Terms

NEW WORLD OFFERS MARKETING 
Website Terms and Conditions of Use and Program Participation 
Effective Date: June 1, 2026     |     Last Updated: September 18, 2026
 
PLEASE READ THESE TERMS CAREFULLY. These Terms are directed to businesses and business representatives, not to individual consumers seeking a loan or other consumer financial product. 
1.  THE WEBSITE AND THESE TERMS 
1.1 New World Offers Marketing Inc. (“NWOM,” “we,” “us,” or “our”), a company organized under the laws of the Republic of Panama with its principal place of business at Obarrio 54th Street & Samuel Lewis Avenue, Atrium Tower Building Floors 26&27, Panama, Republic of Panama, owns and operates the website located at https://www.newworldoffers.com and any related subdomains, portals, and application interfaces (collectively, the “Website“). 
1.2 These Terms and Conditions of Use and Program Participation (these “Terms”) govern your access to and use of the Website, including any submission of an application to participate in the NWOM publisher, affiliate, or lead purchasing program (the “Program”). 
1.3 By accessing, browsing, registering for an account on, or submitting information through the Website, you agree to be bound by these Terms. If you do not agree to these Terms, do not access or use the Website. 
1.4 We may revise these Terms at any time by posting an updated version to the Website. Revisions take effect upon posting, or on such later date as we specify. Your continued use of the Website after revisions are posted constitutes your acceptance of the revised Terms. We encourage you to review these Terms periodically. The “Last Updated” date above identifies the current version. 
1.5 These Terms are entered into between NWOM and the business entity on whose behalf you act. By accepting these Terms, you represent that you are at least eighteen (18) years of age, that you are acting in a commercial capacity and not as a consumer, and that you are duly authorized to bind that entity. 


2.  DEFINITIONS 
2.1 In these Terms, the following capitalized terms have the meanings given below: 
(a) “Consumer” means an individual who submits, or whose information is submitted through, any marketing asset, landing page, form, or other channel operated or used by a Publisher. 
(b) “Consumer Data” means any information relating to an identified or identifiable Consumer, including personally identifiable information and nonpublic personal information as those terms are defined under applicable law. 
(c) “Lead” means a record of Consumer Data transmitted to, or generated through, NWOM for distribution to a Lead Buyer. 
(d) “Lead Buyer” means a lender, network, agent of record, or other party that receives or purchases Leads from NWOM. 
(e) “Program Agreement” means the separate written agreement, together with any insertion order, statement of work, campaign order, or addendum, executed between NWOM and a Publisher or Lead Buyer governing participation in the Program. 
(f) “Publisher” means any person or entity that generates, collects, or directs Consumer traffic or Consumer Data to NWOM, whether as a click provider, post provider, affiliate, or otherwise. 
(g) “Sub-Affiliate” means any third party engaged, permitted, or used by a Publisher to generate traffic or Consumer Data ultimately delivered to NWOM. 
(h) “You” or “your” means the business entity accessing the Website and each individual acting on its behalf, including any applicant, Publisher, or Lead Buyer. 
3.  NATURE OF THE WEBSITE; NO LENDING ACTIVITY 
3.1 The Website is intended to serve as a business-to-business informational resource and as a portal through which prospective Publishers and Lead Buyers may apply to participate in the Program. 
3.2 NWOM is not a lender. NWOM does not make loans, does not take or process loan applications, does not make credit decisions, does not set or negotiate loan terms, and does not fund, service, or collect on any extension of credit. NWOM is not an agent, representative, or broker of any Consumer. 
3.3 Nothing contained on the Website constitutes an offer to sell or a solicitation of an offer to buy any financial product or instrument, nor does it constitute legal, financial, tax, or compliance advice or a recommendation with respect to any financial product or instrument. 
3.4 Information published on the Website, including any description of the Program, lead categories, verticals, or capabilities, is provided for general informational purposes and may be changed at any time without notice. 


4.  ELIGIBILITY 
4.1 To access the Website and apply to the Program, you must be (i) of legal age to consent to contractual agreements or (ii) a validly formed and, where required, duly licensed or registered business entity in good standing in each jurisdiction in which you conduct the activities contemplated by the Program. 
4.2 You represent and warrant that neither you (as an individual) nor any of your entity’s principals, officers, directors, beneficial owners, or key personnel: (a) appears on any list of sanctioned or restricted parties maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control or any comparable authority; (b) is subject to any outstanding order, injunction, consent order, or assurance of voluntary compliance issued by the Federal Trade Commission, the Consumer Financial Protection Bureau, any state attorney general, or any other governmental authority relating to consumer protection, lending, telemarketing, privacy, or advertising; or (c) is otherwise barred from participating in the activities contemplated by the Program. 
4.3 You must disclose to NWOM any matter described in Section 4.2 that arises, or that you become aware of, at any time, whether before or after your application is submitted. 
4.4 We may decline access to the Website or to the Program to any person or entity, at any time, in our sole discretion and without stating a reason. 


5.  PROGRAM APPLICATION AND ACCOUNT REGISTRATION 
5.1 Submission of an application through the Website is an expression of interest only. Submission of an application does not create any contractual relationship, partnership, joint venture, or Program participation right, and does not obligate NWOM to accept you, to transmit or purchase any Lead, or to make any payment. 
5.2 No Program relationship is formed unless and until (a) NWOM has completed its due diligence and approval process to its satisfaction, and (b) a Program Agreement has been executed by an authorized representative of each party. 
5.3 As part of our onboarding and due diligence process, you may be required to complete a compliance questionnaire, provide government-issued identification for principals, participate in a live video or in-person interview, furnish trade references, provide sample marketing assets and landing pages, and deliver copies of your compliance, privacy, complaint handling, and data security policies. You agree to cooperate in good faith with these requests. 
5.4 You represent and warrant that all information you submit through the Website, including application and questionnaire responses, is true, complete, and accurate, and that you will notify NWOM in writing of any event that would materially change any response within fifteen (15) days of that event. NWOM relies on that information in deciding whether to approve and continue a Program relationship. 
5.5 If you are issued account credentials, you are responsible for maintaining their confidentiality and for all activity occurring under your account, whether or not authorized by you. You must notify us promptly at compliance [at] newworldoffers.com upon becoming aware of any unauthorized access or use. 
5.6 We may suspend, restrict, or terminate your Website access or account at any time, with or without notice, including where we reasonably suspect inaccurate information, non-compliance with these Terms, or conduct that presents legal, regulatory, or reputational risk to NWOM or its partners. 


6.  RELATIONSHIP TO THE PROGRAM AGREEMENT 
6.1 These Terms govern use of the Website and the application process. The Program Agreement governs the substantive commercial and compliance terms of Program participation, including compensation, lead specifications, caps, return and credit policy, and termination. 
6.2 In the event of a conflict between these Terms and an executed Program Agreement with respect to Program participation, the Program Agreement controls. These Terms continue to govern your use of the Website in all respects not addressed by the Program Agreement. 
6.3 NWOM policies referenced in or incorporated into the Program Agreement, including any advertising and marketing policy, prohibited content standards, and data security requirements, apply in addition to these Terms and are incorporated by reference. 


7.  ACCEPTABLE USE OF THE WEBSITE 
7.1 You agree not to, and not to permit any third party to: 
(a) introduce or transmit any virus, worm, malicious code, or other harmful component to or through the Website; 
(b) use any device, script, robot, spider, scraper, or other automated means to access, monitor, index, or copy the Website or any data available through it, except as expressly authorized in writing; 
(c) interfere with, disrupt, probe, or place an unreasonable load on the Website or the servers or networks on which it operates, or attempt to circumvent any security, rate-limiting, or access-control measure; 
(d) disassemble, decompile, decipher, or reverse engineer any software comprising or supporting the Website, except to the extent this restriction is unenforceable under applicable law; 
(e) access the Website using another party’s credentials, or share your credentials with any third party; 
(f) use the Website to transmit unsolicited commercial communications, or for any unlawful, fraudulent, deceptive, or abusive purpose; or 
(g) use the Website to collect, harvest, or derive information about NWOM’s Lead Buyers, Publishers, pricing, or campaign structures for competitive purposes. 
7.2 You are responsible for all use of the Website by any person using your systems, devices, or credentials, and you must ensure that any such person complies with these Terms. 


8.  COMPLIANCE OBLIGATIONS OF APPLICANTS, PUBLISHERS, AND LEAD BUYERS 
8.1 The Program operates in a heavily regulated sector. If you apply to, or participate in, the Program, you represent, warrant, and covenant that you conduct, and will remain in full compliance with all applicable federal, state, tribal, and local laws, rules, and regulations, and with generally accepted industry standards, including without limitation: 
(a) the Federal Trade Commission Act, including Section 5 prohibitions on unfair or deceptive acts or practices, and the prohibition on unfair, deceptive, or abusive acts or practices under the Dodd-Frank Act; 
(b) the Telephone Consumer Protection Act and its implementing regulations, the Telemarketing Sales Rule, and federal and state do-not-call and calling-time requirements; 
(c) the CAN-SPAM Act and applicable state electronic communications and text messaging statutes; 
(d) the Gramm-Leach-Bliley Act, including the Privacy Rule and Safeguards Rule, and the Fair Credit Reporting Act; 
(e) the Truth in Lending Act and Regulation Z, including advertising requirements, and the Equal Credit Opportunity Act and Regulation B; 
(f) the California Consumer Privacy Act as amended by the California Privacy Rights Act, and all other applicable state consumer privacy, data broker registration, and data security laws; and 
(g) all applicable state lead generation, loan broker, credit services organization, telemarketing, and advertising licensing and registration requirements. 
8.2 You further represent, warrant, and covenant that: 
(a) every Lead delivered to NWOM originates from a Consumer who has taken an affirmative, documented action on a disclosed marketing asset, and reflects prior express written consent to be contacted where such consent is required by law; 
(b) you maintain, and will produce to NWOM upon request within a commercially reasonable period, complete consent records for each Lead, including the source URL, the full disclosure and consent language displayed, timestamp, IP address, and the identity of the parties to whom consent was given; 
(c) you do not and will not generate Leads through incentivized traffic, co-registration, pre-checked consent boxes, pre-populated fields, data appends, purchased or aged lists, or any channel in which the Consumer did not knowingly submit the information, except with NWOM’s prior written approval; 
(d) your marketing assets do not state or imply that the Consumer will be matched with the “best” or “lowest cost” lender, that approval or funding is guaranteed, that the Consumer is pre-approved, prequalified, or prescreened absent, that no credit check is performed, or that you are the lender or participate in any credit decision; 
(e) each marketing asset and landing page you operate displays a conspicuous privacy policy, accurate identification of the operator, a clear disclosure that the operator is not a lender, and clear and conspicuous consent language positioned above the submission control; and 
(f) you maintain a functioning mechanism by which Consumers may opt out of, unsubscribe from, or revoke consent to further communications, and you honor such requests promptly and in accordance with applicable law. 
8.3 You are fully responsible for the acts and omissions of your Sub-Affiliates as if they were your own. You will (a) conduct documented due diligence on each Sub-Affiliate before engagement, (b) impose by written agreement obligations no less protective than those in these Terms, (c) monitor Sub-Affiliate marketing assets on an ongoing basis, and (d) disclose Sub-Affiliate participation to NWOM upon request. Undisclosed Sub-Affiliate traffic is grounds for immediate termination. 
8.4 You will notify NWOM in writing as soon as commercially reasonable, and in any event within five (5) business days, upon becoming aware of: any inquiry, subpoena, civil investigative demand, or correspondence from any federal, state, or tribal regulatory authority relating to your marketing or data practices; any litigation or demand alleging violation of the statutes identified in Section 8.1; any actual or suspected data breach or unauthorized disclosure of Consumer Data; or any material change in your corporate structure, ownership, or personnel with access to Consumer Data. 
8.5 NWOM may monitor, review, test, and audit your marketing assets, landing pages, consent records, policies, and compliance practices at any time, no less frequently than annually, and may require corrective action, including written remediation plans with deadlines, suspension of specific assets or channels, or termination. You will cooperate with such monitoring and audit activity. 
8.6 You will retain all records relating to Leads delivered to NWOM, including consent records, for a period of not less than five (5) years from the date of delivery, or such longer period as applicable law requires. 


9.  INTELLECTUAL PROPERTY 
9.1 All copyrights, trademarks, service marks, trade dress, database rights, and other intellectual property rights in the Website and its contents, including all text, graphics, screens, interfaces, compilations, and underlying software and source code, are owned by or licensed to NWOM. 
9.2 Subject to your compliance with these Terms, we grant you a limited, revocable, non-exclusive, non-transferable license to access and view the Website, and to temporarily store or print extracts for your internal business evaluation of the Program. You may not republish, retransmit, redistribute, frame, or make available to any third party any portion of the Website without our prior written consent. 
9.3 No right or license to any NWOM name, mark, or logo is granted by these Terms. Any use of NWOM marks or NWOM-supplied creative assets in your marketing requires prior written approval and is limited to the approved form, placement, and duration; approval may be withdrawn at any time. 
9.4 If you submit ideas, suggestions, or feedback regarding the Website or the Program, you grant NWOM a perpetual, irrevocable, worldwide, royalty-free license to use and exploit that feedback without restriction or compensation. 
9.5 If you believe material available through the Website infringes your copyright, send notice to our designated agent at compliance [at] newworldoffers.com, including the elements required by 17 U.S.C. § 512(c)(3). 


10.  CONFIDENTIALITY 
10.1 Non-public information disclosed to you through the Website or the application process, including Program economics, pricing, Lead Buyer identities, campaign structures, technical specifications, and compliance requirements, is the confidential information of NWOM. 
10.2 You will use such information solely to evaluate or perform under the Program, will protect it using no less than reasonable care, and will not disclose it to any third party except to personnel and advisors with a need to know who are bound by comparable obligations. This Section survives termination of your Website access. 


11.  THIRD-PARTY WEBSITES AND CONTENT 
11.1 The Website may contain links to websites operated by third parties. Those links are provided for convenience only. We do not control, endorse, or assume responsibility for the content, accuracy, availability, privacy practices, or security of any linked site. You should review the terms and privacy policies of any linked site before using it. 
11.2 We make no representation or warranty regarding the accuracy, functionality, security, or performance of any third-party software, platform, tracking system, or integration used in connection with the Website. 
11.3 You may not frame, deep-link, or hot-link to the Website or its content in any manner that misrepresents your relationship with NWOM, implies endorsement, or obscures the source of the content. 


12.  PRIVACY, DATA, AND INTERNATIONAL PROCESSING 
12.1 Our collection and use of information through the Website is described in our Privacy Policy, available at https://newworldoffers.com/privacy-policy-2/, which is incorporated into these Terms by reference. 
12.2 We may collect information about your use of and visits to the Website, including traffic data, device and browser information, weblogs, and other communication data, some of which is collected through cookies and similar technologies. You may configure your browser to restrict cookies, though doing so may impair Website functionality. 
12.3 NWOM is organized in and operates from the Republic of Panama and uses service providers located in the United States and other jurisdictions. By using the Website and submitting information through it, you acknowledge that information you provide will be transferred to, stored in, and processed in Panama, the United States, and other jurisdictions whose data protection laws may differ from those of your jurisdiction. 
12.4 As between you and NWOM, Consumer Data transmitted to NWOM is subject to the terms of the applicable Program Agreement. You are solely responsible for the lawfulness of your collection of Consumer Data and for providing all notices and obtaining all consents required for its disclosure to NWOM and onward disclosure to Lead Buyers and their service providers. 
12.5 You will maintain a written information security program appropriate to the sensitivity of Consumer Data, including access controls, encryption of Consumer Data in transit and at rest, secure disposal procedures, and incident response capability. 
12.6 Messages transmitted over the internet cannot be guaranteed to be secure and may be intercepted, lost, delayed, or altered. We are not responsible for any communication lost, intercepted, or altered by third parties in transit. 


13.  DISCLAIMERS 
13.1 THE WEBSITE AND ALL CONTENT, MATERIALS, AND SERVICES AVAILABLE THROUGH IT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT WARRANTY OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY. NWOM EXPRESSLY DISCLAIMS ALL IMPLIED WARRANTIES, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, ACCURACY, AND NON-INFRINGEMENT. 
13.2 We do not warrant that the Website will be available, uninterrupted, timely, secure, or error-free, that defects will be corrected, that transmitted information will not be lost or delayed, or that the Website or its servers are free of viruses or other harmful components. You are solely responsible for adequate protection and backup of your data and equipment and for taking appropriate precautions to scan for malicious code. 
13.3 NWOM MAKES NO REPRESENTATION OR WARRANTY REGARDING LEAD VOLUME, LEAD QUALITY, ACCEPTANCE RATES, CONVERSION RATES, PAYOUT RATES, OR EARNINGS. ANY FIGURE, PROJECTION, OR HISTORICAL RESULT COMMUNICATED THROUGH THE WEBSITE IS ILLUSTRATIVE ONLY AND IS NOT A PROMISE OR GUARANTEE OF FUTURE RESULTS. 
13.4 Nothing on the Website constitutes legal or compliance advice. You are responsible for obtaining your own counsel regarding your regulatory obligations. NWOM’s review or approval of any marketing asset is for NWOM’s own risk management purposes only, does not constitute a determination of legal compliance, and does not relieve you of any obligation under Section 8.

 
14.  LIMITATION OF LIABILITY 
14.1 TO THE MAXIMUM EXTENT PERMITTED BY LAW, NWOM AND ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOST PROFITS, LOST REVENUE, LOSS OF DATA, LOSS OF GOODWILL, OR BUSINESS INTERRUPTION, ARISING OUT OF OR RELATING TO THE WEBSITE OR THESE TERMS, WHETHER BASED IN CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE, AND WHETHER OR NOT WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. 
14.2 NWOM’S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THE WEBSITE OR THESE TERMS WILL NOT EXCEED THE TOTAL AMOUNTS PAID BY NWOM TO YOU UNDER ANY PROGRAM AGREEMENT DURING THE THREE (3) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM. 
14.3 Your use of the Website and reliance on any information obtained through it is at your own risk. 
14.4 Nothing in these Terms limits or excludes any liability that cannot lawfully be limited or excluded, including liability for fraud or fraudulent misrepresentation. 
14.5 The limitations in this Section apply notwithstanding the failure of the essential purpose of any limited remedy and reflect an agreed allocation of risk between commercially sophisticated parties. 


15.  INDEMNIFICATION 
15.1 You will defend, indemnify, and hold harmless NWOM and its affiliates, and their respective officers, directors, employees, agents, successors, and assigns, from and against any and all claims, demands, actions, investigations, proceedings, losses, liabilities, damages, judgments, settlements, fines, penalties, and expenses, including reasonable attorneys’ fees and costs of investigation, arising out of or relating to: 
(a) your use of or access to the Website; 
(b) your breach of these Terms or of any representation, warranty, or covenant made in them; 
(c) any actual or alleged violation by you or any Sub-Affiliate of any law, rule, or regulation, including the Telephone Consumer Protection Act, the Telemarketing Sales Rule, the CAN-SPAM Act, the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, or any state consumer privacy or lead generation statute; 
(d) any marketing asset, disclosure, consent mechanism, or landing page operated or used by you or any Sub-Affiliate; 
(e) any claim that a Consumer did not consent to contact, or that consent was improperly obtained, documented, or transferred, with respect to any Lead you delivered; 
(f) any actual or alleged unauthorized access to, acquisition of, or disclosure of Consumer Data in your possession or control, or in the possession or control of any Sub-Affiliate; and 
(g) any claim that content supplied by you infringes or misappropriates the intellectual property rights of any third party. 
15.2 NWOM will provide notice of any claim for which it seeks indemnification. NWOM may, at its election and at your expense, assume or participate in the defense and settlement of any such claim using counsel of its choosing. You may not settle any claim in a manner that imposes any obligation or admission on NWOM without NWOM’s prior written consent. 
15.3 This Section survives termination of your Website access and of any Program Agreement. 


16.  SUSPENSION AND TERMINATION 
16.1 We may suspend or terminate your access to the Website, your account, or any pending application at any time, with or without cause and with or without notice. 
16.2 Upon termination, the licenses granted to you under Section 9 immediately terminate, and you must cease all use of NWOM marks and NWOM-supplied materials and, upon request, return or destroy NWOM confidential information in your possession. 
16.3 Sections 2, 3, 8.4 through 8.6, 9.1, 9.4, 10, 12, 13, 14, 15, 17, 18, and 19 survive termination, together with any provision that by its nature is intended to survive. 


17.  ELECTRONIC COMMUNICATIONS AND SIGNATURES 
17.1 You consent to receive communications from NWOM electronically, including by email and by posting to the Website, and agree that such communications satisfy any legal requirement that a communication be in writing. 
17.2 You agree that your electronic acceptance of these Terms, your electronic submission of an application, and your electronic signature on any Program Agreement have the same legal force and effect as a handwritten signature, and you waive any right to assert otherwise under the Electronic Signatures in Global and National Commerce Act, the Uniform Electronic Transactions Act, or any comparable statute. 
17.3 Notices to NWOM under these Terms must be sent to compliance [at] newworldoffers.com and, if requested by NWOM, by courier to the address in Section 1.1. Notices to you may be sent to the email address associated with your account or application. 


18.  GOVERNING LAW AND DISPUTE RESOLUTION 
18.1 These Terms, and any dispute or claim arising out of or relating to them, their subject matter, or their formation, whether in contract, tort, statute, or otherwise, are governed by and construed in accordance with the laws of the State of Delaware, United States of America, without regard to its conflict of laws principles.  
18.2 Except as provided in Section 18.5, any dispute, claim, or controversy arising out of or relating to these Terms or the Website will be resolved by final and binding arbitration administered by the American Arbitration Association under its Commercial Arbitration Rules then in effect. The arbitration will be conducted before a single arbitrator and judgment on the award rendered by the arbitrator may be entered in any court having jurisdiction thereof. 
18.3 YOU AND NWOM EACH AGREE THAT ANY DISPUTE WILL BE BROUGHT IN AN INDIVIDUAL CAPACITY ONLY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING. THE ARBITRATOR HAS NO AUTHORITY TO CONSOLIDATE CLAIMS OR TO PRESIDE OVER ANY CLASS OR REPRESENTATIVE PROCEEDING. If this waiver is found unenforceable as to any claim, that claim will be severed and heard in the courts identified in Section 18.4. 
18.4 For any matter not subject to arbitration, the parties irrevocably submit to the exclusive jurisdiction of the state and federal courts located in the State of Delaware, and waive any objection based on venue or forum non conveniens. EACH PARTY IRREVOCABLY WAIVES ANY RIGHT TO TRIAL BY JURY. 
18.5 Either party may seek temporary or preliminary injunctive relief in any court of competent jurisdiction to protect its intellectual property, confidential information, or data security interests, without waiving the arbitration agreement. 
18.6 Any claim arising out of or relating to these Terms or the Website must be commenced within one (1) year after the cause of action accrues, or it is permanently barred, to the extent permitted by applicable law. 


19.  GENERAL PROVISIONS 
19.1 Independent Parties. Nothing in these Terms creates any partnership, joint venture, agency, franchise, employment, or fiduciary relationship between you and NWOM. Neither party has authority to bind the other or to make any representation on the other’s behalf. 
19.2 Assignment. You may not assign or transfer these Terms, or any right or obligation under them, by operation of law or otherwise, without NWOM’s prior written consent. NWOM may assign these Terms without restriction. Any prohibited assignment is void. 
19.3 Severability. If any provision of these Terms is held invalid, illegal, or unenforceable, that provision will be modified to the minimum extent necessary to make it enforceable, or severed if modification is not possible, and the remaining provisions will continue in full force. 
19.4 No Waiver. No failure or delay by NWOM in exercising any right constitutes a waiver of that right, and no waiver is effective unless in writing and signed by an authorized representative of NWOM. 
19.5 Force Majeure. NWOM is not liable for any failure or delay in performance resulting from causes beyond its reasonable control, including acts of God, natural disaster, war, terrorism, civil unrest, governmental action, labor disturbance, epidemic, utility or telecommunications failure, denial of service attack, or internet or hosting provider outage. 
19.6 Export and Sanctions Compliance. You will comply with all applicable export control, economic sanctions, and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, in connection with your use of the Website and participation in the Program. 
19.7 Entire Agreement. These Terms, together with the Privacy Policy and any executed Program Agreement, constitute the entire agreement between you and NWOM regarding the Website and supersede all prior or contemporaneous understandings on that subject. 
19.8 Language. These Terms are drafted in the English language, which governs in all respects. Any translation is provided for convenience only and has no legal effect. 
19.9 Headings. Headings are for convenience of reference only and do not affect interpretation. 
19.10 Interpretation. These Terms will not be construed against either party as drafter. “Including” means “including without limitation.” 


20.  CONTACT 
Questions regarding these Terms may be directed to: 
New World Offers Marketing 
Attn: Compliance Department 
Obarrio 
54th Street & Samuel Lewis Avenue 
Atrium Tower Building, Floors 26&27 
Panama, Republic of Panama 
Compliance [at] newworldoffers.com