LEGAL

Terms of Service

Last updated: 23 September 2026 · Version 2026-09-23

1. Who we are and what Alfafolio is

Alfafolio (the “Service”) is an information platform available at alfafolio.com and operated by Alfafolio.com, registered in the European Union (“Alfafolio”, “we”, “us”). The Service aggregates publicly available data — including quarterly Form 13F filings published by the U.S. Securities and Exchange Commission (SEC EDGAR) and public market data — and presents it as dashboards, screens, rankings and analytics for informational and educational purposes.

Alfafolio is not an investment adviser, broker-dealer or financial institution. Nothing on the Service is investment advice, a recommendation, or an offer or solicitation to buy or sell any security. The Investment Disclaimer forms part of these Terms.

2. Acceptance and changes

By accessing the Service or creating an account, you agree to these Terms of Service (the “Terms”), the Privacy Policy, the Cookie & Local Storage Policy and the Investment Disclaimer. If you do not agree, do not use the Service. We may update these documents from time to time; we will announce material changes in the app, update the date above, and record the version you accepted with your account. Continuing to use the Service after a change takes effect means you accept the updated Terms.

3. Eligibility and accounts

• You must be at least 18 years old to use the Service or create an account. • You are responsible for keeping your credentials confidential and for all activity under your account. • You must provide accurate information and notify us promptly of any unauthorised use of your account. • We may suspend or terminate accounts that violate these Terms or applicable law. • You may delete your account at any time; the Privacy Policy explains what happens to your data.

4. Acceptable use

You agree not to: • scrape, bulk-download or resell the Service’s data or derived metrics without our prior written consent; • attempt to disrupt, probe, overload or gain unauthorised access to the Service, its infrastructure or other users’ data; • use the Service for any unlawful purpose, including market manipulation or insider dealing.

5. Content and intellectual property

Underlying filing data comes from public sources and remains public. The Service’s selection and arrangement of that data, its derived metrics (such as consensus trends and specialist classifications), and its design and software are our intellectual property or that of our licensors. Watchlists, portfolios, notes and other content you create remain yours; you grant us a limited licence to store, process and display that content to you so we can provide the Service.

6. Third-party advertising and links

The Service displays advertising served by Google and its partners and may link to third-party websites. We do not control or endorse third-party ads, sites or offers, and any dealings you have with them are solely between you and that third party. The Privacy Policy explains how advertising cookies work and how to manage your choices.

7. No warranty

The Service and all data are provided “as is” and “as available”, without warranty of any kind, including as to accuracy, completeness, timeliness, merchantability or fitness for a particular purpose. Public filings may contain errors made by the filer, derived metrics are calculations rather than facts, and coverage is partial by nature (see the Investment Disclaimer).

8. Limitation of liability

To the maximum extent permitted by law, we are not liable for any indirect, incidental, special or consequential damages, or for any loss of profits, capital or data, arising from your use of — or inability to use — the Service, including decisions made in reliance on information shown. Nothing in these Terms excludes or limits liability that cannot be excluded or limited by law, including, where applicable, liability for intent or gross negligence, or affects your statutory rights as a consumer.

9. Suspension and termination

You may stop using the Service at any time. We may suspend or discontinue the Service or any feature, giving reasonable notice where practicable. Sections 5, 7, 8 and 10 continue to apply after termination.

10. Governing law and disputes

These Terms are governed by the laws of the EU member state in which the operator of the Service is registered, without prejudice to the mandatory consumer-protection rules of your country of residence. If you are a consumer, you may also bring proceedings in the courts of the country where you live. Before starting formal proceedings, please contact us so we can try to resolve the matter informally.

11. Contact

Questions about these Terms: info@alfafolio.com.