Effective: August 31, 2022

These Terms of Service ("Terms") govern your access to and use of INTΞGRITY’s (or "we") websites, mobile applications, and other online products and services (collectively, the "Services"). By clicking your assent (e.g. "Continue," "Sign-in," or "Sign-up") or by utilizing our Services, you consent to these Terms, including the mandatory arbitration provision and class action waiver in the Resolving Disputes; Binding Arbitration Section.

Our Privacy Policy describes how we gather and utilize your information, while our Rules detail your duties when utilizing our Services. You agree to be bound by these Terms and our Rules by utilizing our Services. Please refer to our Privacy Statement for details on how we collect, utilize, disclose, and otherwise manage your information.

Please contact us at hello@int3grity.com if you have any queries regarding these Terms or our Services.

Account Details and Responsibilities

You are responsible for your use of the Services and any content you contribute, including compliance with all relevant laws. The Services may host content that is protected by the intellectual property rights of third parties. Please do not copy, post, download, or distribute content without permission.

You must adhere to our Rules when using the Services.

To use any or all of our services, you may need to register for an account. Contribute to the protection of your account. Protect your account's password, and maintain accurate account details. We advise you not to share your password with anyone else.

If you are accepting these Terms and using the Services on behalf of someone else (such as another person or entity), you confirm that you are allowed to do so, and the words "you" or "your" in these Terms refer to that other person or entity.

You must be at least 13 years old to access our services.

If you use the Services to access, collect, or otherwise utilize the personal information of other INTΞGRITY users ("Personal Information"), you agree to comply with all applicable laws. You also undertake not to sell any Personal Information, where "sell" has the meaning ascribed to it by relevant legislation.

For Personal Information you provide to us (as a Newsletter Editor, for example), you represent and warrant that you have lawfully collected the Personal Information and that you or a third party have provided all required notices and obtained all required consents prior to collecting the Personal Information. You further represent and warrant that INTΞGRITY’s use of such Personal Information in accordance with the purposes for which you provided the Personal Information will not violate, misappropriate, or infringe any rights of a third party (including intellectual property rights or privacy rights) or cause us to violate any applicable laws.

The Services' User Content

INTΞGRITY may monitor your conduct and material for compliance with these Terms and our Rules, and reserves the right to remove any content that violates these guidelines.

INTΞGRITY maintains the right to remove or disable content that is accused to violate the intellectual property rights of others, as well as to cancel the accounts of repeat infringers. We respond to notifications of alleged copyright violations if they comply with the law; please report such notices using our Copyright Policy.

Ownership and Rights

You maintain ownership of all content that you submit, upload, or display on or through the Services.

By submitting, posting, or displaying content on or through the Services, unless otherwise agreed in writing, you grant INTΞGRITY a nonexclusive, royalty-free, worldwide, fully paid, and sublicensable license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, publicly perform and display your content and any name, username or likeness provided in connection with your content in all media formats and distribution methods now known or later developed.

INTΞGRITY requires this license because you are the owner of your material, and INTΞGRITY cannot show it across its multiple platforms (mobile, online) without your consent.

This type of license is also required for content distribution throughout our Services. For example, you may publish a piece on INTΞGRITY. It is duplicated as versions on both our website and app, and distributed to many locations on INTΞGRITY, including the homepage and reading lists. A tweak could be that we display a fragment of your work as a preview (rather than the entire post), with attribution. An example of a derivative work might be a list of top authors or quotations on INTΞGRITY that includes chunks of your article, again with full attribution. This license solely applies to our Services and does not grant us permissions outside of our Services.

So long as you comply with these Terms, INTΞGRITY grants you a limited, non-exclusive, personal, and non-transferable license to access and utilize our Services.

Copyright, trademark, and other United States and international laws protect the Services. These Terms do not grant you any right, title, or interest in the Services, the material posted by other users on the Services, or INTΞGRITY’s trademarks, logos, or other brand characteristics.

In addition to the content you submit, post, or display on our Services, we appreciate your feedback, which may include your thoughts, ideas, and suggestions regarding our Services. This input may be used for any reason at our sole discretion and without obligation to you. We may treat your comments as non-confidential.

We reserve the right, at our sole discretion, to discontinue the Services or any of its features. In addition, we reserve the right to impose limits on use and storage, and to remove or restrict the distribution of content on the Services.

Termination

You are allowed to terminate your use of our services at any time. We have the right to stop or cancel your use of the Services with or without notice.

Moving and Processing Information

To enable us to deliver our Services, you accept that we may handle, transfer, and retain information about you in the United States and other countries, where you may not enjoy the same rights and protections as you do under local law.

Indemnification

To the maximum extent permitted by applicable law, you will indemnify, defend, and hold harmless INTΞGRITY, and our officers, directors, agents, partners, and employees (collectively, the "INTΞGRITY Parties"), from and against any losses, liabilities, claims, demands, damages, expenses or costs ("Claims") arising out of or relating to your violation, misappropriation, or infringement of any rights of another (including intellectual property rights or privacy rights). You undertake to promptly notify INTΞGRITY Parties of any third-party Claims, to assist INTΞGRITY Parties in fighting such Claims, and to pay any fees, charges, and expenses connected with defending such Claims (including attorneys' fees). You further agree that, at INTΞGRITY’s sole discretion, the INTΞGRITY Parties will govern the defense or settlement of any third-party Claims.

Disclaimers — Services Provided "As Is"

INTΞGRITY strives to provide you with excellent Services, but there are certain things we cannot guarantee. Utilization of our services is at your own risk. You acknowledge that our Services and any content uploaded or shared by users on the Services are given "as is" and "as available" without explicit or implied warranties of any kind, including warranties of merchantability, fitness for a particular purpose, title, and non-infringement. In addition, INTΞGRITY does not represent or promise that our Services are accurate, comprehensive, dependable, up-to-date, or error-free. No advice or information gained from INTΞGRITY or via the Services shall create any warranty or representation unless expressly set forth in this section. INTΞGRITY may provide information on third-party products, services, activities, or events, or we may permit third parties to make their material and information accessible via our Services (collectively, "Third-Party Content"). We neither control nor endorse any Third-Party Content, nor do we make any claims or warranties about it. Accessing and utilizing Third-Party Content is at your own risk. The disclaimers in this section may not apply to you if they are prohibited in your location.

Limitation of Liability

We do not exclude or limit our obligation to you where it would be unlawful to do so; this includes any liability for the gross negligence, fraud, or willful misconduct of INTΞGRITY or the other INTΞGRITY Parties in providing the Services. In jurisdictions where the foregoing exclusions are not permitted, our liability to you is limited to losses and damages that are reasonably foreseeable as a result of our failure to exercise reasonable care and skill or breach of contract with you. This paragraph does not impact consumer rights that cannot be waived or limited by contract.

In jurisdictions that permit liability exclusions or limits, INTΞGRITY and INTΞGRITY Parties will not be liable for:

(a) Any indirect, consequential, exemplary, incidental, punitive, or extraordinary damages, or any loss of use, data, or profits, based on any legal theory, even if INTΞGRITY or the other INTΞGRITY Parties were advised of the potential of such damages.

(b) Except for the types of liability we cannot limit by law (as described in this section), we limit the total liability of INTΞGRITY and the other INTΞGRITY Parties for any claim arising out of or related to these Terms or our Services, regardless of the form of action, to $100.00 USD.

Arbitration; Resolution of Disputes

We intend to address your concerns without filing a formal lawsuit. Before making a claim against INTΞGRITY, you agree to contact us and attempt to resolve the dispute informally by emailing hello@int3grity.com or by sending certified mail to INTΞGRITY, P.O. JOY, 479 Jessie St, San Francisco, CA 94103. The notice must (a) contain your name, address, email address, and telephone number; (b) identify the nature and grounds of the claim; and (c) detail the relief requested. Our notice to you will be sent to the email address linked with your online account and will contain the information specified in the preceding section. Any party may commence a formal procedure if we are unable to reach a resolution within thirty (30) days of the date of any notice.

Please read the following section carefully because it compels you to arbitrate certain claims and disputes with INTΞGRITY and limits the method in which you can seek redress from us, unless you opt out of arbitration by following the steps provided below. This arbitration provision does not permit class or representative lawsuits or arbitrations. In addition, arbitration prohibits you from filing a lawsuit or having a jury trial.

(a) Absence of Representative Actions You and INTΞGRITY agree that any dispute arising out of or relating to these Terms or our Services is personal to you and INTΞGRITY and will be resolved entirely via individual action, and not by class arbitration, class action, or other representative procedure.

(b) Dispute Arbitration. Except for small claims disputes in which you or INTΞGRITY seeks to bring an individual action in small claims court located in the county where you reside and disputes in which you or INTΞGRITY seeks injunctive or other equitable relief for the alleged infringement or misappropriation of intellectual property, you and INTΞGRITY waive your rights to a jury trial and to have any other dispute arising out of or relating to these Terms or our Services, including claims related to privity of contract, decided by a jury. All Disputes submitted to JAMS shall be decided by confidential, binding arbitration before a single arbitrator. If you are a consumer, you may choose to have the arbitration in your county of residence. A "consumer" is a person who uses the Services for personal, family, or household purposes for the purposes of this provision. You and INTΞGRITY agree that Disputes shall be resolved using the JAMS Streamlined Arbitration Rules and Procedures ("JAMS Rules"). The latest version of the JAMS Rules is accessible on the JAMS website and is incorporated herein by reference. Either you accept and agree that you have read and comprehended the JAMS Rules or you forfeit your right to read the JAMS Rules and any claim that the JAMS Rules are unreasonable or should not apply for any reason.

(c) You and INTΞGRITY agree that these Terms affect interstate commerce and that the enforceability of this provision is subject to the Federal Arbitration Act, 9 U.S.C. 1 et seq. (the "FAA"), to the maximum extent permissible by applicable law. As limited by the FAA, these Terms, and the JAMS Rules, the arbitrator will have sole authority to make all procedural and substantive judgments regarding any Dispute, and to grant any remedy that would otherwise be available in court, including the authority to determine arbitrability. The arbitrator may only conduct an individual arbitration and may not consolidate the claims of more than one party, preside over any sort of class or representative procedure, or preside over any proceeding involving more than one party.

d) The arbitration will permit the discovery or exchange of nonconfidential information pertinent to the Dispute. The arbitrator, INTΞGRITY, and you will maintain the confidentiality of all arbitration proceedings, judgments, and awards, as well as any information gathered, prepared, or presented for the purposes of the arbitration or relating to the Dispute(s) therein. Unless the law specifies otherwise, the arbitrator will have the right to make decisions that protect confidentiality. The duty of confidentiality does not apply where disclosure is required to prepare for or conduct the arbitration hearing on the merits, in connection with a court application for a preliminary remedy, in connection with a judicial challenge to an arbitration award or its enforcement, or where disclosure is otherwise required by law or judicial decision.

e) You and INTΞGRITY agree that for any arbitration you begin, you will pay the filing fee (up to $250 if you are a consumer) and INTΞGRITY will pay the remaining JAMS fees and costs. INTΞGRITY will pay all JAMS fees and costs for any and all arbitrations it initiates. You and INTΞGRITY agree that the state and federal courts of California and the United States located in San Francisco have exclusive jurisdiction over any appeals and the implementation of an arbitration award.

(f) Any Dispute must be filed within one year after the relevant claim arose; otherwise, the Dispute is permanently barred, meaning that neither you nor INTΞGRITY will be able to assert the claim.

(g) You have the right to opt-out of binding arbitration within 30 days of the date you initially accepted the terms of this section by sending an email to hello@int3grity.com. For the opt-out notification to be effective, it must include your full name and address and clearly explain your intent to opt out of binding arbitration. By declining binding arbitration, you consent to the resolution of Disputes in accordance with "Governing Law and Venue" below.

(h) If any portion of this section is found to be unenforceable or unlawful for any reason: (1) the unenforceable or unlawful provision shall be severed from these Terms; (2) the severance of the unenforceable or unlawful provision shall have no effect whatsoever on the remainder of this section or the parties' ability to compel arbitration of any remaining claims on an individual basis pursuant to this section; and (3) to the extent that any claims must therefore proceed on an individual basis, the parties agree to arbitrate those claims on an individual basis. In addition, if it is determined that any portion of this section prohibits an individual claim seeking public injunctive relief, that provision will be null and void to the extent that such relief may be sought outside of arbitration, and the balance of this section will be enforceable.

Statute and Location

These Terms and any dispute that may arise between you and INTΞGRITY are governed by California law, excluding its conflict of law provisions. Any issue between the parties that is not arbitrable or cannot be heard in small claims court will be determined by the state or federal courts of California and the United States, sitting in San Francisco, California.

Some nations have regulations that require agreements to be controlled by the consumer's country's laws. These statutes are not overridden by this paragraph.

Amendments

Periodically, we may make modifications to these Terms. If we make modifications, we will notify you by sending an email to the address connected with your account, providing an in-product message, or amending the date at the top of these Terms. Unless we specify otherwise in our notification, the modified Terms will take effect immediately, and your continued use of our Services after we issue such notice indicates your acceptance of the changes. If you do not accept the updated Terms, you must cease using our services.

Severability

If any section or portion of a provision of these Terms is determined to be unlawful, void, or unenforceable, that provision or part of the provision shall be deemed severable from these Terms and shall not affect the validity and enforceability of the other terms.

Miscellaneous INTΞGRITY’s omission to assert or enforce any right or term of these Terms is not a waiver of such right or provision. These Terms and the terms and policies specified in the Other Terms and Policies that May Apply to You Section constitute the complete agreement between the parties pertaining to the subject matter hereof and supersede all prior agreements, statements, and understandings between the parties. The section headings in these Terms are for convenience only and have no legal or contractual significance. The use of the word "including" shall be taken to mean "including without limitation." Unless otherwise specified, these Terms are intended solely for the benefit of the parties and are not intended to confer third-party beneficiary rights on any other person or entity. You consent to the use of electronic means for our communications and transactions.

Effective date: August 31, 2022

This Privacy Statement describes how INTΞGRITY ("we," or "us") collects, uses, and discloses your personal information. This Privacy Statement applies when you use our websites, mobile applications, and other online products and services that link to this Privacy Statement (collectively, our "Services"), communicate with our customer care team, interact with us on social media, or otherwise interact with us.

This Privacy Policy may be modified from time to time. If we make modifications, we will update the date at the top of this policy and, in certain instances, we may give you extra notice (such as adding a statement to our website or providing you with a notification). We encourage you to routinely review this Privacy Statement to remain informed about our information practices and available options.

INFORMATION COLLECTION

The Data You Provide to Us

We collect information that you directly supply to us. When you register an account, fill out a form, submit or post material through our Services, contact us via third-party platforms, request customer assistance, or otherwise communicate with us, you provide us with information directly. We may collect your name, display name, username, bio, email address, company information, your published content, including your avatar image, photos, posts, responses, and any other information you voluntarily give.

In certain instances, we may collect the information you submit about third parties. We will use your information to fulfill your request and will not send emails to your contacts unrelated to your request unless they separately opt to receive such communications or connect with us in some other way.

We do not collect payment details via the Services.

Automatically Collected Information When You Communicate with Us

In certain cases, we automatically collect the following information:

We gather data regarding your behavior on our Services, such as your reading history and when you share links, follow users, highlight posts, and like posts.

Device and Usage Information: We gather information about the device and network you use to access our Services, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information regarding your activities on our Services, including access times, pages viewed, links clicked, and the page you visited immediately prior to accessing our Services.

Information Obtained Through Cookies and Comparable Tracking Technologies: We collect information about you through tracking technologies including cookies and web beacons. Cookies are little data files kept on your computer's hard disk or device's memory that assist us in enhancing our Services and your experience, determining which areas and features of our Services are the most popular, and tracking the number of visitors. Web beacons (also known as "pixel tags" or "clear GIFs") are electronic pictures that we employ on our Services and in our communications to assist with cookie delivery, session tracking, and usage analysis. We also partner with third-party analytics providers who use cookies, web beacons, device identifiers, and other technologies to collect information regarding your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, and links clicked. INTΞGRITY and others may use your information to, among other things, analyze and track data, evaluate the popularity of certain content, present content tailored to your interests on our Services, and better comprehend your online activities. See Your Options for additional information on cookies and how to disable them.

Information Obtained from Outside Sources

We acquire information from external sources. We may collect information about you, for instance, through social networks, accounting service providers, and data analytics service providers. In addition, if you create or log into your INTΞGRITY account via a third-party platform (such as Apple, Facebook, Google, or Twitter), we will have access to certain information from that platform, including your name, lists of friends or followers, birthday, and profile picture, in accordance with the authorization procedures determined by that platform.

We may derive information about you or make assumptions based on the data we gather. We may deduce your location based on your IP address or your reading interests based on your reading history, for instance.

USAGE OF INFORMATION

We use the information we collect to deliver, maintain, and enhance our Services, including publishing and distributing user-generated content, and customizing the posts you see. Additionally, we utilize collected information to: create and administer your INTΞGRITY account;

Send transaction-related information, including confirmations, receipts, and user satisfaction surveys;

Send you technical notices, security alerts, and administrative and support messages;

Respond to your comments and queries and offer support;

Communicate with you about new INTΞGRITY content, goods, services, and features, as well as other news and information that we believe may be of interest to you (see Your Choices for details on how to opt out of these communications at any time);

Monitor and evaluate usage, trends, and activities associated with our Services;

Detect, investigate, and prevent security incidents and other harmful, misleading, fraudulent, or illegal conduct, and safeguard INTΞGRITY’s and others' rights and property;

Comply with our legal and financial requirements; and Carry out any other purpose specified to you at the time the information was obtained.

SHARING OF INFORMATION

We share personal information where required by law or as otherwise specified in this policy:

Personal information is shared with other Service users. If you use our Services to publish content, make comments, or send private messages, for instance, certain information about you, such as your name, photo, bio, and other account information you may supply, as well as information about your activity on our Services, will be available to others (e.g., your followers and who you follow, recent posts, likes, highlights, and responses).

We share personal information with vendors, service providers, and consultants who require access to such information to perform services on our behalf, such as companies that assist us with web hosting, storage, and other infrastructure, analytics, fraud prevention, and security, customer service, communications, and marketing.

We may release personally identifiable information if we think that doing so is in line with or required by any relevant law or legal process, including authorized demands from public authorities to meet national security or law enforcement obligations. If we intend to disclose your personal information in response to a court order, we will provide you with prior notice so that you may contest the disclosure (for example, by seeking court intervention), unless we are prohibited by law or believe that doing so could endanger others or lead to illegal conduct. We shall object to inappropriate legal requests for information regarding users of our Services.

If we believe your actions are inconsistent with our user agreements or policies, if we suspect you have violated the law, or if we believe it is necessary to defend the rights, property, and safety of INTΞGRITY, our users, the public, or others, we may disclose your personal information.

We share personal information with our attorneys and other professional advisers when necessary for obtaining counsel or otherwise protecting and managing our business interests.

We may disclose personal information in conjunction with or during talks for any merger, sale of corporate assets, financing, or purchase of all or part of our business by another firm.

Personal information is transferred between and among INTΞGRITY, its current and future parents, affiliates, subsidiaries, and other companies under common ownership and management.

We will only share your personal information with your permission or at your instruction.

We also disclose aggregated or anonymized data that cannot be used to identify you.

IMPLEMENTATIONS FROM THIRD PARTIES

Some of the content shown on our Services is not hosted by INTΞGRITY. Users are able to publish content hosted by a third party but embedded in our pages ("Embed"). When you interact with an Embed, it can send information to the hosting third party just as if you had visited the hosting third party's website directly. When you load an INTΞGRITY post page with a YouTube video Embed and view the video, for instance, YouTube collects information about your behavior, such as your IP address and how much of the video you watch. INTΞGRITY has no control over the information that third parties acquire via Embeds or what they do with it. This Privacy Statement does not apply to data gathered via Embeds. Before interacting with the Embed, it is recommended that you review the privacy policy of the third party hosting the Embed, which governs any information the Embed gathers.

INFORMATION TRANSFER TO THE UNITED STATES AND OTHER NATIONS

INTΞGRITY’s headquarters are located in the United States, and we have operations and service suppliers in other nations. Therefore, we and our service providers may transmit, store, or access your personal information in jurisdictions that may not provide a similar degree of data protection to your home jurisdiction. For instance, we transfer personal data to Amazon Web Services, one of our service providers that processes personal information on our behalf in numerous data centers throughout the world, including those indicated above. We shall take measures to guarantee that your personal information is adequately protected in the jurisdictions where it is processed.

YOUR SETTINGS

Account Specifics

You can access, modify, delete, and export your account information at any time by login into the Services and visiting the Settings page. Please be aware that if you delete your account, we may preserve certain information on you as needed by law or for our legitimate business purposes.

Cookies

The majority of web browsers accept cookies by default. You can often configure your browser to delete or refuse cookies if you wish. Please be aware that removing or rejecting cookies may impact the accessibility and performance of our services.

Communications

You may opt out of getting certain messages from us, such as digests, newsletters, and activity notifications, by following the instructions contained within those communications or by visiting the Settings page of your account. Even if you opt out, we may still send you emails regarding your account or our ongoing business relationships.

Mobile Push Notifications

We may send push notifications to your mobile device with your permission. You can cancel these messages at any time by modifying your mobile device's notification settings.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act, or "CCPA" (Cal. Civ. Code 1798.100 et seq. ), grants California residents some rights regarding their personal data. If you are a California resident, you are subject to this clause.

We have collected the following categories of personal information over the past year: identifiers, commercial information, internet or other electronic network activity information, and conclusions. Please refer to the section titled "Collection of Information" for specifics regarding the data points we gather and the sorts of sources from which we acquire them. We collect personal information for the business and marketing purposes outlined in the section on Use of Information. In the past 12 months, we have shared the following types of personal information to the following groups of recipients for business purposes:

Category of Personal Information: Identifiers
Categories of Recipients: Analytics Providers, Communication Providers, Custom Service Providers, Fraud Prevention and Security Providers, Infrastructure Providers, Marketing Providers, Payment Processors

Category of Personal Information: Commercial Information
Categories of Recipients: Analytics Providers, Infrastructure Providers, Payment Processors

Category of Personal Information: Internet or Other Electronic Network Activity Information
Categories of Recipients: Analytics Providers, Infrastructure Providers

Category of Personal Information: Inferences
Categories of Recipients: Analytics Providers, Infrastructure Providers

INTΞGRITY does not sell personally identifiable information.

You have the right, subject to certain limitations: (1) to request more information about the categories and specific pieces of personal information we collect, use, and disclose about you; (2) to request the deletion of your personal information; (3) to opt out of any future sales of your personal information; and (4) to not be discriminated against for exercising these rights. You may submit these requests by email to hello@int3grity.com. We shall not treat you differently if you exercise your rights under the CCPA.

If we receive your request from an authorized agent, we may request proof that you have granted the agent a valid power of attorney or that the agent otherwise possesses valid written authorization to submit requests on your behalf. This may involve requiring identity verification. Please contact us if you are an authorized agent wishing to make a request.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

This section applies to you if you are based in the European Economic Area ("EEA"), the United Kingdom, or Switzerland and have specific rights and safeguards regarding the processing of your personal data under relevant law.

Legal Justification for Processing

We will process your personal information based on the following legal grounds:

To fulfill our obligations under our agreement with you (e.g., providing the products and services you requested).

When we have a legitimate interest in processing your personal information to operate our business or to safeguard our legitimate interests, we will do so (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).

To meet our legal responsibilities (e.g., to maintain a record of your consents and track those who have opted out of non-administrative communications).

If we have your permission to do so (e.g., when you opt in to receive non-administrative communications from us). When consent is the legal basis for our processing of your personal information, you may at any time withdraw your consent.

Data Retention

We retain the personal information associated with your account so long as your account is active. If you close your account, your account information will be deleted within 14 days. We retain other personal data for as long as is required to fulfill the objectives for which it was obtained and for other legitimate business purposes, such as to meet our legal, regulatory, or other compliance responsibilities.

Data Access Requests

You have the right to request access to the personal data we hold on you and to get your data in a portable format, to request that your personal data be rectified or erased, and to object to or request that we restrict particular processing, subject to certain limitations. To assert your legal rights:

If you sign up for an INTΞGRITY account, you can request an export of your personal information at any time via the Settings website, or by visiting Settings and selecting Account from inside our app.

You can edit the information linked with your account on the Settings website, or by navigating to Settings and then Account in our app, and the Customize Your Interests page.

You may withdraw consent at any time by deleting your account via the Settings page, or by visiting Settings and then selecting Account within our app (except to the extent INTΞGRITY is prevented by law from deleting your information).

You may object to the use of your personal information at any time by contacting hello@int3grity.com.

Questions or Complaints

If we are unable to settle your concern over our processing of personal data, you have the right to file a complaint with the Data Protection Authority in your country. The links below provide access to the contact information for your Data Protection Authority.

For people in the EEA, please visit https://edpb.europa.eu/about-edpb/board/members en.

For persons in the United Kingdom, please visit https://ico.org.uk/global/contact-us.

For people in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

CONTACT US

Please contact us at hello@int3grity.com if you have any queries regarding this Privacy Statement.

Sam Bankman Fried (SDBF) is a legendary con man. But the NYT might not tell you that...

Since SBF's empire was revealed to be a lie, mainstream news organizations and commentators have failed to give readers a straightforward assessment. The New York Times and Wall Street Journal have uncovered many key facts about the scandal, but they have also soft-peddled Bankman-Fried's intent and culpability.

It's clear that the FTX crypto exchange and Alameda Research committed fraud to steal money from users and investors. That’s why a recent New York Times interview was widely derided for seeming to frame FTX’s collapse as the result of mismanagement rather than malfeasance. A Wall Street Journal article lamented FTX's loss of charitable donations, bolstering Bankman's philanthropic pose. Matthew Yglesias, court chronicler of the neoliberal status quo, seemed to whitewash his own entanglements by crediting SBF's money with helping Democrats in 2020 – sidestepping the likelihood that the money was embezzled.

Many outlets have called what happened to FTX a "bank run" or a "run on deposits," but Bankman-Fried insists the company was overleveraged and disorganized. Both attempts to frame the fallout obscure the core issue: customer funds misused.

Because banks lend customer funds to generate returns, they can experience "bank runs." If everyone withdraws at once, they can experience a short-term cash crunch but there won't be a long-term problem.

Crypto exchanges like FTX aren't banks. They don't do bank-style lending, so a withdrawal surge shouldn't strain liquidity. FTX promised customers it wouldn't lend or use their crypto.

Alameda's balance sheet blurs SBF's crypto empire.

The funds were sent to Alameda Research, where they were apparently gambled away. This is massive theft. According to a bankruptcy document, up to 1 million customers could be affected.

In less than a month, reporting and the bankruptcy process have uncovered a laundry list of decisions and practices that would constitute financial fraud if FTX had been a U.S.-regulated entity, even without crypto-specific rules. These ploys may be litigated in U.S. courts if they enabled the theft of American property.

The list is very, very long.

The many crimes of Sam Bankman-Fried and FTX

At the heart of SBF's fraud are the deep and (literally) intimate ties between FTX and Alameda Research, a hedge fund he co-founded. An exchange makes money from transaction fees on user assets, but Alameda trades and invests its own funds.

Bankman-Fried called FTX and Alameda "wholly separate" and resigned as Alameda's CEO in 2019. The two operations were closely linked. Bankman-Fried and Alameda CEO Caroline Ellison were romantically linked.

These circumstances enabled SBF's sin.  Within days of FTX's first signs of weakness, it was clear the exchange was funneling customer assets to Alameda for trading, lending, and investing. Reuters reported on Nov. 12 that FTX sent $10 billion to Alameda. As much as $2 billion was believed to have disappeared after being sent to Alameda. Now the losses look worse.

It's unclear why those funds were sent to Alameda or when Bankman-Fried betrayed his depositors. On-chain analysis shows most FTX to Alameda transfers occurred in late 2021, and bankruptcy filings show both lost $3.7 billion in 2021.

SBF's companies lost millions before the 2022 crypto bear market. They may have stolen funds before Terra and Three Arrows Capital, which killed many leveraged crypto players.

FTT loans and prints

CoinDesk's report on Alameda's FTT holdings ignited FTX and Alameda Research. FTX created this instrument, but only a small portion was traded publicly; FTX and Alameda held the rest. These holdings were illiquid, meaning they couldn't be sold at market price. Bankman-Fried valued its stock at the fictitious price.

FTT tokens were reportedly used as collateral for loans, including FTX loans to Alameda. Close ties between FTX and Alameda made the FTT token harder or more expensive to use as collateral, reducing the risk to customer funds.

This use of an internal asset as collateral for loans between clandestinely related entities is similar to Enron's 1990s accounting fraud. These executives served 12 years in prison.

Alameda's margin liquidation exemption

Alameda Research had a "secret exemption" from FTX's liquidation and margin trading rules, according to legal filings by FTX's new CEO.

FTX, like other crypto platforms and some equity or commodity services, offered "margin" or loans for trades. These loans are usually collateralized, meaning borrowers put up other funds or assets. If a margin trade loses enough money, the exchange will sell the user's collateral to pay off the initial loan.

Keeping asset markets solvent requires liquidating bad margin positions. Exempting Alameda would give it huge advantages while exposing other FTX users to hidden risks. Alameda could have kept losing positions open while closing out competitors. Alameda could lose more on FTX than it could pay back, leaving a hole in customer funds.

The exemption is criminal in multiple ways. FTX was fraudulently marketed overall. Instead of a level playing field, there were many customers.

Above them all, with shotgun poised, was Alameda Research.

Alameda front-running FTX listings

Argus says there's circumstantial evidence that Alameda Research had insider knowledge of FTX's token listing plans. Alameda was able to buy large amounts of tokens before the listing and sell them after the price bump.

If true, these claims would be the most brazenly illegal of Alameda and FTX's alleged shenanigans. Even if the tokens aren't formally classified as securities, insider trading laws may apply.

In a similar case this year, an OpenSea employee was charged with wire fraud for allegedly insider trading. This employee faces 20 years in prison for front-running monkey JPEGs.

Huge loans to executives

Alameda Research reportedly lent FTX executives $4.1 billion, including massive personal loans. Bankman-Fried received $1 billion in personal loans and $2.3 billion for an entity he controlled, Paper Bird. Nishad Singh, director of engineering, was given $543 million, and FTX Digital Markets co-CEO Ryan Salame received $55 million.

FTX has more smoking guns than a Texas shooting range, but this one is the smoking bazooka – a sign of criminal intent. It's unclear how most of the personal loans were used, but liquidators will have to recoup the money.

The loans to Paper Bird were even more worrisome because they created another related third party to shuffle assets. Forbes speculates that some Paper Bird funds went to buy Binance's FTX stake, and Paper Bird committed hundreds of millions to outside investments.

FTX Inner Circle: Who's Who

That included many FTX-backed VC funds. Time will tell if this financial incest was criminal fraud. It fits Bankman-pattern Fried's of using secret flows, leverage, and funny money to inflate asset prices.

FTT or loan 'bailouts'

Also. As the crypto bear market continued in 2022, Bankman-Fried proposed bailouts for bankrupt crypto lenders BlockFi and Voyager Digital. CoinDesk was among those deceived, welcoming SBF as a J.P. Morgan-style sector backstop.

In a now-infamous interview with CNBC's "Squawk Box," Bankman-Fried referred to these decisions as bets that may or may not pay off.

But maybe not. Bloomberg's Matt Levine speculated that FTX backed BlockFi with FTT money. This Monopoly bailout may have been intended to hide FTX and Alameda liabilities that would have been exposed if BlockFi went bankrupt sooner. This ploy has no name, but it echoes other corporate frauds.

Secret bank purchase

Alameda Research invested $11.5 million in the tiny Farmington State Bank, doubling its net worth. As a non-U.S. entity and an investment firm, Alameda should have cleared regulatory hurdles before acquiring a U.S. bank.

In the context of FTX, the bank's stake becomes "ominous." Alameda and FTX could have done more shenanigans with bank control. Compare this to the Bank for Credit and Commerce International's failed attempts to buy U.S. banks. BCCI was even nefarious than FTX and wanted to buy U.S. banks to expand its money-laundering empire.

The mainstream's mistakes

These are complex and nuanced forms of fraud that echo traditional finance models. This obscurity helped Bankman-Fried masquerade as an honest player and likely kept coverage soft after the collapse.

Bankman-Fried had a scruffy, nerdy image, like Mark Zuckerberg and Adam Neumann. In interviews, he spoke nonsense about an industry full of jargon and complicated tech. Strategic donations and insincere ideological statements helped him gain political and social influence.

SBF' s'Effective' Altruism Blew Up FTX

Bankman-Fried has continued to muddy the waters with disingenuous letters, statements, interviews, and tweets since his con collapsed. He's tried to portray himself as a well-intentioned but naive kid who made some mistakes. This is a softer, more pernicious version of what Trump learned from mob lawyer Roy Cohn. Bankman-Fried doesn't "deny, deny, deny" but "confuse, evade, distort."

It's mostly worked. Kevin O'Leary, who plays an investor on "Shark Tank," repeats Bankman-SBF's counterfactuals.  O'Leary called Bankman-Fried a "savant" and "probably one of the most accomplished crypto traders in the world" in a Nov. 27 interview with Business Insider, despite recent data indicating immense trading losses even when times were good.

O'Leary's status as an FTX investor and former paid spokesperson explains his continued affection for Bankman-Fried despite contradictory evidence. He's not the only one promoting Bankman-Fried. The disgraced son of two Stanford law professors will defend himself at Wednesday's DealBook Summit.

SBF's fraud and theft rival those of Bernie Madoff and Jho Low. Whether intentionally or through malign ineptitude, the fraud echoes Worldcom and Enron.

The Perverse Impacts of Anti-Money-Laundering

The principals in all of those scandals wound up either sentenced to prison or on the run from the law. Sam Bankman-Fried clearly deserves to share their fate.

Read the full article here.

I've written a lot about Y Combinator's success, but as any startup founder or investor knows, many startups fail.

Rebel Fund invests in the top 5-10% of new Y Combinator startups each year, so we focus on identifying and supporting the most promising technology startups in our ecosystem. Given the power law dynamic and asymmetric risk/return profile of venture capital, we worry more about our successes than our failures. Since the latter still counts, this essay will focus on the proportion of YC startups that fail.

Since YC's launch in 2005, the figure below shows the percentage of active, inactive, and public/acquired YC startups by batch.

As more startups finish, the blue bars (active) decrease significantly. By 12 years, 88% of startups have closed or exited. Only 7% of startups reach resolution each year.

YC startups by status after 12 years:

Half the startups have failed, over one-third have exited, and the rest are still operating.

In venture investing, it's said that failed investments show up before successful ones. This is true for YC startups, but only in their early years.

Below, we only present resolved companies from the first chart. Some companies fail soon after establishment, but after a few years, the inactive vs. public/acquired ratio stabilizes around 55:45. After a few years, a YC firm is roughly as likely to quit as fail, which is better than I imagined.

I prepared this post because Rebel investors regularly question me about YC startup failure rates and how long it takes for them to exit or shut down.

Early-stage venture investors can overlook it because 100x investments matter more than 0x investments.

YC founders can ignore it because it shouldn't matter if many of their peers succeed or fail ;)