These Terms of Service ("Terms") govern your access to and use of the THULO website, waitlist, beta program, and — once made generally available — the THULO platform (collectively, the "Service") operated by Thulo Inc. ("THULO," "we," "us," or "our"). By accessing or using the Service, you agree to be bound by these Terms. If you do not agree, do not use the Service.
THULO is an analytical and strategy-development software platform. The Service helps users research markets, develop strategy specifications expressed in natural language, simulate those strategies against historical data ("backtesting"), and — where the user elects — connect to third-party brokerage accounts through licensed integration providers to monitor or automate their own strategies subject to the user's own rules and risk limits.
THULO is not:
All output produced by the Service — including AI-generated research, strategy specifications, backtest results, alerts, and notifications — is for informational and analytical purposes only. It does not constitute investment advice and is not tailored to your individual financial situation, objectives, or risk tolerance. You are solely responsible for evaluating whether any analysis or strategy is appropriate for you, and for all decisions made based on it. THULO does not hold customer funds or securities at any time; all assets remain in your account at your broker, under your broker's custody.
Trading and investing in securities, options, futures, foreign exchange, cryptocurrencies, and other financial instruments involve substantial risk of loss, including the possible loss of all capital committed. You can lose more than you invest in certain instruments, particularly those involving leverage. Past performance — including any historical results, simulated results, or backtests displayed through the Service — is not indicative of future results. Hypothetical or simulated performance results have inherent limitations: they are prepared with the benefit of hindsight, do not involve real money, and may not reflect the impact of material economic and market factors on decision-making.
THULO makes no guarantees, representations, or warranties regarding profits, returns, performance, or the absence of losses. You should not commit capital you cannot afford to lose, and you should consult a qualified financial professional before making any investment decision.
To access or use the Service, you must (a) be at least 18 years of age (or the age of majority in your jurisdiction, whichever is greater); (b) have the legal capacity to enter into a binding contract; (c) not be located in, organized under the laws of, or ordinarily resident in any jurisdiction subject to comprehensive U.S., Canadian, U.K., EU, or U.N. sanctions; and (d) not be a person prohibited from receiving services under applicable law. By using the Service, you represent and warrant that you meet these requirements. We may verify eligibility at any time and may suspend or terminate access if we reasonably believe you do not meet them.
When the platform launches, you will be responsible for safeguarding your account credentials, for all activity that occurs under your account, and for promptly notifying us of any unauthorized use. You agree to provide accurate information, to keep it current, and not to impersonate any person or misrepresent your affiliation.
You are solely responsible for all trading and investment decisions, all orders placed, all configurations and risk parameters you set within the Service, and all consequences (financial or otherwise) of those decisions and configurations — including in connection with autonomous or semi-autonomous agent modes you enable. The Service provides tools; how you use them is your responsibility.
You agree not to:
The Service may interoperate with third-party services, including brokers, data providers, and integration partners. Your use of any third-party service is governed by that party's own terms. THULO does not control and is not responsible for third-party services, the accuracy or completeness of third-party data, broker outages, broker execution quality, or the consequences of decisions made by a third party. When you connect a brokerage account, you authorize the relevant integration provider and broker to act on your instructions; THULO never holds, transfers, or has withdrawal access to your funds.
The Service, including all software, text, graphics, models, prompts, designs, and other content (excluding User Content) is owned by Thulo Inc. or its licensors and is protected by intellectual property laws. Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Service for your personal, lawful purposes. All rights not expressly granted are reserved.
You retain ownership of the content and strategy specifications you create using the Service ("User Content"). You grant us a worldwide, royalty-free license to host, store, and process your User Content solely as necessary to operate the Service for you. We will not use your User Content to train AI models — ours or third parties' — and we will not share it with other users except as you explicitly direct (for example, through marketplace publishing features you opt into).
The Service may be offered through free tiers, paid subscriptions, and usage-based credit packs as described on the pricing pages. Fees, billing cycles, and refund terms are presented at the point of purchase. We may change pricing for future billing periods with prior notice. Taxes and surcharges, where applicable, are your responsibility unless we state otherwise.
TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, ACCURACY, OR THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, SECURE, OR FREE OF HARMFUL COMPONENTS. WE MAKE NO WARRANTY OR REPRESENTATION REGARDING ANY TRADING RESULTS, RETURNS, OR PROFITS YOU MAY ACHIEVE OR AVOID. NO ADVICE OR INFORMATION OBTAINED FROM THE SERVICE CREATES ANY WARRANTY NOT EXPRESSLY STATED IN THESE TERMS.
TO THE MAXIMUM EXTENT PERMITTED BY LAW, IN NO EVENT WILL THULO, ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OR TRADING LOSSES — WHETHER ARISING IN CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR ANY OTHER LEGAL THEORY — EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. OUR AGGREGATE LIABILITY FOR ALL CLAIMS ARISING FROM OR RELATING TO THE SERVICE WILL NOT EXCEED THE GREATER OF (A) THE AMOUNT YOU PAID US IN THE TWELVE MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED U.S. DOLLARS ($100). SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES; IN THOSE JURISDICTIONS, OUR LIABILITY IS LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW.
You agree to defend, indemnify, and hold harmless THULO and its affiliates, officers, directors, employees, and agents from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or related to (a) your use of or access to the Service; (b) your User Content; (c) your trading or investment decisions; (d) your violation of these Terms; or (e) your violation of any applicable law or the rights of a third party.
Agreement to Arbitrate. You and THULO agree that any dispute, claim, or controversy arising out of or relating to these Terms or the Service — whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory — will be resolved exclusively through final and binding arbitration, rather than in court, except that you may assert claims in small-claims court if your claims qualify.
Arbitration Forum and Rules. The arbitration will be administered by the American Arbitration Association ("AAA") under its Consumer Arbitration Rules (or, if applicable, its Commercial Arbitration Rules), as modified by these Terms. The arbitration will be conducted by a single arbitrator. The seat and legal place of arbitration will be San Juan, Puerto Rico. The arbitration may be conducted in person, by documents, by telephone, or by video, as the arbitrator determines. The arbitrator's award will be final and binding and may be entered as a judgment in any court of competent jurisdiction.
Class-Action Waiver. YOU AND THULO AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING. The arbitrator may not consolidate more than one person's claims and may not preside over any form of representative or class proceeding. If this class-action waiver is found to be unenforceable, then the entirety of this arbitration provision will be null and void as to the affected claim only, and that claim will proceed in court.
Opt-Out. You may opt out of this arbitration agreement by sending written notice to [email protected] within 30 days of first accepting these Terms. Your notice must include your name, the email address associated with your account, and a clear statement that you wish to opt out of arbitration. Opting out will not affect any other part of these Terms.
Governing Law. These Terms are governed by the laws of the Commonwealth of Puerto Rico and applicable U.S. federal law (including the Federal Arbitration Act), without regard to conflict-of-laws principles.
You may stop using the Service at any time. We may suspend or terminate your access at any time, with or without notice, for any reason — including if we reasonably believe you have violated these Terms, created risk for us or other users, or used the Service in a way that could expose us to legal liability. Sections that by their nature should survive termination (including Risk Disclosure, Intellectual Property, Disclaimers, Limitation of Liability, Indemnification, Arbitration, and these miscellaneous provisions) will survive.
We may modify, suspend, or discontinue any part of the Service at any time. We may also modify these Terms from time to time. When we make material changes, we will update the "Last Updated" date and provide reasonable notice — by posting the updated Terms here and, where appropriate, by email or in-product notice. Your continued use of the Service after the effective date of the updated Terms constitutes your acceptance of them. If you do not agree to the updated Terms, you must stop using the Service.
These Terms, together with the Privacy Policy and any other policies referenced here, constitute the entire agreement between you and THULO regarding the Service and supersede all prior or contemporaneous agreements on the same subject. If any provision is found unenforceable, the remaining provisions will remain in full force. Our failure to enforce any right or provision is not a waiver of that right or provision. You may not assign or transfer these Terms without our prior written consent; we may assign these Terms freely. The headings in these Terms are for convenience only and do not affect interpretation.
For legal notices, questions about these Terms, or to provide opt-out notice as described above: