Privacy Policy

FBA CAPITAL LLC d/b/a Fear Being Average ("Company," "we," "our," or "us") is committed to protecting your privacy and safeguarding your personal information.

This Privacy Policy explains how we collect, use, disclose, and protect your information across our website at fbainnercircle.org, our programs, our community platforms, and all related services.

By accessing or using our services, you consent to the practices described in this policy. If you do not agree, you should not use our services.

We collect both personal and non-personal information to operate and improve our services.

a) Personal Information

We may collect:

• Full name
• Email address
• Phone number
• Age or date of birth, for eligibility verification
• Information submitted through forms, applications, onboarding questionnaires, or surveys
• Communication data from sales calls, mentorship calls, support interactions, and community messages
• Audio and video recordings of calls you attend, as described in Section 4
• Trading journals, screenshots, charts, or other materials you voluntarily submit for review

With your permission, we may also access limited data from connected platforms, such as social media profile information, to provide requested services.

Payment Information: We do not store or process full payment details. All transactions are securely handled through third-party payment providers such as Whop, Stripe, or similar platforms. Those providers maintain their own privacy policies governing your payment data.

b) Automatically Collected Data

We may collect technical and behavioral data using cookies, pixels, and similar technologies, including:

• IP address
• Device and browser type
• Operating system
• Pages visited and user interactions
• Referral sources
• Ad and content engagement
• Video watch time and content consumption data

This data may be linked to your device but is not used on its own to directly identify you.

c) Location Data

We and our advertising partners may collect approximate location data derived from your IP address to improve your experience and to deliver relevant content.

Location data is anonymized unless you explicitly authorize otherwise. You may manage location permissions through your device or browser settings.

We use your information to:

• Provide access to programs, course content, mentorship calls, live trading sessions, and community platforms
• Schedule and deliver one-on-one calls and group sessions
• Verify eligibility, including age and legal capacity
• Communicate updates, reminders, support, and educational content
• Deliver marketing and retargeting communications, with opt-out available at any time
• Improve platform performance, curriculum, and user experience
• Conduct analytics and performance tracking
• Prevent fraud, unauthorized access, and content piracy
• Comply with legal and regulatory obligations

Live trading sessions, group educational calls, backtesting calls, and one-on-one mentorship calls may be recorded, including audio, video, screen shares, and any charts or account information you choose to display.

By joining any call, you consent to being recorded.

Recordings may be used within the program, in future course material, and in marketing content. If you do not wish to appear in publicly used material, notify us in writing at andre@fbainnercircle.org before the call and keep your camera and microphone off.

You are responsible for what you display on your screen. Do not show account numbers, personal identification, or any information you are not comfortable having recorded and potentially published.

By providing your phone number and opting in, you expressly consent to receive SMS or MMS messages from Fear Being Average, which may include:

• Program updates and announcements
• Call reminders and scheduling notifications
• Educational content
• Promotions or offers

Important details:

• Consent is not a condition of purchase
• Message frequency varies, up to 10 messages per month
• Message and data rates may apply
• You may opt out at any time by replying STOP
• You may request help by replying HELP
• After opting out, you may receive a single confirmation message
• Carriers are not liable for delayed or undelivered messages

Data Protection: No mobile information or SMS consent data will be shared with or sold to third parties for their own marketing or promotional purposes.

We do not sell your personal data.

a) Trusted Service Providers

We may share your information with third-party providers who help us operate the business, including:

• Whop, for payments, course hosting, and access management
• Discord and Telegram, for community access
• Zoom and similar video conferencing tools, for calls
• CRM, email, and SMS platforms
• Scheduling and calendar tools
• Analytics tools, such as Google Analytics
• Advertising platforms, such as Meta, Google, and TikTok

These providers operate under confidentiality and data protection obligations and are permitted to use your information only to perform services on our behalf.

b) Advertising and Analytics

Third-party platforms may collect anonymized behavioral and device data to deliver personalized advertising.

This data is associated with your device rather than your identity. You may opt out of targeted advertising through your browser settings, your device settings, or the ad preference controls offered by each platform.

c) Legal Requirements

We may disclose your information:

• If required by law, subpoena, or court order
• To protect our legal rights, our users, or our property
• To investigate fraud, piracy, or violations of our Terms of Service
• In connection with a merger, acquisition, financing, or sale of assets

You have the right to:

• Request access to the personal data we hold about you
• Request correction of inaccurate information
• Request deletion of your data

To make a request, contact us at andre@fbainnercircle.org. We will respond within the timeframe required by applicable law.

We retain personal data for as long as your account is active and for a reasonable period afterward to meet legal, tax, accounting, and dispute resolution obligations. We may retain certain records, including transaction history, communications relating to a dispute, and call recordings, after a deletion request where retention is required or permitted by law.

Deleting your data may end your access to purchased programs. Deletion does not cancel outstanding payment obligations.

We implement reasonable technical and administrative safeguards to protect your information.

However, no system is completely secure and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for all activity that occurs under your account.

Our services are intended solely for individuals 18 years of age and older. We do not knowingly collect personal information from anyone under 18.

If we become aware that we have collected personal information from a person under 18, we will delete it promptly and terminate any associated account.

If you believe a minor has provided us with personal information, contact us at andre@fbainnercircle.org.

Our services are operated in the United States.

If you access our services from outside the United States, you consent to your data being transferred to, processed in, and stored in the United States, where data protection laws may differ from those in your country.

If you are a California resident, you have the right to:

• Know what personal information we collect, use, and disclose
• Request deletion of your personal information
• Request correction of inaccurate personal information
• Opt out of the sale or sharing of personal information
• Not be discriminated against for exercising these rights

We do not sell personal information as that term is defined under the California Consumer Privacy Act.

To exercise your rights, contact andre@fbainnercircle.org. We may need to verify your identity before processing your request.

If you are a resident of a state with a comprehensive consumer privacy law, including but not limited to Virginia, Colorado, Connecticut, Utah, Texas, Oregon, or Florida, you may have rights to access, correct, delete, or obtain a copy of your personal data, and to opt out of targeted advertising.

To exercise these rights, contact andre@fbainnercircle.org.

You may:

• Unsubscribe from marketing emails using the link in any email
• Opt out of SMS messages by replying STOP
• Request deletion of your data by emailing andre@fbainnercircle.org
• Manage cookies and tracking through your browser settings
• Adjust ad personalization settings on Meta, Google, and other platforms

We do not currently respond to browser "Do Not Track" signals.

Our website, content, and community may contain links to third-party websites, brokers, prop firms, or tools. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing any personal information.

We may update this Privacy Policy at any time. Material changes will be posted on this page with a revised Effective Date.

Continued use of our services after an update constitutes acceptance of the revised policy.

FBA CAPITAL LLC d/b/a Fear Being Average — Email: andre@fbainnercircle.org — Website: fbainnercircle.org