LEGAL / REFERRAL & INCENTIVE PROGRAM POLICY

Referral & Incentive Program Policy

This is the general policy governing every referral and incentive program TrueLabel runs, including the Community Partner program. Specific rates, caps, tapers, and windows for a given program are published in that program's own dated Schedule A, within the bounds of this policy.

TrueLabel Collector Referral & Incentive Program Policy

Operated by: truelabel FZCO ("truelabel," "we," "us," "our"), operator of the TrueLabel physical-AI data-collection marketplace (the "Platform"). Applies to: TrueLabel collectors who affirmatively opt in to either incentive leg described below. Policy version: v1.0 Effective date: July 4, 2026 Governing law of this Policy (subject to Sections 3.6 and 19.3): United Arab Emirates, Dubai International Financial Centre (DIFC). Hosted at: https://truelabel.ai/legal/referral-incentive-program-policy Questions / support: [email protected]

What this document is. This is the general Referral & Incentive Program Policy: the framework and the protections that apply to every referral or incentive program TrueLabel runs. It does not hardcode the mechanics of any single program. The specific rates, caps, gates, tapers, and windows for a given program are published in that program's own dated Schedule A, within the bounds of this Policy (Section 6). The Schedule A at the end of this document states the general default framework values that apply unless a specific program's published Schedule A provides otherwise. This Policy may be updated from time to time; changes are prospective only, and the then-current published version governs (Section 18).

The short version (plain-language summary)

Translation / Traducción / Tradução. This whole Policy — not just this box — is published in English, and full Spanish, Portuguese, and Arabic versions are made available before any collector in those languages is asked to accept. You will be shown, and asked to accept, the version in your own language. If you live in Latin America, or anywhere local law requires it, the Spanish or Portuguese version is the one that legally counts for you. If anything is unclear, ask us before you opt in.

This box is a friendly summary in plain words. It is not the full rules — the numbered sections and the figures table (Schedule A) are what count. If the summary and a numbered section ever disagree, the numbered section wins.

Two optional ways to earn a little extra by bringing good people to TrueLabel

Buddy Referral — invite a friend to become a collector. When they get paid for accepted footage, you earn a small bonus for each accepted hour they are paid for. This bonus is currently $0.50 per accepted hour. These are not typical earnings. Most people will earn a small amount or nothing, and no amount is promised or guaranteed.
Community Partner — for people who bring many collectors. A higher per-hour bonus, but you must pass an identity check and be approved first, and your money is held until that clears. This bonus is currently $1.00 per accepted hour. These are not typical earnings. Most people will earn a small amount or nothing, and no amount is promised or guaranteed.

You only earn from the real, accepted, paid work of people you personally invited. You never earn just for signing people up. You never earn from the people that your friends later invite. There is no second level, no "downline," and nothing to buy or pay to join.
It costs nothing to opt in, and it is your choice.

The parts you must read — these can delay, reduce, or take back money

You may earn nothing on a real, honest referral. Your bonus depends on the person you invited getting paid — and that only happens if they pass their own identity check and reach their own minimum payout. You cannot see or control any of that. If they never verify, or never earn enough to get paid, you get nothing from that referral.
The person you invite gets no bonus from the referral. The bonus is paid only to you. Never tell anyone they get a signup, join, or referral bonus — they don't.
When you tell friends, you must be honest. You must say that you can get paid for referrals, you must not promise them any earnings, "easy money," or a signup bonus, and you must not exaggerate. Breaking these honesty rules can cost you access to the Program.
For a brand-new person you invite, we may hold your whole bonus (not just part of it), and for longer than usual, until their footage builds a track record. For people whose footage has already proven reliable, we normally hold back only a small part (currently about 20%) for about 45 days. Either way this is because some accepted hours can be reversed later.
A bonus you were already paid can be reduced later — even through nothing you did wrong. If the person you invited has hours rejected or corrected after you were paid, we take it back only by lowering your future bonuses — never by charging your card or touching your own base pay. We can only do this for up to 12 months after a bonus was paid. If you have stopped earning bonuses by then, we simply absorb the difference — you never owe us money.
You must build up at least $10 in bonuses before we pay any of it out. Small $0.50 amounts add up until they reach $10. If your account closes, or the Program ends, we still pay you any real earned bonus you have built up — even if it is under $10 (after the identity check). We do not quietly keep earned money.
Each program sets its own rules — any starter step, weekly limit, taper, and windows — in its own published terms (Schedule A), and they can differ from country to country. Some programs ask you to finish a one-time starter step before Buddy bonuses begin; others don't. Most programs cap Buddy bonus at a flat weekly amount (currently $25/week) that does not depend on your own pay. Only where local law allows, a specific program may instead tie that weekly limit to your own pay that week — and where it does, a week you don't film can mean about $0 in bonus that week. Your program's Schedule A tells you which rules apply to you.
Bonus over the weekly limit rolls over, but not forever — it expires after about 8 weeks. If you can't fit it under the limit within that time, that extra is lost. So it is possible to have a friend do real accepted work and still not receive a bonus for all of it. This is a real limit — please read Section 8.3.
Community Partner bonuses stay unpaid until identity and anti-fraud checks clear. We tell you what's needed and promise a maximum review time.
Everyone must pass an identity and sanctions check before any bonus is paid — including Buddy Referral. If you are located in, or a resident of, a fully-embargoed country (Cuba, Iran, North Korea, Syria, or the Crimea/Donetsk/Luhansk regions), you cannot take part or be paid at all. For some other countries (for example Venezuela), we do not ban everyone — we check each specific person against the applicable sanctions lists, and you can take part unless you are personally listed or blocked.
For footage recorded through the Datoric app, Datoric — not TrueLabel — is who you contract with and who pays you for that footage. TrueLabel only pays the separate referral bonus. If Datoric's reported hours are the reason a bonus is held, you can ask to see those hours and appeal.
You get USD amounts, minus currency conversion and transfer fees, so what lands can be a bit less than the headline number. If a payout is blocked or unclaimed, we hold it and contact you — we don't just keep it.
You are an independent contractor. You handle your own taxes. Your work quality never changes your bonuses, and your bonuses never change your work. The only thing that can affect your collector account is conduct that breaks the Terms of Service on its own, like fake identities or fraud.
If you disagree with a decision, you can appeal for free. A different reviewer looks at it, in your own language, online — you never have to travel or hire a lawyer to dispute a small bonus.

When money actually reaches you (plain timeline)

The friend you invited gets paid for accepted hours → your bonus starts to build.
We hold back part of it (a small part for proven footage; possibly all of it for a brand-new person) for about 45 days, in case some hours get reversed.
Once the hold clears and your total built-up bonus reaches $10, it is paid out on the next monthly bonus run, by Wise or bank transfer, minus conversion/transfer fees.
If hours are reversed later, your future bonuses go down to make up for it (never a charge to you).

One worked example

Say you invite Ana. In one week she is paid for 20 accepted hours. At $0.50/hour that is $10 for you. These are not typical earnings. Most people earn a small amount or nothing, and no amount is guaranteed. The weekly limit in most countries is $25, so the full $10 counts. (In the few countries where the limit is tied to your own pay, a week you didn't film could mean a $0 limit that week, and the $10 would roll over — and could expire after about 8 weeks if it never fits under the limit.) We hold back part of it for about 45 days, and you must reach the $10 total before it is paid out on the next monthly bonus run.

1. Definitions

1.1. "Accepted Hour" — one hour of submitted footage that has passed quality review, been approved, and been paid to the collector who recorded it. Hours that are pending, rejected, duplicated, corrected, reversed, or unpaid are not Accepted Hours. Accepted-Hour status is provisional until it settles at the close of the Finalization Window (Section 12.5); it can be reversed or corrected before then, and, for good-faith corrections, within the Forward-Offset lookback afterward (Section 12.6), and at any time for fraud (Section 12.3). Footage routed through our partner application Datoric is reported by Datoric; once confirmed, those reported hours are treated as Accepted Hours subject to the same finalization, corrections, and screening (Sections 3.7, 12, 14).

1.2. "Base Earnings" — the amount you are paid for your own Accepted Hours in a given Week (rate in Schedule A). Base Earnings exclude any Bonus. Where a specific program's Schedule A adopts a base-earnings-linked cap (Section 8.3) — which no program is required to do — that cap is calculated on this Bonus-excluded figure.

1.3. "Bonus" and when it "accrues." A Bonus is a formula-based incentive: a Buddy Referral Bonus (Section 8) or a Community Partner Bonus (Section 9). A Bonus accrues when the underlying Accepted Hour is paid to the collector who recorded it, once you satisfy the stated conditions. An accrued Bonus is not immediately fully payable: it becomes payable as set out in Section 11, and remains subject to (i) the Reserve and Finalization Window (Section 12.5), (ii) Forward-Offset for validly reversed hours within the lookback cap (Section 12.6), (iii) Screening (Section 14), and (iv) the caps and windows in this Policy. "Already-accrued Bonus" in Sections 17 and 18.3 means a Bonus that has accrued under this Section, and those sections protect it only from prospective rule changes — not from Forward-Offset, valid reversal, or fraud recovery. The parties intend Bonuses to be incentive payments, not wages; the effect of that intention is addressed in Section 3.5.

1.4. "Collector" — an independent contractor approved to record footage on the Platform and be paid per Accepted Hour under the ToS.

1.5. "Referrer" — a Collector who has opted in to the Buddy Referral leg and invites another person to join.

1.6. "Community Partner" — a participant approved under Section 9 to introduce many Collectors. "Community Partner" is a descriptive label only and, as Section 3.5 states for wages, is not controlling of the activity's legal character.

1.7. "Referred Collector" / "Introduced Collector" — a new Collector credited to exactly one Referrer or Community Partner under Section 7.

1.8. "Eligibility Gate" — an optional, program-defined one-time qualification milestone that a specific program's Schedule A may require a Referrer to reach before earning any Buddy Referral Bonus. Its purpose is anti-fraud: to confirm the Referrer is a real, genuine collector, not a straw account. Where a program defines one, it may be satisfied as that program's Schedule A provides (a verified onboarding/qualification milestone and/or a small number of the Referrer's own Accepted Hours); once reached, it stays reached, and you do not lose eligibility by later filming less (Section 8.1). A program may define no Eligibility Gate at all, relying on the universal identity and anti-fraud Screening (Section 14) instead.

1.9. "Attribution" — the exclusive, first-touch crediting of a Referred/Introduced Collector to one Referrer or Community Partner, requiring a Genuine Introduction (Sections 1.10, 7).

1.10. "Genuine Introduction" — an introduction in which the Referrer had actual, direct contact or a real prior relationship with the person, and actively caused that person to learn about and choose to join TrueLabel. Objective indicators include: the Referrer can identify the person and the circumstances of the introduction; the person, on onboarding, confirms that this specific Referrer introduced them; and the person was not already a collector, applicant, lead, or invitee in our records before the referral event (Section 7.3). A "Non-Genuine Introduction" is the opposite — e.g., mass, indiscriminate, or spammed link distribution; harvesting sign-ups from people the Referrer had no real contact with; or claiming credit for a person already engaged with TrueLabel. These are objective tests applied to identifiable facts; any adverse determination is explained and is subject to appeal (Section 19.1).

1.11. "Screening" — identity verification ("KYC"), plus anti-fraud, anti-money-laundering (AML), and sanctions screening (and, for politically-exposed persons, enhanced due diligence under Section 14.4) against applicable lists (Section 14).

1.12. "Forward-Offset" — recovery of a previously paid Bonus solely by netting it against your future Bonuses when the underlying Accepted Hours are later reversed or corrected, subject to the lookback cap in Section 12.6 and the waiver in Section 12.4. Except in cases of fraud (Section 12.3), we do not charge your payout method, reverse your Base Earnings, or demand direct repayment, and if you have no future Bonuses to offset within the lookback, we absorb the difference.

1.13. "Reserve / Holdback" — the portion of an accrued Bonus we hold pending the Finalization Window before it becomes payable (Section 12.5).

1.14. "Week" — Monday 00:00 to Sunday 23:59 UTC (Schedule A). Bonuses are disbursed on a monthly cycle (Section 11.1, Schedule A), even though weekly caps are measured per Week.

1.15. "Program" — this Collector Referral & Incentive Program (Buddy Referral leg and Community Partner leg).

1.16. "Schedule A" — the dated, versioned figures schedule that forms part of this Policy and states every binding number.

1.17. Sanctions categories. Two different rules apply, depending on the regime:

(a) "Comprehensive-Embargo Jurisdiction" — a country or territory subject to a comprehensive sanctions or embargo program under any list truelabel is required or elects to apply, currently Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions, as updated from time to time. A person located in, or resident in, a Comprehensive-Embargo Jurisdiction is ineligible for the Program and cannot be paid a Bonus. This exclusion is based on location/residency (and on any nationality-based bar only to the narrow extent applicable law actually requires); it does not automatically exclude a person merely for holding that nationality while lawfully located and resident elsewhere.
(b) "List-Based / Sectoral Regime" — a targeted or sectoral sanctions program that does not comprehensively embargo a whole country (for example, programs affecting Venezuela and various other countries). For these, there is no blanket exclusion of nationals or residents. Instead, truelabel screens the specific person or entity against the applicable SDN/consolidated/sectoral lists (Section 14.3); the person is eligible unless they are themselves listed, blocked, or otherwise a prohibited counterparty under the applicable program.
(c) A person who is a listed or blocked person on any applicable list, or acting for the benefit of a sanctioned target, is ineligible regardless of location.

1.18. "Politically-Exposed Person (PEP)" — an individual entrusted with a prominent public function (or their close associate/family member). A PEP is not a blocked or sanctioned person and is not excluded from the Program; a PEP is subject to enhanced due diligence (Section 14.4).

2. Relationship to the Terms of Service; acceptance; effective date

2.1. Incorporation by reference. This Policy is incorporated into, and forms part of, the TrueLabel Terms of Service and Collector Agreement (together, the "ToS"). Capitalized terms not defined here have the meaning given in the ToS.

2.2. Effective date and how you accept. (a) This Policy takes effect on its Effective Date. It does not apply to you, and no attribution or bonus tracking begins for you, until you affirmatively opt in to a specific leg through the in-app opt-in for that leg. (b) New collectors are presented with this Policy and the per-leg opt-in when they join. (c) Existing collectors are not bound by mere posting or continued use. We give conspicuous advance notice and present the per-leg opt-in showing the then-current Schedule A figures; you become a participant only by affirmatively opting in. (d) Per-leg, informed opt-in, with honest earnings context. Each opt-in screen displays the then-current material figures from Schedule A (rate, gate, caps, taper, windows) for that leg. Wherever a per-accepted-hour rate is shown on the opt-in screen (and in any recruitment copy), a plain statement appears directly adjacent to the rate: "These are not typical earnings. Earnings depend entirely on the accepted work of people you refer, are often small or zero, and are not guaranteed. This is designed as a small supplement, not a source of income." (Section 13.) You cannot accrue a Bonus under a leg you have not opted in to.

2.3. Order of precedence. Where documents conflict, this order controls, top first:

Any mandatory, non-waivable law of your jurisdiction (Section 19.3);
The ToS / Collector Agreement, for these matters only: worker classification, governing law, and dispute resolution and forum;
This Policy, for all Program-specific matters — eligibility, attribution, bonus calculation, caps, gates, windows, corrections/forward-offset, holds, Program enforcement, and the Program-related limitation of liability (Section 20); where a Program dispute concerns limitation of liability, Section 20 of this Policy governs, not any different ToS cap;
Schedule A, for the specific numeric values;
Any summary, marketing, or in-app description of the Program.

2.4. Voluntary and free. Opting in is voluntary and costs nothing. Bonuses are tied to the real accepted work of directly-referred people and do not change the per-Accepted-Hour rate you earn for your own footage.

3. Independent-contractor status; no employment; no partnership; classification governed by local law

3.1. Intended structure — not a presumption. The Program is structured on the basis that collectors, Referrers, and Community Partners are independent contractors, and nothing in this Policy — no Bonus, cap, gate, or recognition — is intended to create an employment, agency, partnership, joint-venture, franchise, or fiduciary relationship between any participant and truelabel, or between participants. This statement describes the parties' intended structure only. It carries no presumptive weight, and truelabel does not rely on it, in any collector's actual classification analysis, which is governed by mandatory local law (Sections 3.5, 3.6). The Program has no leaderboards, tiers, or titles that rank or reward participants by the number of people they recruit; any recognition, if offered, is based only on a participant's own accepted collection work and carries no monetary reward tied to recruitment counts.

3.2. No control through this Policy. You decide whether, when, where, how, and to whom you refer people. The honesty, anti-fraud, and legal-compliance obligations here are conditions of the incentive and a compliance minimum; they are not directions about the manner in which you perform collection work or referral activity, and this Policy adds no right for truelabel to direct that manner.

3.3. A referrer is not a boss. Referring or introducing others does not make you a manager, supervisor, employer, or agent of anyone. You have no authority to hire, direct, coach-for-quality, discipline, allocate work to, or terminate any other collector, and no authority to bind truelabel or present yourself as its employee, agent, or official representative.

3.4. Independent-business indicia; non-exclusivity. Consistent with the Collector Agreement (which governs the underlying engagement), a collector: (a) is free to work for others, including other platforms and clients, and to accept or decline any work; (b) provides their own equipment (e.g., their own phone) and bears their own costs; (c) sets their own schedule and chooses when, whether, and how much to film; and (d) operates as their own independent business, responsible for their own taxes and any registration their local law requires. Participation in the Program does not narrow any of these. Where these indicia are elaborated in the ToS/Collector Agreement, those terms control the underlying engagement.

3.5. Community Partner acts on its own behalf; economic-dependence handled structurally. A Community Partner: (a) acts as an independent principal on its own behalf, not as truelabel's agent, employee, or representative; (b) does not employ, engage, direct, supervise, discipline, schedule, allocate work to, or set or pay the earnings of any Introduced Collector; (c) is solely responsible for its own conduct and costs; and (d) contracts with truelabel as a registered business entity under a business-to-business statement of work and holds any recruitment, labour-intermediary, manpower, or business license required by its local law. truelabel and Datoric are not joint employers of any collector, and a Community Partner is not an intermediary employer of any Introduced Collector. To limit economic-dependence risk, the Program caps the share of a Community Partner's income that may derive from the Program (Schedule A). The parties acknowledge that statutory commercial-agency / "representante" regimes (including the UAE Commercial Agencies regime) may still apply as a matter of mandatory local law regardless of this label; each party reserves its position, and these questions are governed by mandatory local law (Section 19.3).

3.6. Wage-integration reservation (no flat "not wages" claim). The parties intend and have structured Bonuses as incentive payments rather than wages, and truelabel does not treat them as wages for its own purposes. The parties acknowledge the label is not controlling and that, under some jurisdictions' law (including primacy-of-reality principles), a habitual bonus may be examined for integration into salary, social charges, severance, or 13th-month calculations. To reduce that risk, Bonuses are disbursed on a monthly cycle separate from weekly base pay (Section 11.1); any weekly cap a program applies is, by default, a flat ceiling decoupled from your own earnings, and a cap defined by reference to your own earnings is used only in a jurisdiction whose law affirmatively permits it (Section 8.3); and Bonuses are itemized separately (Section 11.1). Each party reserves its position; this is subject to mandatory local law (Section 19.3). Nothing here admits that any Bonus is or is not wages.

3.7. Classification and worker protections are governed by your local law. Worker classification, wage and benefit entitlements, unlawful deductions, work authorization, and other mandatory worker protections are governed by the mandatory law of the jurisdiction where you perform your work, regardless of the UAE/DIFC choice-of-law or forum clause. The UAE/DIFC choice reflects truelabel's own establishment; DIFC Employment Law does not govern a collector performing work outside the DIFC. truelabel does not represent that UAE/DIFC law resolves your classification and does not rely on the UAE/DIFC forum where a local labour forum is mandatory for you.

3.8. Datoric-routed hours — who you contract with, and why this is not intermediary employment. For footage you record through the Datoric partner application, your counterparty and payer for that collection work is Datoric, which reports your accepted hours to us. Substantively: truelabel does not direct or supervise your Datoric work, does not set or pay your Datoric rate, does not schedule you, and does not control the manner of that work — you contract directly with Datoric for it. truelabel's only role for those hours is paying a separate referral Bonus to the Referrer/Partner as a truelabel incentive. This creates no employment, agency, or intermediary-employment relationship among you, the Referrer/Partner, truelabel, and Datoric. Before truelabel pays any Bonus tied to Datoric-reported hours, those hours and the persons involved are subject to equivalent Screening (Section 14.7). Where truelabel is the base payer, standard terms apply.

4. Single-level program — how it is structured

4.1. Single level only. Both legs are strictly single-level. You earn only from the real, accepted, paid footage of people you personally referred. There is no downline, second level, override, or multi-generation structure. You never earn from people that your Referred/Introduced Collectors in turn refer.

4.2. No pay for recruiting itself. No Bonus is paid for a sign-up, for the act of recruiting, for the number of people recruited, or for a recruit in turn recruiting. Every Bonus is a function of Accepted Hours a directly-referred person is actually paid for.

4.3. No buy-in, no pay-to-play. There is no fee, purchase, buy-in, inventory, starter kit, or payment of any kind to join TrueLabel or the Program or to remain eligible.

4.4. Why this is not a pyramid, and its regulatory posture. Every amount payable is a function of genuine, paid data-collection work performed by a real, distinct, directly-referred individual. No amount depends on recruitment as such, on organization size, or on money paid in by new participants — and this is true in every market, including markets where the weekly cap is not tied to your own filming. The anti-pyramid basis for the Buddy Referral leg does not depend on the Referrer's own filming; it rests on three things that hold everywhere: (i) it is single-level (you never earn from a recruit's recruits); (ii) every dollar is tied to the referred person's own genuine, accepted, paid work; and (iii) hard per-referee, weekly, and lifetime caps prevent it from becoming a recruitment-driven income stream. The no-buy-in, no-required-payment design (Section 4.3) is intended to keep the Program outside the FTC Business Opportunity Rule (16 CFR Part 437) and outside pyramid/endless-chain definitions.

5. Eligibility; no effect on your collector standing

5.1. To opt in you must: (a) be an active TrueLabel collector whose account is not under a fraud/abuse, legal, or screening/sanctions restriction (or, for Community Partners, an approved participant under Section 9) — your work-quality standing does not affect Program eligibility; (b) be of the age of majority in your country of residence; (c) have a valid payout method in your own name; and (d) comply with this Policy, the ToS, and applicable law.

5.2. Opting in is voluntary. You are never required to refer anyone.

5.3. Program removal is limited. We may decline, pause, or remove you from the Program only for: suspected fraud or abuse (Section 10); legal, screening, or sanctions restrictions (Section 14); or a breach of the Program eligibility rules — subject to appeal (Section 19.1). We do not remove you from the Program for ordinary work-quality reasons.

5.4. No effect on your work as a collector. Your participation, non-participation, or any Program outcome (including disqualification or forfeiture) has no effect on your task allocation, work opportunities, per-hour pay rate, priority, or standing as a collector; and your work-quality standing has no effect on your Program eligibility. Exception: conduct that independently breaches the ToS — for example creating fake or duplicate identities, or identity fraud (Section 10) — may affect your collector account under the ToS on its own terms. A Program-only issue (such as a disputed attribution or a cap breach) leads only to Program removal and Bonus recovery, never to loss of your collector account.

6. The two legs at a glance

truelabel offers two separate legs. You may opt in to one or both. The two legs never both pay on the same Accepted Hour of the same person.

Framework vs. per-program mechanics. This Policy sets the framework and the protections for both legs — the kinds of rules that may apply (eligibility criteria, caps, tapers, holds/reserves, corrections and Forward-Offset, and windows) and the floors that protect you. The specific values and mechanics for any given program — including whether an Eligibility Gate applies and in what form, whether and how a weekly cap applies, the per-hour rate, tapers, and windows — are set in that program's dated Schedule A, and may differ by program and by jurisdiction. This Policy does not itself impose any universal percentage-of-your-own-earnings cap or any universal own-hours precondition; those are program-level choices published in Schedule A, adopted only where lawful in the applicable jurisdiction.

7. Attribution — exclusive, first-touch, one referrer, genuine introduction

7.1. One referrer per person. Each Referred/Introduced Collector is credited to at most one Referrer or Community Partner — never both and never several.

7.2. First-touch rule. Where more than one person could claim the same referral, credit goes to the first valid referral link, code, or verified invitation associated with the new account at sign-up, per our system records. Our records are evidence but are not conclusive and may be rebutted (Section 19.1). Later claims are not honored.

7.3. The person must be new. Credit is given only for a genuinely new collector. A person is not new if, when the referral link/code is first used, they: (a) already have or previously had a TrueLabel or Datoric collector account; or (b) already submitted a collector application or already appear as a lead/invitee in our onboarding records with a timestamp earlier than the referral event. A person already in our records before the referral event is treated as one who would have joined without the referral.

7.4. Genuine-introduction requirement (anti-harvesting). Attribution requires a Genuine Introduction as defined in Section 1.10. A Non-Genuine Introduction — including mass, indiscriminate, or spammed link distribution that merely "captures" people already reachable to us — does not earn attribution. We apply the objective indicators in Section 1.10; we may deny or withhold attribution and Bonuses for a Non-Genuine Introduction, even where no fraud is present, and we will state the specific basis and allow appeal (Section 19.1).

7.5. No stacking or double-crediting. The same Accepted Hour of the same collector generates a Bonus for at most one person and is not eligible under both legs at once.

7.6. No self-attribution and no transfer. You cannot be your own Referrer/Introduced Collector (Section 10), and you cannot sell, trade, assign, or reassign a referral or the right to a Bonus.

7.7. Corrections to attribution. Where attribution is unclear, disputed, or appears manipulated, we make a good-faith determination against the Section 1.10 indicators and may correct attribution to fix a demonstrated technical error, fraud, or Non-Genuine Introduction. You may submit contrary evidence and appeal (Section 19.1).

8. Leg 1 — Buddy Referral

A small supplement for collectors who bring a friend.

8.1. Eligibility to earn (program-defined; a program may or may not use a one-time gate)

A program may require you to reach a one-time Eligibility Gate before you can earn any Buddy Referral Bonus. Whether a Gate applies, and what satisfies it, are set in that program's Schedule A and may differ by program and jurisdiction. Where a program defines a Gate, its purpose is anti-fraud — to confirm you are a real, genuine collector, not a straw account — and it may be satisfied as Schedule A provides (a verified onboarding/qualification milestone and/or a small number of your own Accepted Hours); until you reach it, referrals may be tracked (after opt-in) but no Bonus accrues, and once you reach the Gate you stay eligible even if you later film less or stop filming. Reaching a Gate does not retroactively create Bonuses for hours before it was met. A program may define no hours-based Gate at all — in that case eligibility rests on the universal identity and anti-fraud Screening (Section 14), with no own-filming precondition. In every case, the universal Screening in Section 14 applies before any Bonus is paid.

8.2. What you earn

Once past the Gate, you accrue the Buddy rate in Schedule A for each Accepted Hour a Referred Collector is actually paid for — never on pending, rejected, or reversed hours, and only once that person clears their own Screening and is actually paid (Section 11.2).

8.3. Weekly cap — program-defined; flat and wage-decoupled by default

A program may cap your total Buddy Referral Bonus in any Week to guard against farming. Whether a weekly cap applies, its amount, and its form are set in that program's Schedule A and may differ by program and jurisdiction. Any such cap is designed not to tie your Bonus to your own wages:

Standard form (used by default): a flat weekly ceiling (Schedule A), not linked to your own Base Earnings and not requiring you to have filmed that Week. This decoupling is deliberate, to keep the incentive from being linked to your own wages.
Jurisdiction-specific alternative (per-program, only where lawful): a program may, only where the applicable jurisdiction's law affirmatively permits it, instead define its weekly cap by reference to your own Base Earnings that Week, as set out in that program's Schedule A (Section 1.2). This is not a rule of this Policy; it is a per-program choice, adopted only in a jurisdiction whose law affirmatively permits linking an incentive cap to a contractor's own earnings, and only if that program's Schedule A adopts it. Where a program adopts it, a no-film Week can mean about a $0 cap that Week.

This Policy states no universal percentage-of-your-own-earnings cap; the specific weekly-cap mechanic for your program, if any, is the one published in your program's Schedule A.

Excess above the cap — carry-forward that EXPIRES. If a Referred Collector's paid Accepted Hours would generate more Bonus than your cap allows in a Week, the excess carries forward and remains eligible in later Weeks (subject to each later Week's cap and the per-referee window in 8.4) for up to the carry-forward period in Schedule A (e.g., 8 Weeks). After that period, any still-uncapped excess EXPIRES and is lost ($0), except that any unexpired carried-forward amount representing genuine accepted work is paid out on Program wind-down or account closure under Section 11.6. Carry-forward is not a permanent balance, and it is possible for genuine accepted work to yield $0 to you if it never fits under your cap in time — this limit is disclosed in the summary.

8.4. Per-referee lifetime window

For each Referred Collector, you earn Buddy Referral Bonuses only on their first 250 Accepted Hours and only for up to 12 months after they join — whichever comes first (Schedule A). After that, no further Bonus accrues for that person.

8.5. Quality/authenticity and reversal risk

Bonuses attach only to genuinely accepted, paid footage. You bear the risk that footage you had nothing to do with is later rejected or corrected: if a Referred Collector's hours are reversed or fail authenticity checks after a Bonus accrued or was paid, related Bonuses may not accrue, may be held, or may be recovered by Forward-Offset within the lookback cap (Section 12). This is not a penalty for wrongdoing on your part.

9. Leg 2 — Community Partner

For people who introduce many collectors. Identity-verified and approval-gated.

9.1. Application and approval

Community Partner status is not automatic. You apply and are approved, and you contract as a registered business entity under a business-to-business statement of work (Section 3.5). We may approve, decline, condition, pause, or revoke approval — including for fraud/abuse risk, incomplete verification, or Screening results — subject to appeal (Section 19.1).

9.2. Screening and approval-gated payout, with a maximum hold window

Community Partner Bonuses are held and not payable until you have (a) completed KYC and any required tax/payee onboarding, and (b) cleared anti-fraud and sanctions/AML Screening (Section 14). We commit that:

we tell you, at opt-in and again when your first Bonus is held, what is required to clear the hold;
we complete review and either release the payable amount or give you a written reason within the maximum decision window in Schedule A after you submit complete verification, keeping you informed of status; and
if we need more information, we ask specifically, and the window pauses only while we reasonably await your response. If we cannot lawfully pay you (Section 14.3), we tell you, subject to any legal restriction on what we may disclose (Section 14.6).

9.3. What you earn, and the taper

Once approved and verified, you accrue the Community Partner rate in Schedule A for each Accepted Hour each of your Introduced Collectors is actually paid for, tapering on the published Schedule A schedule (days 1–30: 100%; 31–60: 66%; 61–90: 33%; after 90 days: $0) per Introduced Collector.

9.4. Caps and cohort-integrity gate

Community Partner Bonuses are subject to: (a) a per-recruit cap (Schedule A); (b) a monthly aggregate cap (Schedule A); (c) the income-share cap in Section 3.5; and (d) a cohort-integrity gate limited to fraud, authenticity, and abuse signals (e.g., coordinated abuse, fabricated/duplicate identities, shared-payout-identity patterns, elevated fraud-driven reversals). The gate is not a work-quality supervision tool and never requires, rewards, or penalizes you for directing, coaching, disciplining, or managing any collector's work. Attribution may also be denied for a Non-Genuine Introduction (Sections 1.10, 7.4). Where cohort-level fraud/abuse signals are present, affected Bonuses may be held, reduced, or reversed and participation paused, subject to appeal (Section 19.1).

9.5. Not tied to your own filming

The Community Partner Bonus does not require you to film and is not capped against your own earnings. It remains single-level: you earn only on your directly-introduced collectors' accepted, paid work, never on any further tier.

9.6. Attestation; lawful activity only

By participating you attest that: (a) each person you introduce is a real, distinct individual who genuinely chose to join and whom you genuinely introduced (Section 1.10); (b) you have not colluded to inflate hours, share payouts, or create linked/duplicate accounts; (c) you are not paid by any Introduced Collector and do not share in their pay; and (d) you act only where you may lawfully do so and hold any required license (Section 3.5). truelabel's payment to you is an incentive for genuine introductions and is not consideration for recruiting as such.

10. Prohibited conduct and anti-fraud

The Program only works if referrals are real. The following are prohibited. A Program-only violation results in holding, reduction, reversal, or Forward-Offset of Bonuses, forfeiture of amounts obtained through the conduct, and removal from the Program. Your collector account is suspended or terminated only where the same conduct independently breaches the ToS (for example, fake or duplicate identities, or identity fraud). All of this is subject to Section 19.1.

10.1. Self-referral. Referring or introducing yourself, or any account you own, control, co-own, operate, or benefit from — including alternate, duplicate, family-proxy, or "straw" accounts. 10.2. Fake or fabricated accounts. Creating, procuring, or crediting accounts that do not correspond to a real, distinct individual doing genuine work, or using others' identities. 10.3. Incentivized-fraud activity. Paying, coercing, or inducing collectors to submit footage that is not bona fide, or any scheme to manufacture Accepted Hours. 10.4. Shared payout identity. Multiple supposedly-separate collectors routing payments to the same person, bank/Wise account, wallet, tax ID, or instrument in a way indicating the accounts are not genuinely independent. 10.5. One person, one identity. Each account must correspond to a single real individual. Shared, sold, transferred, or rented accounts are prohibited. 10.6. Spam and misrepresentation. Recruiting through spam, purchased lists, impersonation of truelabel, deceptive job postings, or by misstating what TrueLabel is, how much people will earn, or the Program terms (Section 13). 10.7. Circumvention. Using bots, scripts, VPN/IP masking, or device/location spoofing to evade attribution rules, caps, gates, or anti-fraud controls. 10.8. Coordinated same-household or same-network rings. Even where each account belongs to a real, distinct person, a coordinated cohort of accounts sharing a household, payout identity, device, or IP that refer one another to harvest bonuses is prohibited. Such cohorts are subject to an aggregate household/cohort cap (Schedule A) and to a Genuine-Introduction test (Section 1.10): a same-household referral earns only where there is a real, independent nexus and the referred person genuinely joined through the referrer, not merely because the accounts are co-located. The family-member protection in Section 12.3 protects a genuinely independent person's honestly-earned Bonuses from fraud recovery; it does not exempt a coordinated ring from these aggregate caps or the Genuine-Introduction test. 10.9. Detection, due process, and appeal. We use automated and manual controls — device and IP/geolocation signals, shared-payout-identity detection, velocity and collusion analysis, duplicate-identity matching, and reversal signals — to detect abuse. Where we reasonably suspect prohibited conduct, we may withhold, delay, reduce, or reverse Bonuses, require verification, suspend or terminate participation, and, where an account-level ToS breach is involved, act on the account. For any adverse decision materially affecting Bonuses or participation — including decisions driven by automated matching — we will: (a) tell you the general reason; (b) give you a genuine chance to submit contrary evidence; and (c) provide human review on appeal (Section 19.1). We may limit operational detail only as needed to protect fraud-prevention methods or where law prohibits disclosure (Section 14.6), but not so as to deny you a meaningful chance to respond except where such disclosure is legally barred.

11. How and when Bonuses are paid

11.1. Segregated from base pay; monthly cadence. Payable Bonuses are paid separately from your collector base pay: on their own disbursement line, itemized as an "Incentive Bonus" (never merged into wages), and — where operationally supported — on a distinct transfer. Bonuses are disbursed on a monthly cycle (Schedule A), separate from the weekly base-pay cycle, which supports their treatment as incentive payments rather than integrated wages (Section 3.6). Payment is by Wise or bank transfer to a payout method in your own name, subject to Screening (Section 14), the Reserve/Finalization mechanics (Section 12.5), the minimum-payout threshold in Schedule A, and normal processing times.

11.2. When a Bonus becomes payable, and the dependency chain. A Bonus becomes payable once: the underlying hours are confirmed Accepted Hours; the Referred/Introduced Collector has actually cleared their own Screening and been paid (which the Referrer cannot see or control); the Finalization Window (Section 12.5) has passed for the reserved portion; your own Screening has cleared (Section 14); for Community Partners, Section 9.2 review has cleared; and your accrued total reaches the minimum-payout threshold. You may therefore earn nothing on a genuine referral if the person you referred never clears their own verification, or never reaches their own payout minimum — that is outside your control and is not a fault of yours. Amounts shown as "pending," "estimated," or "projected" are not yet payable and are not guaranteed.

11.3. Partner-reported hours — visibility and appeal. For footage flowing through Datoric or another reporting partner, Bonuses rely on that partner's reported data, are subject to the Finalization Window and correction if that data is later revised (Section 12), and are subject to the cross-screening in Section 14.7. Because your Bonus can depend on a partner's data you cannot otherwise see, we will show you the partner-reported accepted-hour totals that drive your Bonus, and if partner-reported data is the basis for withholding or reducing a Bonus, you may appeal that under Section 19.1 and we will re-examine the partner data.

11.4. Currency and fees. Bonuses are denominated in USD and may be converted to local currency. Exchange spreads, transfer fees, and receiving-bank charges reduce what you receive, so the amount that lands can be less than the Schedule A figure. truelabel does not control third-party FX and bank charges, except as mandatory local law requires.

11.5. Blocked, returned, or unclaimed payouts — held, not forfeited. If a payout is rejected, returned, unclaimed, or blocked (including by the provider or sanctions controls), we will (a) hold the amount in reserve rather than forfeit it; (b) contact you to correct/re-submit details; and (c) allow re-claim during the reclaim window in Schedule A, with reasonable re-attempts. Only after that window passes with reasonable contact attempts and no valid payout method, or where payment remains unlawful (Section 14.3), may an amount be treated as unrecoverable, and even then only as law permits.

11.6. Sub-threshold balances are not quietly forfeited. The minimum-payout threshold is a batching convenience, not a forfeiture. If your accrued, payable, Screening-cleared Bonus balance never reaches the threshold because of few referees, Program wind-down, or account closure, we will still pay out the balance below the threshold on the earlier of a periodic sweep of long-inactive balances (Schedule A) or on Program end or account closure (other than closure for the participant's own fraud under Section 12.3), subject only to Screening and applicable law. Earned amounts are not stranded by the threshold.

12. Corrections, reversals, and Forward-Offset

12.1. Corrections happen. Accepted Hours are sometimes later reversed, corrected, disqualified, or reduced — e.g., footage found on re-review to be duplicated, non-compliant, fraudulent, or unpayable, or where partner-reported data is corrected, or where a Referred person is later found unpayable on sanctions grounds (Section 14.3).

12.2. Forward-Offset, not chargebacks. If a Bonus was paid on hours later reversed or corrected, the amount is recovered solely by netting against your future Bonuses ("Forward-Offset"). We will not issue a negative charge to your payout method, reverse your Base Earnings, or demand direct repayment of a good-faith prior Bonus. In plain terms: if the person you referred later has hours reversed, your future bonuses go down — you carry that risk even though you did nothing wrong. If you have no sufficient future Bonuses within the lookback (Section 12.6), truelabel absorbs the difference; you never owe money (Section 12.7).

12.3. Exception for fraud and complicit linked accounts (narrowed). Section 12.2 does not limit our right, in cases of fraud or serious abuse (Section 10), to withhold amounts and to recover amounts obtained through the fraud (including by direct recovery where Forward-Offset is unavailable), and to recover across other accounts only where those accounts are under the offending participant's control or are complicit in the same fraud (including accounts sharing a payout identity used to effect it, or a coordinated ring under Section 10.8). This right does not reach the honestly-earned Bonuses or Base Earnings of a genuinely independent person (for example, a real family member with their own bona fide account and a real, independent Genuine Introduction) merely because an account is "linked." Recovery is limited to amounts tainted by the fraud. Coordinated same-household/same-network rings (Section 10.8) are not "genuinely independent" for this purpose.

12.4. These are contract conditions; wage-deduction waiver fallback. The Eligibility Gate, caps, windows, attribution rules, Reserve, and Forward-Offset are contractual conditions on when and whether a Bonus is payable. We do not characterize them as wage deductions. Where the mandatory law of your jurisdiction would nonetheless treat a good-faith Forward-Offset as an unlawful wage deduction, truelabel waives the offset and absorbs the good-faith overpayment for you — the mechanic degrades gracefully rather than being void. Offsets, where applied, are taken against the earliest available future Bonus accruals and itemized in your earnings ledger with enough detail to identify the reversed hours. This is subject to mandatory local law (Section 19.3).

12.5. Reserve and Finalization Window (risk-scaled; mandatory elevation for high-reversal cohorts). A portion of each accrued Bonus (the base Reserve percentage in Schedule A, e.g., 20%) is held and does not become payable until the Finalization Window in Schedule A (e.g., 45 days) has passed for the underlying Accepted Hours (measured from the date those hours were paid, or, for Datoric/partner-reported hours, from confirmed reporting). To prevent "bank-and-quit" overpayment:

for a new or unproven Referred/Introduced Collector (including a first-time referee with no track record), and
for any referee or cohort whose reversal rate exceeds the threshold in Schedule A, truelabel will (not "may") apply an elevated Reserve of up to 100% and hold the entire Bonus until finalization, and will lengthen the Finalization Window for such cohorts as stated in Schedule A. Elevated Reserve is mandatory in these defined cases, not discretionary. What "finalization" means. When the Finalization Window closes for given hours, the Reserve for those hours is released and no further holdback is taken for them. Finalization is about releasing the holdback — it does not make the hours permanently immune from correction. Those hours remain subject to good-faith Forward-Offset within the 12-month lookback (Section 12.6) and to fraud recovery at any time (Section 12.3). There is no separate "45-day finality" that conflicts with the 12-month lookback; the 45-day window governs the Reserve, the 12-month lookback governs good-faith recovery.

12.6. Forward-Offset lookback cap. Forward-Offset for a good-faith reversal applies only to reversals that occur within 12 months (Schedule A) after the Bonus was paid. After that period, an unrecovered good-faith overpayment on validly-paid past hours is not offset against your future Bonuses. This cap does not apply to fraud recovery (Section 12.3).

12.7. Good-faith overpayments to non-continuing participants. Because good-faith recovery is only by Forward-Offset against future Bonuses, a participant who stops earning cannot always be recovered from. The mandatory elevated Reserve for new/unproven and high-reversal cohorts (Section 12.5) is our primary protection against engineered "bank-and-quit." Beyond that, truelabel expressly accepts that a residual good-faith overpayment to a participant who has stopped earning is absorbed by truelabel and is not pursued — no chargeback, no debt, no collection. We do not maintain both a hard finality and an open-ended clawback; the two mechanics above are the complete good-faith recovery scheme.

13. No guarantee of earnings; honest sharing; advertiser-side compliance

13.1. No earnings guarantee. We do not promise, guarantee, or represent that you will earn any particular amount — or any amount at all. Earnings depend entirely on the real, accepted, paid work of the people you refer, are often small or zero, and are not guaranteed. This is designed as a small supplement, not a source of income.

13.2. Not typical; examples labeled, with point-of-exposure context. Any earnings figures or example calculations — including any we publish, and including every place a per-accepted-hour rate is shown — are accompanied, directly adjacent to the figure, by a plain statement that these are not typical earnings, earnings depend entirely on the accepted work of people you refer, are often small or zero, and are not guaranteed, and any example is clearly labeled "illustrative, not a promise." truelabel will not publish per-unit rates or calculators as representative earnings, and will not make any quantified typicality claim (such as "most participants earn X"), until it has actual participant-earnings distribution data to support it. Once real distribution data exists, truelabel may add a data-backed earnings statement.

13.3. Honest sharing — your obligation, and what your friend does NOT get. When you tell others about TrueLabel you must be truthful. You must not promise or imply guaranteed income, "easy money," "get rich," or any particular earnings; invent or exaggerate earnings or how quickly they arrive; misdescribe the Program, the caps, gates, or holds; or impersonate truelabel. You must not tell anyone they will receive a signup, join, or referral bonus for joining through you: the Program pays the Bonus only to the referrer — the person you refer earns nothing extra from the referral.

13.4. Clear-and-conspicuous disclosure — a minimum standard, in your invitee's language. If you promote TrueLabel and can earn a Bonus, you must clearly and conspicuously disclose, in the same message or post as the referral itself, that you may be paid a bonus for referrals. This is a minimum honesty standard, not a script — you may use your own wording (truelabel offers optional sample language you are free to ignore), but the disclosure must be in the language you are using to invite the person, so the invitee actually understands it. The disclosure must be hard to miss and adjacent to the referral; a disclosure hidden in a "link in bio," buried among hashtags, or on a separate page does not satisfy this requirement. If you make any claim about how much can be earned, you must additionally disclose that results are not typical and earnings are not guaranteed (Section 13.2).

13.5. Advertiser-side compliance — compelled, minimal, and reactive. truelabel is required, under the FTC Endorsement Guides (16 CFR Part 255) and analogous local rules, to take reasonable steps against deceptive claims by people it incentivizes to promote it. The following program exists only to discharge that advertiser-liability duty — it is not a general supervisory right and confers no control over how, when, or whether you refer (Section 3.2). It consists of:

(a) Mandatory training and attestation. Before your referral sharing is enabled, you must complete brief training on the honesty and disclosure rules (Sections 13.3–13.4) and attest that you will follow them.
(b) Complaint/report intake. truelabel maintains a channel for anyone — invitees included — to report a deceptive or misleading referral claim.
(c) Audit rights on trigger. truelabel may review a participant's referral claims when a complaint or a fraud signal arises, and may sample publicly-posted referral content.
(d) Private-channel limit — expressly acknowledged. Much recruiting happens in private WhatsApp/DM channels truelabel cannot see. truelabel does not monitor private messages. It discharges its advertiser duty through the training + attestation (a), the complaint intake (b), and complaint-/fraud-triggered audits (c), rather than through surveillance of private channels.
(e) Notice-and-cure. On non-compliance, truelabel uses notice-and-cure first — asking you to correct or remove a specifically-identified non-compliant claim — and only for repeat or serious violations suspends Program sharing eligibility.

These steps address truelabel's own advertiser duty and do not make truelabel your employer or give it control over the manner of your activity.

13.6. No spam. Referral outreach must comply with anti-spam and messaging laws applicable to the recipient (Section 16).

14. Screening: identity, AML, and sanctions — mandatory for ALL bonus recipients

14.1. Mandatory pre-payout Screening for everyone. Before any Bonus is paid to any participant — including Buddy Referral — the recipient must clear identity verification (KYC) and sanctions and AML Screening. No Bonus is paid to a recipient who has not cleared Screening.

14.2. First-payout threshold and hold for Leg 1. For Buddy Referral, your first payout is subject to KYC and a pre-payout review/hold window (Schedule A) for Screening and initial fraud review. We may hold, delay, decline, or reverse a Bonus if verification is incomplete, if payment would breach AML or sanctions law, or if we reasonably suspect fraud. Community Partner Bonuses are additionally approval-gated (Section 9.2).

14.3. Sanctions — two rules, and the consequence for the referrer. We apply the two-track approach in Section 1.17:

(a) Comprehensive-Embargo Jurisdictions (Section 1.17(a)): a person located in or resident in Cuba, Iran, North Korea, Syria, or the Crimea/Donetsk/Luhansk regions cannot take part or be paid.
(b) List-Based / Sectoral Regimes (Section 1.17(b), e.g., Venezuela): no blanket country exclusion. We screen the specific person/entity against the applicable lists; they are eligible unless personally listed, blocked, or otherwise a prohibited counterparty.
(c) We do not pay any listed or blocked person, or where payment would otherwise be unlawful.

We screen against applicable lists, including UAE (Executive Office / Local Terrorist List and UN-derived listings), the UN Security Council Consolidated List, US OFAC lists, and, where applicable to the payment flow, the EU and UK consolidated sanctions lists. Because all Bonuses are USD-denominated and clear in US dollars (Section 11.4, Schedule A), OFAC screening is applied to every Bonus — it is not a conditional add-on. Consequence for a Referrer/Partner: if a Referred/Introduced person cannot be paid on sanctions grounds, that person cannot be paid for their footage, so there is no Accepted Hour and therefore no Bonus to the Referrer/Partner on that work; any Bonus already paid on such hours is unlawful and subject to recovery/Forward-Offset (Section 12). Participation is void where prohibited by law.

14.4. PEP handling — enhanced due diligence, not exclusion. A politically-exposed person (Section 1.18) is not a blocked or sanctioned person and is not automatically excluded. A PEP is subject to enhanced due diligence (additional identity/source-of-funds verification and, where required, senior sign-off) and remains eligible if that diligence clears.

14.5. We do our own Screening. truelabel conducts its own Screening and does not rely on the payment provider's screening. A provider (e.g., Wise) may apply its own separate requirements; a provider's checks do not replace or reduce truelabel's Screening.

14.6. AML program obligations. truelabel maintains an AML/CTF program that includes: filing suspicious-transaction/activity reports with the UAE Financial Intelligence Unit via goAML (STR/SAR) where required; retaining KYC, transaction, and screening records for the period required by law (Schedule A / applicable law); and complying with no-tipping-off rules. Accordingly, where a Bonus is held, delayed, or declined for AML/sanctions reasons, truelabel may be legally prohibited from telling you the specific reason; in that case it will give the most general lawful indication and the appeal right in Section 19.1 still applies to the extent the law permits.

14.7. Datoric cross-screening — sanctions, KYC, AND anti-fraud/identity. Where a truelabel Bonus is tied to Datoric-reported (Datoric-paid) base work, truelabel applies equivalent sanctions/KYC screening to that base work and the persons involved before paying the Bonus, and will not pay a Bonus tied to a sanctioned person's Datoric-paid work even though truelabel is not the base payer (Section 3.8). In addition, truelabel conditions any Datoric-tied Bonus on truelabel's access to Datoric-side anti-fraud/identity signals — shared-payout-identity, device/IP, and duplicate-identity data — so that self-referral and straw-account fraud on Datoric-primary referred accounts can be detected (Sections 10.4, 10.8). Where truelabel cannot obtain sufficient anti-fraud/identity data for a Datoric-tied referral, it may withhold the associated Bonus pending that data, subject to appeal (Section 19.1).

15. Taxes

15.1. Your responsibility. Bonuses are paid gross. You are solely responsible for determining, reporting, and paying any income, self-employment, social-security, VAT/GST, or other taxes due, and for any registration or invoicing your local law requires of an independent contractor. 15.2. We do not withhold taxes except where mandatory law requires, may require accurate tax/payee documentation as a condition of payment, and may report payments to authorities where required. 15.3. Nothing here is tax advice. Consult your own tax adviser.

16. Data and privacy (including referred-invitee contact data)

16.1. What we process. Participant identity and payout details, referral links/codes, the identities and accepted-hour activity of referred/introduced collectors, KYC documents, and anti-fraud signals (device, IP, geolocation, payout-identity matching).

16.2. Referring someone and the first contact. If you refer a person, you must confirm the person agreed to be contacted about TrueLabel, and you must not upload contact lists, scrape contacts, or refer people who have not agreed. truelabel will send the first outbound contact to a referred invitee only where it has a lawful basis to do so in that person's market — treating that first contact as a one-time, transactional referral notice (not marketing) with an immediate opt-out, and obtaining consent before any further electronic marketing where consent is required (ePrivacy/GDPR/LGPD and analogous rules). truelabel relies on its own assessment of lawful basis and not solely on your assurance.

16.3. Notice and opt-out to the invitee. On first contact we identify truelabel, explain the referral and how the contact data is used, and give an easy way to opt out and have the contact data deleted from referral processing. We may decline to process referral data obtained through spam or scraping and will honor opt-outs.

16.4. Automated decisions. Automated anti-fraud/attribution decisions that materially affect you are subject to the human-review and appeal rights in Sections 10.9 and 19.1.

16.5. All personal data is handled under the TrueLabel Privacy Policy, incorporated by reference and updated to cover this processing across our footprint (including GDPR, LGPD, and UAE PDPL where applicable).

17. Disqualification and enforcement

17.1. We may withhold, reduce, delay, reverse (by Forward-Offset within the lookback cap), or cancel a Bonus, and remove any participant from the Program, if we reasonably determine this Policy, the ToS, or applicable law has been or is likely to be breached — including Section 10 conduct. Program enforcement is limited to Program removal and Bonus recovery; your collector account is suspended or terminated only where the same conduct independently breaches the ToS (Section 5.4, Section 10 preamble). Any decision is made in good faith, explained in general terms (subject to Section 14.6), and subject to your right to submit contrary evidence and appeal (Section 19.1). Already-accrued Bonuses are cancelled only for fraud/abuse (Section 10) or where the underlying hours are validly reversed (Section 12); an ordinary eligibility change is prospective only (Section 18.3). 17.2. Enforcement steps are in addition to other rights under the ToS or at law, subject to the limits here and mandatory local law.

18. Changes, suspension, or termination of the Program

18.1. Reservation of rights (prospective only). We may modify, suspend, or terminate the Program (in whole or part) and change rates, caps, gates, tapers, windows, and eligibility rules — only prospectively, by publishing a new dated Schedule A. Changes take effect only after notice under 18.2 and, where 2.2 requires, a fresh opt-in.

18.2. Notice; bounded immediate action. We give reasonable advance notice of any material adverse change (in-app and/or email), except that we may act immediately only where necessary to (i) prevent or stop fraud or abuse, (ii) comply with law or a payment-processor/sanctions requirement, or (iii) respond to a specifically-identified security or financial-integrity risk — meaning a concrete threat such as a payment-provider freeze, a sanctions/AML trigger, a coordinated-fraud event, an account/security compromise, or an order from a competent authority. This trigger is limited to those enumerated events, is not a general discretion, and cannot reduce, freeze, or offset any already-accrued Bonus except as Sections 12 and 10 allow; it may only pause future accrual and payouts prospectively.

18.3. No change reaches already-accrued Bonuses. A change to rates, caps, gates, tapers, windows, or eligibility does not reduce, remove, or offset any Bonus that had already accrued (Section 1.3) under the Schedule A in effect when the underlying Accepted Hours were paid. The only permitted reductions to accrued Bonuses are Forward-Offset for validly reversed hours (Section 12) and recovery for fraud/abuse (Sections 10, 12.3). This clause overrides any contrary reading of 18.1 and 18.2.

18.4. If the Program ends. You will still be paid Bonuses accrued before it ended, subject to verification, Screening, and Finalization, and including any balance below the minimum-payout threshold and any unexpired carried-forward amount (Sections 8.3, 11.6). An unrecovered good-faith Forward-Offset balance is netted only against future Bonuses within the lookback cap and is not charged back (except for fraud under Section 12.3).

19. Dispute resolution, appeal, and governing law

19.1. Appeal and re-review — real, free recourse. If you dispute a Bonus calculation, attribution decision, disqualification, forfeiture, offset, or a withholding based on partner-reported data (Section 11.3): (a) raise it first through TrueLabel support; we acknowledge within the Schedule A time and review in good faith; (b) you may appeal within the Schedule A window of our decision, and the appeal is decided by a reviewer other than the one who made the original decision; (c) we give a written response within the Schedule A time; (d) you may submit contrary evidence (screenshots, referral records, payout records), which we will consider; and (e) our system records are evidence of accruals and attribution but are not conclusive — they may be rebutted by credible contrary evidence. Free online dispute resolution. For Program disputes, truelabel provides a free, written, online dispute-resolution process conducted in your own language (English, Spanish, Portuguese, or Arabic), with no filing fee and no need to travel or retain a lawyer, decided by an independent reviewer. For any Program dispute at or below the small-dispute threshold in Schedule A, this online process is the agreed, accessible forum and truelabel bears its cost — you are not required to litigate a small Bonus dispute in a distant court.

19.2. Governing law and forum. This Policy is governed by the laws applicable in the Dubai International Financial Centre (DIFC), United Arab Emirates, and larger disputes are subject to the DIFC Courts, in English, except that: (i) the free online dispute-resolution process in Section 19.1 remains the accessible path for small Program disputes; (ii) where a mandatory local labour or consumer-protection forum and law apply to you, that forum and law prevail for you and that dispute (Sections 3.7, 19.3); and (iii) truelabel does not assert any class-action waiver, the DIFC forum, or the choice of English where it would be unenforceable against you as a consumer or contractor in your jurisdiction.

19.3. Mandatory local law prevails. Where a mandatory, non-waivable law of your jurisdiction — worker-protection, wage, consumer-protection, or data-protection law, or a mandatory local forum — conflicts with any provision here or with the chosen law/forum, that mandatory law prevails for you and for that provision only, and the remainder continues. truelabel does not assert the DIFC forum against you where doing so would override a mandatory local forum.

20. Limitation of liability (governs Program disputes — Section 2.3)

20.1. To the maximum extent permitted by law, truelabel is not liable for indirect, incidental, special, consequential, or punitive damages, or for lost profits, arising out of or relating to the Program, including payment-provider delays or non-delivery.

20.2. Earned money is always paid — no cap on wrongful withholding. Bonuses that had validly accrued to you and were wrongfully withheld are payable to you in full and are NOT subject to any liability cap. For this purpose, a Bonus is "wrongfully withheld" when it is withheld, reduced, reversed, or left unpaid other than as expressly permitted by this Policy — that is, other than for: fraud/abuse (Section 10); a valid reversal or Forward-Offset (Section 12); a screening/sanctions bar (Section 14); an unmet cap, gate, or window (Sections 8, 9); an unresolved verification you have not completed (Sections 9.2, 14); or the partner-data or dependency conditions in Sections 11.2–11.3. For all other Program-related liability, truelabel's total aggregate liability is limited to the greater of (a) US$500 and (b) the amounts you actually earned and were paid under the Program in the 12-month (Schedule A) period before the claim arose. This cap does not apply to the wrongful-withholding entitlement above, to amounts that cannot lawfully be capped (Section 20.3), and is subject to mandatory local law (Section 19.3).

20.3. Nothing here excludes or limits any liability that cannot lawfully be excluded or limited (for example, fraud, gross negligence, or non-waivable statutory rights).

21. General provisions

21.1. Severability. If any provision is held invalid or unenforceable, it is modified to the minimum extent necessary or, failing that, severed for that jurisdiction only, and the remainder continues in full force. 21.2. No waiver. Failure to enforce a provision is not a waiver of the right to enforce it later. 21.3. Assignment. We may assign this Policy as part of a transfer of the Platform or our business. You may not assign your Program rights. 21.4. Entire agreement (as to the Program). This Policy, together with Schedule A and the ToS and Privacy Policy it incorporates and is incorporated into, is the entire agreement on the Program and supersedes prior Program communications, subject to Section 2.3. 21.5. Controlling language. This Policy and Schedule A are published in full in English, and full Spanish, Portuguese, and Arabic versions are made available before any collector in those languages is asked to accept. For a collector resident in Latin America, or in any jurisdiction whose mandatory law requires a contract to be in the collector's local language, the Spanish or Portuguese version (as applicable to that collector) is the controlling version for that collector. For all other collectors, the English version controls in case of conflict. truelabel will not rely on a non-binding "for convenience" translation against any collector. The full Policy (not only the summary) is translated and presented in the collector's language before acceptance.

22. Questions

Questions about the Program or this Policy? Contact us at [email protected] or through in-app help.

Schedule A — General default framework figures (dated, versioned; forms part of this Policy)

Schedule A version: A-1 In effect from: July 4, 2026 Supersedes: none

How to read this Schedule. These are the general default framework values. They apply to a program unless that program's own published, dated Schedule A adopts different values — which it may do only within the framework and protections of this Policy (Section 6) and, where indicated, only where the applicable jurisdiction's law permits.

Item	Value
Collector base rate (own Accepted Hours)	US$5.00 per Accepted Hour
Buddy Referral rate	US$0.50 per Accepted Hour a Referred Collector is paid for
Eligibility Gate (Leg 1) — program-defined; optional	Default: completion of collector onboarding/qualification plus identity/KYC verification (Section 14 Screening) — no own-paid-hours precondition. Once reached, it stays reached. A specific program's Schedule A may add an hours-based milestone (e.g., a small number of own Accepted Hours) for anti-fraud, or define no gate at all beyond Screening.
Weekly cap (Leg 1) — DEFAULT form (flat, wage-decoupled)	flat US$25 per Week; not linked to own Base Earnings; no own-filming requirement. This is the standard form unless a program's Schedule A elects the alternative below.
Weekly cap (Leg 1) — optional base-earnings-linked alternative (per-program, only where lawful)	A program may elect this only in a jurisdiction whose law affirmatively permits linking an incentive cap to a contractor's own earnings (no wage-integration/primacy-of-reality bar): the smaller of (a) US$25 per Week; or (b) 50% of your own Base Earnings that Week. Not a universal rule — a program may decline it and use the flat cap (or no cap) instead.
Programs / jurisdictions electing the base-earnings-linked alternative	None by default. The flat, wage-decoupled US$25 cap is the default everywhere. A program electing the alternative must name the jurisdiction and the cap form in its own published Schedule A.
"Week" definition	Monday 00:00 – Sunday 23:59 UTC
Bonus disbursement cadence (both legs)	Monthly (separate from weekly base pay)
Base Earnings denominator (only where a program elects the base-earnings-linked cap)	Your own paid Accepted Hours × base rate for the Week; excludes all Bonuses
Excess carry-forward period (Leg 1)	up to 8 Weeks, then the uncapped excess EXPIRES ($0); unexpired carry-forward is paid on wind-down/closure (§§8.3, 11.6)
Per-referee window (Leg 1)	first 250 Accepted Hours or 12 months after they join, whichever first
Aggregate same-household / coordinated-cohort cap (§10.8)	Default: 3 Referred Collectors sharing a household, payout identity, device, or IP triggers cohort review; the cohort's combined Buddy Referral Bonus is capped at one flat weekly cap (US$25) across the cohort pending a Genuine-Introduction determination. A program may adjust these values in its Schedule A.
Community Partner rate (Leg 2)	US$1.00 per Accepted Hour an Introduced Collector is paid for
CP taper schedule (Leg 2)	days 1–30: 100%; 31–60: 66%; 61–90: 33%; after 90 days: $0
CP per-recruit cap	US$150 per Introduced Collector
CP monthly aggregate cap	US$2,000 per calendar month across all recruits
CP income-share cap (§3.5)	Default: Program Bonuses may not exceed 50% of a Community Partner's total business income over any trailing 12-month period, as attested at application and on annual re-attestation. A program may set a lower share in its Schedule A.
Reserve / holdback % (both legs)	20% of each accrued Bonus (base); mandatory up to 100% for new/unproven referees and for referees/cohorts above the reversal-rate threshold below
Reversal-rate threshold triggering mandatory elevated Reserve (§12.5)	Default: referee/cohort reversal rate above 25% over the trailing 8 Weeks. A program may set a stricter (lower) threshold in its Schedule A.
Finalization Window (both legs)	45 days from the date the underlying hours were paid / partner-confirmed (mandatorily extended for new/unproven and high-reversal cohorts)
Forward-Offset lookback cap (good-faith reversals)	12 months from the date the Bonus was paid
Leg-1 first-payout review/hold window	up to 14 days for KYC + Screening + initial fraud review
CP maximum decision window (§9.2)	30 days after complete verification submitted
Reclaim window for blocked/unclaimed payouts (§11.5)	90 days
Minimum payout threshold	US$10 accrued before a routine payout; sub-threshold balances are paid on inactivity sweep, Program end, or account closure (§11.6)
Long-inactive sub-threshold sweep (§11.6)	Default: any remaining payable balance is paid out after 12 months of no accrual, subject to Screening.
Small-dispute threshold (free online ODR is the forum) (§19.1)	Default: disputes ≤ US$500.
AML record-retention period (§14.6)	5 years (or longer if local law requires)
Support acknowledgement time (§19.1(a))	5 business days
Appeal filing window (§19.1(b))	30 days
Appeal response time (§19.1(c))	15 business days
Liability look-back period (§20.2(b))	12 months
Liability floor (§20.2)	US$500

Every value above is a single locked default figure. A specific program may adopt different values only in its own published, dated Schedule A and only within this Policy's framework and protections. Changes are prospective only and issued as a new dated Schedule A version under Section 18; they never reduce already-accrued Bonuses (Section 18.3).