WELLTHI TECHNOLOGIES, INC. PLATFORM DISCLOSURES AND DISCLAIMERS
Overview.
Wellthi Technologies, Inc., and its subsidiaries, affiliates, and successors (collectively, “Wellthi”), is the operator of, and moderator of communications on, the Wellthi mobile application (the “Site”). Wellthi in providing the Site to users (a “User”) serves as a services provider to one or more regulated financial entities including, but not limited to, Citizens Bank, N.A. (“Citizens”) and Citizens Securities, Inc., a registered broker-dealer with the Securities and Exchange Commission (the “SEC”) and various state regulators, an investment adviser with the SEC, and is a member of the Financial Industry Regulatory Authority (“FINRA”) and Securities Investor Protection Corporation (“SIPC”), including its affiliates, representatives, and/or investment adviser representatives (collectively, “CSI Financial Advisors”). In its role as provider of the Site, Wellthi does not endeavor to engage in or provide, nor does it believe that it is engaged in or that it provides, any activity or services for which it would otherwise be required to be registered with the SEC, FINRA, SIPC, or any state-level securities regulator as a broker, dealer, investment adviser, investment adviser representative, or in any similar capacity, and hereby disclaims any such affiliation with respect to any other person including, but not limited to, Citizens and CSI Financial Advisors.
No Investment Advice; No Provision of Advisory Services.
Notwithstanding anything to the contrary in the foregoing, Wellthi does not endeavor to engage in or provide, nor does it believe that it is engaged in or that it provides, any activity or services for which it would otherwise be required to be registered with the SEC, FINRA, SIPC, or any state-level securities regulator as a broker, dealer, investment adviser, investment adviser representative, or in any similar capacity, and hereby disclaims any such affiliation with respect to any other person including, but not limited to, Citizens and CSI Financial Advisors. In recognition of the foregoing, no statement or other content shared on the Site is intended or shall be deemed to constitute investment advice or the provision of advisory services. No direct or indirect communication or interaction by a User of the Site with Citizens or CSI Financial Advisors through the Site shall create any fiduciary duty or obligation to on the part of Wellthi.
Further, any interactions through the Site with respect to Citizens and/or CSI Financial Advisors, including, but not limited to, any links provided to the respective websites, bios, and contact information for Citizens, CSI Financial Advisors, and their respective personnel is not intended to be, and shall not be construed as, any endorsement, solicitation, referral, and/or recommendation regarding the performance, ability, reputation, character, sufficiency, advisability, and/or adequacy, or for the use, retention, and/or selection, of Citizens, CSI Financial Advisors, and their respective personnel of Citizens, CSI Financial Advisors, and their respective personnel with respect to the User’s individual financial and/or investment needs. Notwithstanding any information you share through the Site, Wellthi shall have no duty to provide or be deemed to have provided any advice, recommendation, or other information applicable to your individual financial circumstances. For the avoidance of doubt, Wellthi’s provision of any links provided to the respective websites, bios, and contact information for Citizens, CSI Financial Advisors, and their respective personnel is not intended to be, and shall not be construed as an endorsement, solicitation, referral, and/or recommendation regarding the performance, ability, reputation, character, sufficiency, advisability, and/or adequacy of, or the subsequent use, retention, and/or selection by, a User of Citizens, CSI Financial Advisors, and/or their respective personnel for any purpose whatsoever, and that Wellthi affirmatively disclaims any assertion, assumption, or notion that the provision of such links to websites, bios, and contact information constitutes “investment advice” or the provision of “investment advisory services.”
No Advisory Services Recommendations, Endorsements, or Solicitation.
Notwithstanding the disclaimers set forth above regarding endorsement, solicitation, or recommendation of Citizens, CSI Financial Advisors, and their respective personnel, to the extent that Wellthi’s provision of the Site and/or any links provided to the respective websites, bios, and contact information for Citizens, CSI Financial Advisors, and their respective personnel, are deemed to constitute an “endorsement” under Rule 206(4)-1 of the Investment Advisers Act of 1940 (the “Marketing Rule”), Wellthi is required to make the following disclosures:
No Securities, Tax, Financial, or Legal Advice.
Notwithstanding anything to the contrary, no statement or other content shared on the Site by Wellthi is intended or shall be deemed to recommend any transaction in any security. Furthermore, notwithstanding anything to the contrary, no statement or other content shared on the Site by Wellthi is intended, or shall be deemed, to constitute an offer, purchase, or sale of security.
No statement or other content shared on the Site by Wellthi is intended or shall be deemed to constitute tax or financial planning advice. The User agrees to seek advice from an accountant or other qualified tax advisor regarding any tax questions, including any such questions relating to discussions or other content available through the Site.
Wellthi never provide legal advice, including in use of the Site. The User agree to seek advice from a qualified attorney regarding any legal questions, including any such questions relating to discussions or other content available through the Site.
