Bolton-Strid

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Privacy Policy

The Bolton-Strid Foundation Inc. and The Bolton-Strid Corporation (“we,” “our,” “us,” “Foundation,” or “Corp”) respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and share information when you visit www.bolton-strid.org (the “Website”), interact with our services, participate in the Bolton-Strid Hyperledger Fabric network (the “Network”) as a Layer 1 or Layer 2 participant, or otherwise acquire, hold, or transact with CryptoCyte™ or other NEXFT units issued by the Foundation. By using our Website or services, you agree to the practices described in this Privacy Policy.

Who This Policy Covers

The Foundation and Corp are separate legal entities that operate under this shared Privacy Policy for the convenience of Website visitors and Network participants. The Foundation governs unit issuance, allocation, and Layer 1 participation; Corp operates the commercial infrastructure supporting the Network, including Layer 2 participant onboarding and related services. Where this Policy refers to information handled by one entity specifically rather than jointly, it will say so. Corp subsidiaries operating under separate offerings (described in our Investment Disclaimer) maintain their own privacy practices for matters specific to those businesses.

Information We Collect

We may collect the following types of information:

a. Personal Information

  • Name, email address, postal address, phone number, and other contact details;
  • Information regarding your organization, business, or the individual(s) authorized to act on its behalf;
  • Government-issued identification and organizational documentation (for identity verification, accreditation, and KYC/AML compliance applicable to Network membership);
  • For Layer 1 participants: information submitted to document and verify a capital or quality-improvement need in connection with a unit allocation, as described in our Network Overview;
  • Network identity credentials issued through the Fabric membership service provider (MSP) associated with your organization, and transaction records related to unit ownership and transfers;
  • Any additional information required for KYC/AML compliance or Network accreditation.

b. Non-Personal Information

  • IP address, browser type, device information, operating system, and access times;
  • Usage data including pages visited, click patterns, and interactions with the Website;
  • Cookies and similar technologies to improve functionality and analytics.

How We Use Your Information

We use your information to:

  • Provide, operate, and maintain the Website and Network-related services;
  • Verify identity and eligibility for Network membership and Layer 1 or Layer 2 participation, including verification of submitted needs estimates for Layer 1 allocations;
  • Facilitate unit issuance, transfers, and ownership verification on the permissioned Network;
  • Comply with legal obligations, including KYC/AML and nonprofit governance requirements;
  • Communicate updates, changes, or important notifications regarding the Foundation, Corp, or the Network;
  • Monitor and analyze usage and trends to improve our services and security;
  • Protect against fraud, unauthorized access, or illegal activity;
  • Enforce our Terms of Service.

How We Share Your Information

We do not, and never will, sell your personal information. We may share your information in the following circumstances:

  • Between the Foundation and Corp: as needed to operate the Network and administer Layer 1 and Layer 2 participation, consistent with the arm’s-length governance practices described in our Network Overview;
  • Service Providers: with trusted third-party providers who assist with Network infrastructure, identity/accreditation verification, payment processing, analytics, or security. These parties are bound by confidentiality obligations;
  • Accredited Data-Governance Participants: with organizations participating in the Network’s endorsement and data-governance processes, limited to information necessary for their verification role;
  • Legal Compliance: when required by law, regulation, or legal process;
  • Business Transfers: in the event of a merger, acquisition, or sale of assets of the Foundation or Corp;
  • Protection of Rights: to enforce our Terms of Service, protect Foundation or Corp property, or prevent illegal activities.

We do not share your information with third-party liquidity providers described in our Network Overview; any interaction you choose to have with such a provider is governed directly by that provider’s own privacy practices, as described further below.

Data Security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Network identity credentials are managed through the Fabric membership service provider (MSP) structure rather than a public wallet system. Nevertheless, transmission via the Internet is not completely secure, and we cannot guarantee the security of information about you.

Data Retention

We retain personal information only as long as necessary to provide services, comply with legal obligations, resolve disputes, and enforce agreements. Once data is no longer required, it will be securely deleted or anonymized.

User Rights and Choices

Depending on your jurisdiction, you may have rights to:

  • Access, correct, or delete your personal information;
  • Object to or restrict certain processing;
  • Withdraw consent where processing is based on consent;
  • Receive a copy of your data in a structured, machine-readable format.

Where you request the deletion of your information, we may continue to retain and use your information as required under applicable laws for legal, tax, or regulatory reasons.

To exercise these rights, contact privacy@bolton-strid.org.

Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to enhance user experience, analyze traffic, and improve our services via our Website. You may disable cookies through your browser settings; however, some features of the Website may not function properly without cookies.

Third-Party Websites and Services

We may integrate technologies operated or controlled by other parties into parts of the Website, and the Website may include links to websites, platforms, or interfaces not operated or controlled by us. This includes independent, unaffiliated third-party liquidity providers who may, at their own discretion, offer to purchase Network units for cash, as described in our Network Overview. We do not operate, own, or control any such provider.

Please note that when you interact with other parties, including when you leave the Website or engage a third-party liquidity provider, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices with respect to their services, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use directly.

Children’s Privacy

The Website is intended for general audiences and is not directed at children. We do not knowingly collect Personal Information (as defined by the U.S. Children’s Online Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected Personal Information in violation of COPPA, please contact us at privacy@bolton-strid.org and we will remove the Personal Information in accordance with COPPA if it exists.

International Data Transfers

Your information may be transferred to, and maintained on, servers located outside your country of residence. By using our services, you consent to such transfers and understand that your data will be subject to the laws of the receiving jurisdiction.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in practices, technology, or legal requirements. Updates will be posted on the Website with a revised effective date. Your continued use of the Website or Network services constitutes acceptance of the updated Privacy Policy.

Contact Information

If you have questions about this Privacy Policy or your personal information, please contact: privacy@bolton-strid.org

Consumer Protection

The Bolton-Strid Foundation Inc. (“we,” “our,” or “Foundation”) and The Bolton-Strid Corporation (“Corp”), together operating www.bolton-strid.org (the “Website”) and the Bolton-Strid Hyperledger Fabric Network (the “Network”), are committed to maintaining the highest standards of consumer and participant protection for all users of our Website and holders of NMD™ units. This Consumer Protection Policy (“Policy”) outlines our commitments, practices, and safeguards designed to protect your rights and interests. This Policy does not create or imply any contractual right, governance claim, or claim on the Foundation or Corp, but expresses operational standards.

Transparency and Accuracy

To the extent reasonably practicable and without guaranteeing future performance or market outcomes:

  • We strive to provide clear, accurate, and accessible information about the Network, unit allocation, participation, and any associated risks.
  • All information provided on the Website, in whitepapers, litepapers, network overviews, or other communications is reviewed for accuracy and completeness.
  • We disclose any material updates or changes to unit functionality, Network mechanics, or services promptly on the Website and via official communication channels.

Unit Value and Risks

  • NMD™ units are designated as Non-Participatory Externally Valued Asset States (NEXAS™).
  • Unit supply is not an arbitrarily chosen, computer-coded number; it is tied to net annual change in the licensed, patient-care physician workforce, as reported by accredited third-party organizations.
  • Unit value is mathematically tied to publicly verifiable aggregate physician productivity metrics, determined annually through an independently commissioned IMPLAN economic study. The Foundation does not control, manage, or influence this value; it is determined solely by underlying economic data involving the supply of and demand for physician services. Physicians themselves do not contribute assets or financial backing to create unit value; unit value is an abstraction of physician economic productivity that exists independently of the Foundation, Corp, or the Network.
  • While the system is designed for stability, participants are informed that unit-based participation carries inherent risks, including operational, counterparty, tax, and healthcare-sector risks.
  • Risks associated with NMD™ units are disclosed in our Risk Disclosure.

Participation, Allocation, and Transactions

  • Units are not sold or offered for public purchase. Layer 1 healthcare participants receive units through a free allocation from the Foundation, sized to a documented and verified capital or quality-improvement need. Layer 2 business participants earn units by accepting them as payment for goods or services provided to Layer 1 participants or other Layer 2 participants.
  • Participants who wish to convert units to cash may do so only through independent, unaffiliated third-party liquidity providers, at that provider’s own discretion and terms; the Foundation and Corp do not operate, own, or control any such provider and are not a party to that transaction.
  • All Network transactions are processed on the permissioned Hyperledger Fabric ledger through participant-specific digital identities issued via the Network’s membership service provider (MSP) infrastructure, not through public blockchain wallets or smart contracts.
  • The Foundation maintains accurate records of allocations made directly to Layer 1 participants; all subsequent ownership and transfer records are recorded on the permissioned ledger and are visible to participants and accredited governance bodies in accordance with the Network’s channel and endorsement architecture, rather than being publicly viewable in the manner of a public blockchain explorer.
  • Participants are responsible for maintaining the confidentiality and proper administration of their Network identity credentials.

Customer Support and Dispute Resolution

  • The Foundation and Corp maintain a dedicated support channel for participant inquiries and complaints: consumerprotection@bolton-strid.org.
  • Complaints will be acknowledged within 48 hours, and efforts will be made to resolve issues within 10 business days.
  • Participants may escalate unresolved disputes following the procedures outlined in the Terms of Service, including arbitration if applicable.

Consumer and Participant Rights

Users have the right to:

  • Access and review their unit holdings and allocation history;
  • Request clarification regarding Network operations, unit valuation, allocation criteria, and functionality;
  • Report suspicious activity or potential security breaches;
  • Exercise rights related to data privacy, as outlined in the Privacy Policy.

Neither the Foundation nor Corp charges hidden fees or imposes unexpected obligations on Layer 1 participants, whose allocations remain free of charge. Any fees applicable to Layer 2 participants — including network access, membership, or accreditation fees — are disclosed in advance and described in our Network Overview.

Security and Fraud Prevention

  • The Foundation and Corp implement best-in-class security measures to protect participant data, Network identity credentials, and ledger records.
  • Multi-factor authentication, encrypted storage, and permissioned-network access controls (including MSP-based identity verification and endorsement policies) are utilized.
  • Participants are encouraged to report suspicious activity or unauthorized access immediately.

Anti-Fraud and Anti-Money Laundering (AML) Compliance

  • The Foundation and Corp comply with applicable AML and KYC requirements for Network membership, accreditation, and unit transactions, consistent with the Bank Secrecy Act (BSA) and applicable state and federal law.
  • Network participation is limited to accredited, verified organizations; transactions involving fraudulent, illegal, or high-risk activity are subject to participant suspension, credential revocation, and unit recovery in accordance with Network governance policy.
  • Participants are expected to provide accurate information — including accurate documentation supporting any Layer 1 needs-based allocation request — and to cooperate with verification procedures if requested. The Foundation and Corp reserve the right to suspend or revoke access for illegal or high-risk activity.

Foundation Statement of Political Neutrality

The Bolton-Strid Foundation Inc. (“we,” “our,” or “Foundation”) maintains a position of strict political neutrality. Our mission is to advance healthcare, science, and innovation in service of public well-being — independent of any political ideology, party affiliation, or governmental influence.

We neither endorse nor oppose political candidates, organizations, or movements. All decisions, partnerships, and communications are guided solely by evidence-based reasoning, ethical standards, and the pursuit of equitable healthcare outcomes, including the Foundation’s work addressing the funding and infrastructure gap facing financially distressed rural healthcare facilities.

Our work is focused on collaboration, research, and the advancement of ideas that improve systems and lives, without regard to political or partisan considerations.

This Political Neutrality statement applies solely to The Bolton-Strid Foundation Inc. in its capacity as a nonprofit mission-governance entity. It does not extend to or restrict The Bolton-Strid Corporation, a separate for-profit affiliate, or its subsidiaries, which operate under ordinary commercial governance and are not bound by this statement.

If you have any questions or concerns, please email us at consumerprotection@bolton-strid.org.

Terms of Service

These Terms of Service (“Terms of Service” or “Terms”) apply to your access to and use of www.bolton-strid.org (the “Website”). “We,” “us,” “our,” “Foundation,” and “Corp” refer to The Bolton-Strid Foundation Inc. and The Bolton-Strid Corporation, respectively, together with their respective affiliates and subsidiaries. These Terms also apply, without limitation, to participation in the Bolton-Strid Hyperledger Fabric Network (the “Network”), including the allocation, receipt, holding, and transfer of NMD™ units and any future NEXAS™ (Non-Participatory Externally Valued Asset States) created or issued by the Foundation.

Changes to Terms of Service

The Foundation and Corp may revise and update these Terms at any time without notice; all changes are effective immediately upon posting on the Website. If you do not agree to the revised terms, your recourse is to stop using the Website or participating in the Network.

Privacy

Our privacy policy can be found here.

Prohibited Activities

You agree not to:

  • Reverse engineer or attempt to access the underlying code, chaincode, or infrastructure of the Website, the Network, or any Foundation or Corp applications;
  • Impersonate any person or entity or misrepresent your affiliation or Network accreditation status;
  • Introduce viruses, malware, or harmful code;
  • Use the Website or Network for spam, DDoS attacks, or unlawful communications;
  • Violate local, state, or national law;
  • Harm the Foundation, Corp, their affiliates, or other Network participants;
  • Harvest information without authorization;
  • Take actions that impose disproportionate loads on Foundation, Corp, or Network infrastructure;
  • Conduct automated queries or unauthorized access attempts;
  • Interfere with the proper working of the Website or the Network;
  • Submit false, inflated, or unsubstantiated needs estimates in connection with a Layer 1 unit allocation request.

Third-Party Services

The Foundation and Corp may reference or provide access to third-party services, including independent, unaffiliated third-party liquidity providers described in our Network Overview. Use of such services is at your own risk and subject to that provider’s own terms. Neither the Foundation nor Corp operates, owns, controls, or is a party to any transaction between you and a third-party liquidity provider, and neither is responsible for third-party actions, privacy policies, security, or accuracy of data. You agree to indemnify the Foundation and Corp from claims arising from third-party usage tied to your account.

Dispute Resolution

All disputes, except intellectual property claims, will be resolved through binding individual arbitration under the rules of the American Arbitration Association (“AAA”). You, the Foundation, and Corp waive rights to a court trial, jury trial, or class/representative actions.

Informal Dispute Resolution: Before arbitration, parties must attempt informal resolution by notifying the other party within 30 days. Notice to the Foundation or Corp: consumerprotection@bolton-strid.org. The parties agree to negotiate in good faith for 60 days, including, but not limited to, in person, email, video conference, text messaging, and at least one telephonic dispute resolution conference.

Arbitration Process: Arbitration will occur under AAA rules, in Billings, Montana, in English. Arbitrators will apply substantive law consistent with the FAA (9 U.S.C. §1 et seq.). Arbitration awards will respect any limitations of liability set forth in these Terms.

Governing Law and Venue

These Terms and all disputes arising from them are governed by the laws of the State of Montana, without regard to conflict-of-law principles. Arbitration provisions are governed by the FAA. Non-arbitrable disputes will be resolved exclusively in the courts of Montana.

Severability

If any provision outlined herein is held illegal or unenforceable, it shall be severed without affecting the remainder of these Terms, which remain fully enforceable.

Miscellaneous

These Terms constitute the entire agreement regarding your use of the Website, participation in the Network, or holding of NMD™ or other NEXAS™. Participating in the Network or holding units does not create a partnership, joint venture, or similar relationship, and does not constitute an investment in, or securities transaction with, the Foundation, Corp, or the Network.

Disclaimer of Warranties

Use of the Website and the Network is at your sole risk. The Website, the Network, and NMD™/NEXAS™ units are provided “as is” without warranties of any kind, including merchantability, fitness for purpose, or non-infringement.

Limitation of Liability

To the maximum extent permitted by law, neither the Foundation nor Corp is liable for any indirect, incidental, punitive, or consequential damages arising from use of the Website, participation in the Network, or holding of units. The Foundation’s and Corp’s total combined liability will not exceed $5,000 USD or the amount paid by you to the Foundation or Corp for access, whichever is greater.

Additional Terms

The failure to enforce any provision does not constitute a waiver. These Terms are not assignable by you without prior written consent, though the Foundation and Corp may assign freely. No joint venture, partnership, or fiduciary relationship is created by these Terms.

Corporate Disclosures

The Bolton-Strid Foundation Inc. and The Bolton-Strid Corporation are committed to transparency, accountability, and compliance with applicable laws and regulations. Our Corporate Disclosures page provides information regarding the governance, operational structure, unit issuance, and financial accountability of both entities. Our objective is to ensure that stakeholders, regulators, and the public have confidence in the integrity of our work. You can view our Corporate Disclosures Here.

Risk Disclosure

This Risk Disclosure Statement is provided to all Network participants and holders of NMD™ units. It outlines the risks associated with allocation, receipt, holding, transfer, and use of NMD™ units on the Bolton-Strid Hyperledger Fabric Network (the “Network”). Participants are required to review this statement carefully before participating in the Network.

Nature of NMD™

NMD™ is a Non-Participatory Externally Valued Asset States (NEXAS™) unit. Its valuation is derived from independently verified, annually updated U.S. physician economic productivity data, determined through an independently commissioned IMPLAN economic study. Unlike speculative cryptocurrencies, NMD™ does not fluctuate based on trading volume, investor sentiment, or market volatility. Instead, its valuation is tied exclusively to the real-world, annual economic output of actively employed, patient-care physicians. NMD™ is not a security or investment vehicle; unit holders have no corporate or governance rights and no equity, ownership, or claim on the Foundation or The Bolton-Strid Corporation (“Corp”).

Risks Associated with NMD™

a. Valuation Risk

NMD™ is valued according to third-party economic input/output data modeling (e.g., IMPLAN physician productivity studies). While designed to be stable and non-speculative, changes in physician labor force participation, productivity metrics, or broader healthcare economics such as service pricing may impact value.

  • A decrease in physician productivity or systemic changes in the healthcare sector could impact the value of NMD™ units.
  • A decrease in healthcare prices could impact the value of NMD™ units.
  • A decrease in the number of active patient-care physicians could impact the value of NMD™ units.

b. Liquidity Risk

NMD™ is intended to be used as a closed-loop settlement instrument within the Network, not as a speculative trading asset. It is not listed on, and the Foundation does not operate, any exchange or trading platform. Liquidity for participants who wish to convert units to cash depends entirely on the independent decision of unaffiliated third-party liquidity providers to offer such a service, at their own discretion and pricing.

  • Neither the Foundation nor Corp guarantees the existence, availability, pricing, or terms of any third-party liquidity option.
  • Neither the Foundation nor Corp redeems, repurchases, or converts NMD™ units for cash under any circumstances.
  • Network participation and unit allocation are limited to accredited Layer 1 healthcare entities and accredited Layer 2 business participants approved in accordance with Network governance; there is no individual consumer market for NMD™ units.

c. Finality of Transactions

All Network transactions are final once committed to the ledger. Neither the Foundation nor Corp redeems units.

d. Operational and Technological Risk

NMD™ transactions occur on the Bolton-Strid Hyperledger Fabric Network, a permissioned distributed ledger. Participants assume risks inherent in distributed ledger technology, including:

  • Network downtime, congestion, or delays;
  • Chaincode (smart contract) vulnerabilities or bugs, including in future upgrades;
  • Risk of loss of access due to mismanagement, loss, or compromise of Network identity credentials issued through the Network’s membership service provider (MSP) infrastructure;
  • Risk of transferring units to an incorrect or unintended participant account;
  • Hardware or software failure affecting Network infrastructure or a participant’s own systems;
  • Risks associated with the endorsement, ordering, and consensus processes underlying ledger commitment.

e. Regulatory Risk

NMD™ is structured as a non-speculative, externally valued digital asset and, based on the analysis set forth in our Network Overview, is not believed to constitute a security under the Howey or Reves tests, and is not subject to regulation by the U.S. Securities and Exchange Commission on that basis. NMD™ is not a security or investment vehicle; unit holders have no corporate or governance rights and no claim on the Foundation or Corp. However, regulatory frameworks applicable to digital assets, distributed ledger technology, and asset classification continue to evolve, and no regulatory body has issued a determination specific to NMD™. Participants accept the risk that changes in U.S. or international law, tax policy, or financial regulation may affect the use, transfer, or classification of NMD™ units.

f. Custodial and Counterparty Risk

Neither the Foundation nor Corp provides custodial services for cash or other assets. Participants are responsible for securing access to their own Network identity credentials in accordance with their organization’s internal controls.

  • Neither the Foundation nor Corp is liable for losses due to fraud, theft, credential mismanagement, or the insolvency of any third-party service provider, including any independent third-party liquidity provider.
  • Participants are encouraged to implement industry-standard security practices, including multi-factor authentication and internal access controls appropriate to their organization.

g. Economic and Policy Risk

NMD™’s valuation is tied to physician productivity within the U.S. healthcare system. Changes in healthcare policy, physician reimbursement models, workforce participation, or broader economic disruptions may influence valuation trends over time.

  • While designed for stability, NMD™ is not entirely immune to macroeconomic, demographic, or labor-market shocks.
  • NMD™ is not legal tender recognized by the U.S. Government.

h. Tax Risk

NMD™ units received by a participant are generally treated as ordinary income at fair market value on the date of receipt, and appreciation over time in connection with the annual valuation update may result in further tax consequences depending on a participant’s specific circumstances. Participants are responsible for their own compliance with applicable federal, state, and local tax law and reporting obligations. Neither the Foundation nor Corp provides tax advice, and participants should consult their own tax advisors.

i. Risk of Uninsured Losses

In the event of any loss of NMD™ units or loss of access to Network identity credentials, there is no public insurer, such as the Federal Deposit Insurance Corporation, or private insurer, to offer recourse to the participant. NMD™ unit holdings are not protected, guaranteed, or reimbursed by any governmental, regulatory, or other entity.

j. Risk of Weaknesses or Exploitable Breakthroughs in Cryptography

Advances in cryptography, or technical developments such as the emergence of practical quantum computing, could present risks to the cryptographic mechanisms underpinning the Network’s permissioned ledger, identity infrastructure, and endorsement processes.

Participant Acknowledgment

By receiving, holding, or participating in transactions involving NMD™ units, the participant expressly acknowledges and agrees that they:

  • Have read and understood this Risk Disclosure Statement;
  • Accept that NMD™ is not an investment vehicle, speculative asset, or security, and that participation in the Network does not confer equity, governance, or ownership rights in the Foundation or Corp;
  • Recognize that while NMD™ units are valued based on real-world economic fundamentals, risks remain inherent to distributed ledger technology and to participation in the Network;
  • Assume full responsibility for their receipt, holding, and use of NMD™ units, and accept all associated technology and operational risks described above.

Contact

If you have any questions regarding this Risk Disclosure, please contact us at: admin@bolton-strid.org

Regulation D Rule 506(c) Offering

The Bolton-Strid Corporation (“Corp”), a Montana corporation and majority-owned affiliate of The Bolton-Strid Foundation Inc. (“Foundation”), is currently conducting a private placement of its common stock pursuant to the exemption provided by Rule 506(c) of Regulation D under the Securities Act of 1933, as amended. This offering is available exclusively to accredited investors as defined in Rule 501(a) of Regulation D.

Important Verification Requirement: In accordance with Rule 506(c), the Company is required to take reasonable steps to independently verify the accredited investor status of all purchasers before accepting any subscription. This may involve review of financial documentation (such as tax returns, bank statements, or brokerage statements) or written confirmation from a qualified third party, such as a registered broker-dealer, SEC-registered investment adviser, licensed attorney, or certified public accountant. Self-certification alone does not satisfy this requirement.

What This Offering Is — and Is Not

An investment in this offering is an investment in the equity of Corp and, where applicable, its subsidiaries. It is not an acquisition of, right to, or claim on NMD™ units, NEXAS™ assets, or any allocation on the Bolton-Strid Hyperledger Fabric Network, and it confers no rights of Network participation. The value of Corp’s common stock is a function of Corp’s business operations, revenue, and prospects — including its network access, membership, data, and integration services revenue, and its ownership interests in its IP subsidiaries — and is not derived from, pegged to, or guaranteed by the annual physician economic output index described in our Network Overview. Corp’s revenue model and subsidiary structure are described in further detail in the Confidential Private Placement Memorandum available to qualified prospective investors.

Relationship to the Foundation

Corp is majority-owned and controlled by the Foundation, a nonprofit entity that separately governs the issuance, allocation, and supply of NMD™ units and holds no obligation to Corp’s investors. Corp does not hold a vote or influence over Foundation governance or mission-critical functions, including unit issuance and Layer 1 allocation, consistent with the arm’s-length governance structure described in our Network Overview and Corporate Disclosures.

Forward-Looking Statements

This website, and the offering materials referenced herein, contain forward-looking statements regarding our business strategy as it pertains to Corp, entities fully under Corp’s control, business entities in pre-incorporation or early development stages, and intellectual property held by Corp or its affiliates. These statements are based on current expectations and are subject to significant risks and uncertainties, including but not limited to the early stage of the Network’s development and adoption, the uncertain timeline and outcome of regulatory pathways applicable to Corp’s subsidiaries (including FDA clearance processes), reliance on the successful completion of this and related capital raises, and general risks associated with new business ventures. Actual results may differ materially from those expressed or implied by these forward-looking statements. No representation is made that any prospective results or projections will be achieved.

Access to Offering Materials

Qualified prospective investors who have been verified as accredited investors in accordance with Rule 506(c) may request access to the Confidential Private Placement Memorandum, Subscription Agreement, and related offering documents by contacting [investor relations contact — to be provided].

Contact

For questions regarding this offering, please contact: [to be provided]

State Securities Notices

Corp’s Regulation D, Rule 506(c) offering, and the separate offerings of its subsidiaries, may be subject to additional notice filing requirements under the securities laws of the states in which securities are offered or sold (“blue sky laws”), notwithstanding the federal exemption from registration provided by Rule 506(c).

Notice Filings

Corp intends to make any required state notice filings (such as a Form D notice filing and applicable filing fees) in states where investors are located, consistent with the National Securities Markets Improvement Act of 1996 (NSMIA) and applicable state law.

No Registration or Qualification

Securities offered under Rule 506(c) are not registered or qualified with the SEC or any state securities regulator, and investors do not receive the protections that would apply to a registered offering. Prospective investors should review the Confidential Private Placement Memorandum and consult their own legal and financial advisors before investing.

State-Specific Disclosures

Certain states may require additional disclosures or impose specific investor suitability standards. Any such state-specific requirements applicable to a given offering will be included in the offering materials provided to prospective investors in that state.

Conflict of Interest Policy

The Bolton-Strid Foundation Inc. (“Foundation”) and The Bolton-Strid Corporation (“Corp”) maintain this Conflict of Interest Policy to protect the integrity of their governance and to ensure that transactions between related parties are conducted fairly, transparently, and at arm’s length.

Scope

This Policy applies to all directors, officers, and key decision-makers of the Foundation and Corp, and to transactions between: (a) the Foundation and Corp; (b) Corp and any of its subsidiaries; (c) the Foundation, Corp, or any subsidiary and any individual serving as a director, officer, or contractor of more than one of these entities.

Duty to Disclose

Any director, officer, or key decision-maker who has an actual, potential, or apparent financial or personal interest in a proposed transaction, contract, or arrangement involving the Foundation, Corp, or a subsidiary must disclose that interest to the applicable governing board prior to any discussion, negotiation, or vote on the matter.

Recusal

An individual who has disclosed a conflicting interest under this Policy must not participate in, or be present for, deliberation or voting on the matter, except to provide factual information or answer questions if requested by the disinterested members of the applicable board.

Related-Party Transaction Review

All transactions between the Foundation and Corp, between Corp and its subsidiaries, or otherwise involving a related-party interest, are subject to the following:

  • Independent benchmarking of terms (e.g., royalty rates, management fees, licensing terms, or loan terms) against comparable arm’s-length transactions, using an independent valuation consultant, licensing specialist, or comparable-transaction analysis where appropriate;
  • Approval by a majority of disinterested directors or officers of the governing board with authority over the transaction;
  • Contemporaneous documentation of the terms, the basis for determining those terms are fair market value, and the vote or approval of disinterested decision-makers.

Compensation of Insiders

Any compensation — including compensation paid in NMD™ units, cash, or equity — provided to an individual who is also involved in forming or governing the Foundation, Corp, or a subsidiary is subject to independent review to confirm the compensation reflects a reasonable market rate for services rendered, consistent with private foundation self-dealing rules and public charity excess-benefit-transaction rules, as applicable to the Foundation’s tax-exempt status.

Periodic Review

Each director, officer, and key decision-maker will be asked to disclose any known conflicts of interest annually, and this Policy will be reviewed periodically by the Foundation’s board to ensure continued compliance with applicable nonprofit governance standards.

Contact

Questions regarding this Conflict of Interest Policy may be directed to: governance@bolton-strid.org

Network Membership and Parcitipation Agreement

This Network Membership and Participation Agreement (“Membership Agreement”) governs an organization’s participation in the Bolton-Strid Hyperledger Fabric Network (the “Network”) as a Layer 1 or Layer 2 participant, in addition to and not in place of the general Website Terms of Service.

Eligibility and Accreditation

Network participation is limited to organizations that have been reviewed and approved in accordance with the Network’s governance and accreditation process described in our Network Overview. The Foundation and Corp reserve sole discretion to approve, decline, suspend, or revoke Network membership.

Layer 1 Participants

  • Layer 1 participation is limited to qualifying healthcare entities (e.g., hospitals, clinics, blood banks, and organizations addressing social determinants of health).
  • Unit allocations are free of charge and are sized to a specific, documented capital or quality-improvement need submitted by the participant and verified in accordance with Network governance procedures described in our Network Overview.
  • Participants agree to submit accurate, substantiated needs estimates and to cooperate with any verification request. Submission of false, inflated, or unsubstantiated needs estimates is grounds for suspension or revocation of Network access.
  • Participants acknowledge that unit allocations are generally treated as ordinary income upon receipt and that tax consequences depend on the participant’s own circumstances; see our Risk Disclosure.

Layer 2 Participants

  • Layer 2 participation is limited to qualifying business entities that supply goods or services to Layer 1 participants or other Layer 2 participants.
  • Layer 2 participants earn units as payment for goods or services and may be subject to network access, membership, or accreditation fees as disclosed at the time of onboarding.
  • Layer 2 participants are responsible for their own tax treatment of units received and for remitting any sales tax or other obligations arising from a transaction, consistent with the mechanics described in our Network Overview.

Network Identity and Credentials

Each participant will be issued Network identity credentials through the Network’s membership service provider (MSP) infrastructure. Participants are responsible for the security and proper internal administration of their credentials and for promptly notifying the Foundation or Corp of any suspected compromise.

Suspension and Revocation

The Foundation and Corp reserve the right to suspend or revoke a participant’s Network access for violation of this Membership Agreement, the Website Terms of Service, or applicable law, or for fraudulent, illegal, or high-risk activity, consistent with our Consumer Protection Policy.

No Investment Relationship

Network participation, including receipt or holding of NMD™ units, does not constitute an investment in, or securities transaction with, the Foundation or Corp, and confers no equity, governance, or ownership interest, consistent with our Terms of Service and Risk Disclosure.

Contact

Questions regarding Network membership may be directed to: governance@bolton-strid.org

Electronic Signature and Communications Consent

By participating in the Network, submitting a subscription for Corp securities, or otherwise transacting electronically with the Foundation or Corp, you consent to the use of electronic records and electronic signatures in accordance with the U.S. Electronic Signatures in Global and National Commerce Act (ESIGN Act) and applicable state law.

Consent to Electronic Communications

You agree that the Foundation and Corp may deliver agreements, disclosures, notices, and other communications to you electronically, including by email or through the Website, rather than in paper form. This includes, without limitation, the Subscription Agreement, Risk Disclosure, Network Membership Agreement, and any related offering or Network documents.

Consent to Electronic Signatures

You agree that your electronic signature on any agreement with the Foundation or Corp — including through a typed name, click-to-accept mechanism, or other electronic signature method — is legally binding and has the same force and effect as a handwritten signature.

Withdrawing Consent

You may withdraw your consent to electronic communications or signatures by contacting governance@bolton-strid.org, though withdrawal may limit or delay your ability to participate in the Network or complete a securities subscription, which are designed to be conducted electronically.

Hardware and Software Requirements

To access and retain electronic communications, you will need a device with internet access, a current web browser, and the ability to download and store or print PDF documents. If these requirements change in a way that affects your ability to receive communications, we will notify you as required by law.

Intellectual Property and Trademark Notice

Ownership

“Bolton-Strid,” “NMD™,” “NEXAS™,” and associated logos and marks are trademarks or service marks of The Bolton-Strid Foundation Inc. and/or The Bolton-Strid Corporation. All content on the Website, including text, graphics, the Network Overview, and related materials, is owned by or licensed to the Foundation or Corp and is protected by U.S. and international copyright, trademark, and other intellectual property laws, except where otherwise noted.

Permitted Use

You may view, download, and print content from the Website for personal, non-commercial, or informational reference purposes, provided you retain all copyright and trademark notices. No other use — including reproduction, distribution, modification, or commercial use of Website content or the Foundation’s or Corp’s marks — is permitted without prior written consent.

Prohibited Use of Marks

You may not use “Bolton-Strid,” “NMD™,” “NEXAS™,” or any related mark in a way that implies endorsement, sponsorship, or affiliation without express written permission, or in any manner likely to cause confusion among consumers, investors, or Network participants.

Third-Party Content and Trademarks

References to third-party organizations, standards bodies, or data sources (e.g., IMPLAN, AMA, IQVIA, CMS, BLS, FSMB) in our Network Overview and related materials are for identification and citation purposes only and do not imply endorsement by or affiliation with those organizations.

Reporting Infringement

If you believe your intellectual property rights have been infringed by content on the Website, please contact: legal@bolton-strid.org

Accessability Statement

The Bolton-Strid Foundation Inc. and The Bolton-Strid Corporation are committed to ensuring the Website is accessible to all users, including individuals with disabilities.

Standard

We aim to conform to the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA, or such successor standard as may be applicable, to the extent reasonably practicable.

Ongoing Efforts

We periodically review Website content and functionality to identify and address accessibility barriers and welcome feedback from users regarding their experience.

Feedback and Assistance

If you experience difficulty accessing any part of the Website or require this information in an alternative format, please contact us at accessibility@bolton-strid.org, and we will make reasonable efforts to respond and provide assistance.

California Privacy Rights (CCPA/CPRA)

This section supplements our Privacy Policy and applies specifically to California residents, in accordance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).

Categories of Information Collected

We collect the categories of personal information described in our Privacy Policy, which may include identifiers, commercial information, internet or network activity, and professional or organizational information, as applicable to your interaction with the Website or the Network.

No Sale or Sharing of Personal Information

We do not sell or share (as those terms are defined under the CCPA) your personal information to third parties for cross-context behavioral advertising or monetary or other valuable consideration.

Your California Rights

California residents have the right to: know what personal information is collected; request deletion of personal information, subject to legal exceptions; correct inaccurate personal information; and not be discriminated against for exercising these rights.

Exercising Your Rights

To exercise these rights, contact privacy@bolton-strid.org. We may need to verify your identity before processing your request.

Whistleblower and Compliance Reporting Policy

The Bolton-Strid Foundation Inc. and The Bolton-Strid Corporation encourage directors, officers, employees, contractors, and Network participants to report suspected violations of law, governance policy, or ethical standards, including suspected self-dealing, financial misconduct, or violations of this Policy or our Conflict of Interest Policy.

How to Report

Reports may be submitted to: compliance@bolton-strid.org, or, where applicable, directly to a member of the Foundation’s Board of Directors.

Non-Retaliation

The Foundation and Corp prohibit retaliation against any individual who, in good faith, reports a suspected violation or participates in an investigation of such a report.

Confidentiality

Reports will be treated confidentially to the extent possible, consistent with the need to conduct an adequate investigation.

Notice: DMCA / Copyright Complaints

[Flagged as optional — see note below.] If you believe content on the Website infringes a copyright you own, you may submit a notice to legal@bolton-strid.org, including a description of the copyrighted work, the material you believe is infringing, and your contact information. We will respond in accordance with the Digital Millennium Copyright Act, 17 U.S.C. §512, as applicable.