Partner Program Compliance & Disclosure Policy

This Partner Program Compliance & Disclosure Policy applies to participants in the LockTrust Partner Program (“Partners”). This policy is designed to ensure compliance with applicable laws, advertising regulations, and payment network requirements.

1. Referral Compensation Disclosure

Partners may receive compensation for referring businesses to LockTrust.

In accordance with Federal Trade Commission (FTC) guidelines, Partners must clearly disclose when they may receive compensation related to referrals.

Examples of acceptable disclosures include:

• “I may receive compensation if you sign up for LockTrust.”

• “This is a referral and I may earn a commission.”

Disclosures should be clear, conspicuous, and easy for businesses to understand.

2. Honest and Accurate Representation

Partners must accurately represent LockTrust services.

Partners may not:

• Make misleading statements about LockTrust

• Guarantee approval of merchant accounts

• Misrepresent pricing, features, or services

• Claim endorsement by financial institutions unless authorized

All marketing materials must be truthful and not deceptive.

3. Payment Network Compliance

Partners must comply with the rules of payment networks including:

• Visa

• Mastercard

• American Express

• Discover

• NACHA (for ACH payments)

Partners may not promote payment services in ways that violate payment network requirements or applicable financial regulations.

4. Prohibited Marketing Practices

Partners may not engage in:

• Spam email or unsolicited bulk messaging

• Misleading advertisements

• False claims about savings or pricing

• High-pressure or deceptive sales tactics

• Marketing to restricted or prohibited industries

LockTrust may remove Partners from the Program for violating these rules.

5. Trademark and Branding

Partners may not use LockTrust logos, trademarks, or branding without written permission.

Partners may not create websites, advertisements, or marketing materials that imply they are LockTrust or represent themselves as LockTrust employees.

6. Data Privacy and Confidentiality

Partners must protect any confidential or personal information obtained during referral activities.

Partners must comply with applicable privacy laws including:

• U.S. data protection laws

• Applicable consumer privacy regulations

Partners may not collect or store sensitive payment data.

7. Compliance Monitoring

LockTrust may monitor partner marketing activities to ensure compliance with this policy.

Partners may be required to:

• Modify marketing materials

• Provide clarification regarding promotions

• Remove non-compliant content

Failure to comply may result in suspension or termination from the Partner Program.

8. Violations

LockTrust may suspend or terminate any Partner that violates this policy.

LockTrust may also withhold referral compensation related to activities that violate legal or compliance requirements.

9. Updates to This Policy

LockTrust may update this policy from time to time to reflect regulatory changes or program updates.

Continued participation in the Partner Program constitutes acceptance of the updated policy.

10. Contact

Questions regarding compliance or this policy may be directed to: