out of or related to your use of AAL, even if AAL has been advised of the possibility of such damages.

(b) AAL's aggregate liability arising out of or related to these Terms or your use of AAL will not exceed the greater of one thousand U.S. dollars ($1,000) or the total amount of fees you actually paid to AAL in the twelve (12) months preceding the event giving rise to the liability.

(c) AAL is not liable for any act, omission, advice, recommendation, communication, sale, product, breach, or violation of law by you, the consumer, TRA, or any third party. Any claim arising from your conduct toward a consumer introduced through the marketplace must be brought against you, not against AAL.

(d) Some jurisdictions do not allow the exclusion or limitation of certain damages. In those jurisdictions, the exclusions above apply only to the maximum extent permitted by law.

(e) The limitation in this Section 19 does not apply to your indemnification obligations under Section 20.

(f) The cap in Section 19(b) does not apply to claims arising from AAL's gross negligence, fraud, willful misconduct, or breach of AAL's confidentiality obligations under Section 17. For all other claims, the cap applies as written.

20. Indemnification

You will defend, indemnify, and hold harmless AAL, The Retirement Atlas LLC, the The Retirement Atlas, their respective affiliates, officers, directors, employees, agents, suppliers, and licensors (collectively, "Indemnified Parties"), from and against any and all claims, demands, actions, regulatory inquiries, investigations, lawsuits, judgments, settlements, damages, losses, liabilities, fines, penalties, costs, and expenses (including reasonable attorneys' fees, costs of investigation, costs of defense, and costs of regulatory response, all from the moment a claim is asserted and whether or not the claim ultimately succeeds), arising out of or related to:

(a) any call, text message, voicemail, ringless voicemail, AI-generated voice communication, prerecorded message, email, or other communication that you (or anyone acting on your behalf, including any employee, sub-producer, marketing partner, or third-party vendor) made or caused to be made to any lead, including without limitation any claim under the federal Telephone Consumer Protection Act and FCC implementing regulations, the Florida Telephone Solicitation Act, the Washington Mass Telephone Practices Act, the Oklahoma Telephone Solicitation Act, the Texas Telephone Solicitation Act, the Texas Business and Commerce Code Sections 301–305 (Texas Mini-TCPA, as amended by SB 140 effective September 1, 2025), the CAN-SPAM Act, the federal Do Not Call Registry, any state Do Not Call registry, any state Deceptive Trade Practices Act, or any other federal or state telemarketing, consumer-protection, or anti-spam law;

(b) your compliance or non-compliance with any state insurance-licensing rule applicable to annuity producers, the NAIC Suitability in Annuity Transactions Model Regulation, any state best-interest standard for annuity transactions, any state annuity advertising rule, any state annuity illustration rule, any state annuity replacement and 1035-exchange rule, any state surplus-lines rule, any state senior-protection annuity rule, or any carrier-specific annuity suitability, training, or product-certification rule;

(b-1) your use of any lead purchased through this marketplace in any capacity other than your state-licensed insurance producer capacity holding annuity-line authority, including any solicitation of fee-based investment advisory services, securities-related services, non-annuity insurance products, or any other engagement outside the scope of annuity discussion, in violation of Sections 5 and 5A;

(c) any advice, recommendation, opinion, projection, illustration, suitability analysis, fee disclosure, product proposal, product sale, or other professional service you provided, recommended, or failed to provide to any lead;

(d) your breach of the GLBA Safeguards Rule (16 C.F.R. Part 314), the California Financial Information Privacy Act, or any state comprehensive privacy law identified in Section 10, with respect to any lead data you received from AAL, including any data breach or unauthorized disclosure;

(e) your breach of any representation or warranty in this Agreement, including without limitation your representations as to licenses, registrations, disciplinary history, insurance, compliance posture, or eligibility for marketplace participation;

(f) any resale, sublicense, transfer, repackaging, or onward sharing of lead data you received from AAL, in violation of Section 10 or Section 14;

(g) any claim by a lead (or by a class or putative class of leads) against any Indemnified Party alleging that an Indemnified Party is liable for your conduct, including any claim for negligent referral, failure to supervise, vicarious liability, agency, apparent or actual authority, alter-ego liability, joint enterprise, or piercing of the corporate veil, in each case to the extent the underlying conduct is yours;

(h) any tax obligation, including any sales, use, gross receipts, or franchise tax, attributable to your purchase of leads or operation of your business;

(i) any third-party claim that any communication you sent to a lead infringes a third party's intellectual property rights, defames any person, or otherwise gives rise to civil or criminal liability.

Your indemnification obligation under this Section 20:

applies whether or not the claim ultimately succeeds;
includes the cost of defense from the moment a claim is asserted;
is not capped or limited by the fees you paid AAL or by any amount otherwise owed by you under this Agreement, and the limitation of liability in Section 19 does not apply to this indemnification obligation;
includes the cost of any regulatory investigation, examination, or enforcement action arising from your conduct, even if no civil claim is filed;
requires you to use counsel reasonably acceptable to AAL and to allow AAL to participate in the defense at AAL's own expense;
prohibits you from settling any claim against an Indemnified Party without AAL's prior written consent if the settlement would impose any obligation on the Indemnified Party or admit any liability of the Indemnified Party;
survives termination of this Agreement.

21. Dispute resolution, arbitration, and class-action waiver

Please read this section carefully. It affects your legal rights.

Informal resolution first. Before filing any claim, you agree to first contact us at legal@advisoratlasleads.com with a written description of the dispute and the relief you seek. We will try in good faith to resolve the dispute within sixty (60) days.

Binding arbitration. If informal resolution fails, you and AAL agree that any claim arising out of or relating to these Terms, your use of AAL, the marketplace, or any lead purchase will be resolved by binding individual arbitration administered by JAMS under its Streamlined Arbitration Rules (for claims under $250,000) or its Comprehensive Arbitration Rules (for larger claims), subject in all events to JAMS Minimum Standards of Procedural Fairness (2009, revised 2018). The arbitration will be conducted before one commercial arbitrator, will be governed by the Federal Arbitration Act and not by any state arbitration law, and will take place in Marion County, Indiana (Indianapolis), with hearings available by videoconference at either party's election.

Filing-fee allocation. AAL will pay all JAMS filing fees and arbitrator fees in excess of $1,000 for any advisor claim under $250,000. For advisor claims of $250,000 or greater, JAMS Comprehensive Rules default fee allocation applies.

Class-action waiver. You and AAL each agree to bring claims against the other only in your or its individual capacity and not as a plaintiff or class member in any purported class, collective, consolidated, or representative action. The arbitrator may not consolidate more than one person's claims and may not preside over any form of representative or class proceeding.

30-day opt-out. You may opt out of this arbitration agreement by sending written notice to legal@advisoratlasleads.com within thirty (30) days of first agreeing to these Terms. The notice must include your name, the email used with AAL, and a clear statement that you wish to opt out of arbitration.

Consumer-side arbitration carry-over. Under Section 17 of the TRA Terms of Use, partner firms (including you) are intended third-party beneficiaries of the consumer arbitration clause. If a consumer brings a claim against you arising from your purchase of the consumer's match, you may invoke the TRA Terms of Use Section 17 arbitration clause as a third-party beneficiary, in addition to any rights you have under this Section 21.

Exceptions. Either party may bring an individual action in small-claims court. Either party may seek injunctive relief in court to protect intellectual property rights or to enforce Section 14 (acceptable use) or Section 20 (indemnification). Nothing in this section limits a party's right to report conduct to a government agency.

22. Suspension and termination

You may close your account at any time from /profile or by writing to support. We may suspend or terminate your account, refuse any purchase, reverse any auto-buy purchase, or hold any unspent wallet balance for review:

immediately, if we have a reasonable belief that you have breached Section 4 (eligibility), Section 10 (PII handling), Section 11 (TCPA), Section 11A (insurance), Section 14 (acceptable use), or Section 20 (indemnification);
immediately, if a regulator, law enforcement agency, or court instructs us to;
immediately, on receipt of a credible complaint from a consumer about your conduct that we cannot resolve informally;
with reasonable notice, for non-payment, fraud risk, or continued failure to report outcomes;
without cause, on thirty (30) days' notice.

On termination, any wallet balance that is not subject to chargeback or dispute will be refunded to your original payment method within thirty (30) days. Within thirty (30) days of termination, you will either (i) certify in writing that all consumer contact information and plan content received from AAL has been deleted from your systems (except for records you are legally required to retain for compliance purposes, which you will continue to protect under the GLBA Safeguards Rule and state privacy law), or (ii) at AAL's option, return such data to AAL. Records you retain for legal-compliance purposes after termination remain subject to Sections 10, 11, and 20 of this Agreement.

The sections that by their nature should survive termination, including 2, 3, 10, 11, 11A (insurance, two years tail), 12, 13, 16, 17, 18, 19, 20, 21, 23, and the Privacy Policy, survive.

23. Governing law

These Terms are governed by the laws of the State of Indiana, excluding its conflict-of-laws rules and excluding any matter governed by the Federal Arbitration Act. Subject to Section 21, the state and federal courts located in Marion County, Indiana (Indianapolis) have exclusive jurisdiction over any matter not subject to arbitration.

24. Changes to these Terms

We may update these Terms. If a change is material, we will give you at least thirty (30) days' notice by email or by an in-product notice before the change takes effect, and we will update the "Effective date" line at the top of this document. Your continued use of AAL after the effective date of the change means you accept the updated Terms. If you do not accept them, you can stop using AAL.

25. Other terms

Entire agreement. These Terms and the Privacy Policy are the entire agreement between you and AAL regarding AAL and supersede any prior agreements.

Third-party beneficiaries. TRA and The Retirement Atlas LLC are intended third-party beneficiaries of Sections 2, 3, 10, 11, 11A, 16, 20, and 21.

Severability. If any provision is held unenforceable, the rest stays in effect.

No waiver. Our failure to enforce a provision is not a waiver of our right to enforce it later.

Assignment. You may not assign these Terms (including by merger, change of control, asset sale, or operation of law) without our prior written consent. We may assign them in connection with a merger, acquisition, reorganization, or sale of substantially all of our assets.

Independent contractors. You and AAL are independent contractors. Nothing in these Terms creates an agency, partnership, joint venture, franchise, or employment relationship.

Notices. We send notices to the email address associated with your account. You can send notices to legal@advisoratlasleads.com.

Counterparts and electronic signature. This Agreement may be accepted electronically as set forth in Section 1 and is effective without a physical signature.

26. Contact

Questions about these Terms: legal@advisoratlasleads.com Billing questions and refund requests: disputes@advisoratlasleads.com Privacy questions and consumer requests: privacy@advisoratlasleads.com Security incidents: security@advisoratlasleads.com Mail: The Retirement Atlas LLC, [registered address]

End of AAL Advisor Terms of Service v2.0.