Terms of Service

Acceptance of Terms

These Terms of Service ("Terms", "Agreement") constitute a legally binding contract between you ("User", "you", "your") and Pingr ("Pingr", "we", "us", "our", "the Company") governing your access to and use of the Pingr platform, website, application, APIs, data feeds, alerts, and all related services (collectively, the "Service").

By creating an account, subscribing to any tier, clicking "I Agree," or otherwise accessing or using any part of the Service, you acknowledge that you have read, understood, and agree to be bound by these Terms in their entirety, including all policies incorporated herein by reference.

If you do not agree to these Terms, you must immediately discontinue all use of the Service and delete your account.

These Terms apply to all visitors, registered users, free-tier members, paid subscribers, and any other person who accesses or interacts with the Service in any manner.

If you are using the Service on behalf of an organisation, company, or other legal entity, you represent and warrant that you have the authority to bind that entity to these Terms, and all references to "you" shall include both you individually and that entity.

Definitions

For the purposes of these Terms, the following definitions apply:

• "Service" — The Pingr platform including the website, dashboard, mobile interface, API endpoints, email alerts, data feeds, Signal Room, Golden Vault simulator, and all related tools and features.
• "Signal" or "Trade Signal" — A data point or aggregation of data points derived from publicly available SEC Form 4 filings, processed and scored by Pingr's proprietary algorithm.
• "Score" or "Signal Score" — A numerical value between 0 and 100 generated by Pingr's algorithmic conviction engine. Scores are informational only and do not constitute recommendations.
• "Golden Trade" — A Signal that achieves a Score of 90 or above and meets certain additional algorithmic criteria. The term is a proprietary Pingr classification label and carries no guarantee of performance.
• "Shadow Vault" or "Golden Vault" — An autonomous paper trading simulation operated by Pingr using Alpaca's paper trading infrastructure. All positions are simulated using paper money with no real capital at risk.
• "SEC" — The United States Securities and Exchange Commission.
• "Form 4" — A document filed with the SEC by corporate officers, directors, and principal shareholders to disclose changes in their ownership of company securities, as required under Section 16(a) of the Securities Exchange Act of 1934.
• "Content" — All text, data, graphics, images, scores, signals, AI-generated summaries, analysis, and other materials provided through the Service.
• "User Content" — Any content submitted, posted, or transmitted by users including comments, watchlist data, and preferences.
• "Subscription" — A paid recurring access arrangement to certain premium features of the Service.
• "Free Tier" — The no-cost access level with limited features and delayed data.
• "Pro Tier" — The paid subscription level providing real-time data and expanded features at the applicable monthly or annual rate.
• "Investor Tier" — The highest paid subscription level providing full access including Golden Trade signals and Shadow Vault data.

Not Financial Advice — Critical Disclaimer

Pingr is a data aggregation and intelligence platform. We process and present publicly available regulatory filings in a structured, scored, and annotated format. We are not, and do not hold ourselves out to be, any of the following:

• A registered investment advisor (RIA) under the Investment Advisers Act of 1940
• A broker-dealer registered with FINRA or any other regulatory body
• A licensed financial planner, analyst, or advisor of any kind
• A fund manager, portfolio manager, or asset manager
• A securities exchange, alternative trading system, or market operator

Nothing on the Pingr platform — including but not limited to Signal Scores, Golden Trade classifications, AI-generated summaries, Shadow Vault performance data, alert notifications, educational content, blog posts, social features, comments, or any other output — constitutes, or should be construed as:

• A recommendation to buy, sell, hold, or otherwise transact in any security
• Financial, investment, tax, legal, or accounting advice of any kind
• A prediction or guarantee of future security performance
• An endorsement of any company, security, or investment strategy
• A solicitation or offer to buy or sell any security or financial instrument

Past performance of any signal, trade pattern, or strategy referenced on Pingr does not guarantee, predict, or imply future results. All investment involves risk of loss, including possible loss of principal. You should consult a qualified financial professional before making any investment decision.

The Shadow Vault simulator uses paper money only and simulated performance does not represent actual investment returns. Simulated results are inherently subject to survivorship bias and do not account for real-world factors including liquidity, slippage, transaction costs, taxes, and market impact.

Use of "Insider" Terminology — Important Clarification

The term "insider" as used throughout the Pingr platform, including in Signal descriptions, alert notifications, AI-generated summaries, marketing materials, and all other communications, refers exclusively to individuals who occupy positions of corporate authority and who are subject to mandatory reporting requirements under Section 16(a) of the Securities Exchange Act of 1934.

Specifically, "insider" on Pingr refers to:

• Corporate officers (including Chief Executive Officers, Chief Financial Officers, Chief Operating Officers, Presidents, Vice Presidents, and other executive officers)
• Members of a company's board of directors
• Principal shareholders owning more than 10% of a class of registered equity securities
• Any other person required to file beneficial ownership reports with the SEC under applicable securities law

Pingr does not allege, suggest, imply, or infer that any individual referenced in our platform has engaged in, or is suspected of engaging in, any illegal insider trading, market manipulation, securities fraud, or any other unlawful activity. All transactions displayed on Pingr are derived from publicly filed SEC disclosures and represent legal, reported transactions.

Legitimate insider buying — where a corporate officer purchases shares of their own company on the open market and discloses that purchase to the SEC — is entirely legal, commonplace, and widely studied in academic finance literature. Pingr's platform is built on analysis of these lawful, publicly disclosed transactions.

The analytical value Pingr provides derives from the informational content of legally disclosed transactions by individuals with deep knowledge of their own companies — not from any unlawful, undisclosed, or confidential information.

If you are a corporate officer, director, or shareholder referenced in Pingr's platform and believe any information displayed is inaccurate, please contact us at [email protected] and we will promptly review your concern.

Data Sources & Accuracy

All trade data displayed on Pingr is derived from SEC EDGAR — the Electronic Data Gathering, Analysis, and Retrieval system operated by the United States Securities and Exchange Commission. EDGAR data is publicly available at no charge and is not proprietary to Pingr.

While Pingr makes reasonable efforts to accurately parse, process, and present SEC filing data, we make no representations or warranties that:

• The data is complete, accurate, current, or error-free
• Any particular filing has been correctly parsed or interpreted
• Signal Scores accurately reflect any underlying quality or predictive value
• The Service will be available without interruption or delay
• Data processing latency meets any particular standard

SEC filing data may contain errors, omissions, or amendments. Pingr's algorithmic processing introduces additional opportunities for data interpretation errors. You acknowledge that you independently verify any information from Pingr before relying on it for any purpose.

AI-generated summaries provided for each Signal are produced by large language model systems and are subject to the inherent limitations and potential inaccuracies of such systems. AI summaries are for informational and entertainment purposes only and do not constitute analysis by a licensed financial professional.

Pingr is not responsible for errors in the underlying SEC filings or for SEC system outages that affect our data ingestion. Signal data is processed on a best-effort basis and real-time delivery is not guaranteed.

Eligibility

To use the Service you must:

• Be at least 18 years of age, or the age of majority in your jurisdiction, whichever is greater
• Have the legal capacity to enter into binding contracts under applicable law
• Not be prohibited from receiving or using the Service under any applicable law or regulation
• Not be located in, or a national or resident of, any jurisdiction where use of the Service would be prohibited by applicable law
• Not be subject to any U.S. government sanctions or on any U.S. government restricted party list

By using the Service you represent and warrant that you meet all eligibility requirements. Pingr reserves the right to verify eligibility at any time and to terminate accounts that do not meet these requirements.

The Service is intended for informational and educational purposes for sophisticated individuals who understand the risks of financial markets. Pingr does not solicit use of the Service by persons who lack such understanding.

User Accounts

To access most features of the Service you must register for an account. By registering you agree to:

• Provide accurate, complete, and current registration information
• Maintain the accuracy of your registration information and update it promptly when it changes
• Keep your password confidential and not share it with any third party
• Be solely responsible for all activity that occurs under your account
• Notify Pingr immediately of any unauthorised access to or use of your account
• Not create more than one account per person
• Not create an account using a false identity or on behalf of someone other than yourself without authorisation

Pingr reserves the right to refuse registration, terminate accounts, or remove usernames at its sole discretion, including for usernames that are offensive, impersonating, or otherwise in violation of these Terms.

You are responsible for all charges incurred through your account. If you believe an unauthorised charge has been made, contact us immediately at [email protected].

Accounts are non-transferable. You may not sell, trade, or otherwise transfer your account to another person.

Subscriptions & Billing

Subscription Plans

Pingr offers Free, Pro, and Investor subscription tiers. Paid subscriptions are billed on a monthly or annual basis at the rates published at the time of subscription. All prices are in United States Dollars (USD) unless otherwise stated.

Billing & Renewal

Paid subscriptions automatically renew at the end of each billing period unless cancelled before the renewal date. By subscribing you authorise Pingr to charge your payment method on a recurring basis for the applicable subscription fee plus any applicable taxes.

Price Changes

Pingr may change subscription prices at any time. We will provide at least 30 days' notice of any price increase via email to the address associated with your account. Continued use of the Service after a price change takes effect constitutes acceptance of the new price.

Cancellation

You may cancel your subscription at any time through your account dashboard. Cancellation takes effect at the end of the current billing period. You will retain access to paid features until that date. Pingr does not provide prorated refunds for partial billing periods except where required by applicable law.

Refunds

All subscription fees are non-refundable except where required by applicable consumer protection law. If you believe you are entitled to a refund, contact us at [email protected] within 7 days of the charge in question.

Failed Payments

If a payment fails, Pingr may suspend or downgrade your account to the Free tier. We will attempt to notify you via email. You are responsible for ensuring your payment method remains valid.

Taxes

Subscription prices may be subject to sales tax, VAT, GST, or other applicable taxes depending on your location. You are responsible for all applicable taxes. Pingr will collect taxes where required by law.

Free Tier

The Free tier provides limited access to the Service at no charge. Free tier access includes delayed trade data (typically 8–12 hours after filing), basic signal scoring, and access to the weekly Ping of the Week signal.

Pingr reserves the right to modify, restrict, or discontinue Free tier features at any time without notice. The availability of a Free tier does not create any obligation for Pingr to continue offering free access in perpetuity.

Free tier users are subject to all provisions of these Terms equally with paid subscribers.

Acceptable Use Policy

You agree to use the Service only for lawful purposes and in accordance with these Terms. You agree not to use the Service:

• In any manner that violates any applicable federal, state, local, or international law or regulation
• To transmit any unsolicited or unauthorised advertising, promotional materials, spam, or any other form of solicitation
• To impersonate any person or entity, or falsely represent your affiliation with any person or entity
• To engage in any conduct that restricts or inhibits anyone's use or enjoyment of the Service
• To attempt to gain unauthorised access to any part of the Service, server, database, or network connected to the Service
• To introduce any viruses, trojan horses, worms, or other malicious or harmful code
• To harvest, scrape, or collect any data from the Service using automated means without our express written permission
• To use the Service to develop a competing product or service
• To redistribute, resell, or commercially exploit any data or Content from the Service without our prior written consent
• To reverse engineer, decompile, or disassemble any software component of the Service
• To bypass or circumvent any access controls, rate limits, or security measures
• To engage in actual insider trading, market manipulation, or any other securities law violation using information from the Service

Violation of this Acceptable Use Policy may result in immediate account termination and, where applicable, referral to appropriate law enforcement or regulatory authorities.

Intellectual Property

The Service and its original Content — excluding SEC filing data which is public domain — including but not limited to the Signal scoring algorithm, conviction engine methodology, Golden Trade classification logic, Shadow Vault simulation architecture, AI synthesis prompting and output formatting, visual design, user interface, software code, trademarks, service marks, logos, and all other proprietary elements, are and shall remain the exclusive property of Pingr and its licensors.

The Pingr name, logo, and all related names, logos, product and service names, designs, and slogans are trademarks of Pingr. You must not use such marks without our prior written permission.

You are granted a limited, non-exclusive, non-transferable, revocable licence to access and use the Service for your personal, non-commercial purposes in accordance with these Terms. This licence does not include the right to:

• Reproduce, duplicate, copy, or sell any part of the Service
• Access the Service to build a competing or similar service
• Use any data mining, robots, or similar data gathering or extraction methods
• Download or copy account information for the benefit of any third party

By submitting User Content to the Service (including comments, feedback, or suggestions), you grant Pingr a worldwide, royalty-free, perpetual, irrevocable licence to use, reproduce, modify, and display such content in connection with operating and improving the Service.

Privacy & Data

Your use of the Service is subject to Pingr's Privacy Policy, which is incorporated into these Terms by reference. By using the Service you consent to the collection, use, and sharing of your information as described in the Privacy Policy.

Pingr collects certain personal data necessary to operate the Service, including account information, usage analytics, and subscription data. We do not sell your personal data to third parties.

We use industry-standard security measures to protect your data, including encrypted storage of sensitive credentials (such as linked brokerage API keys). However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

You have the right to request deletion of your account and associated personal data at any time by contacting [email protected]. Certain data may be retained where required by law or for legitimate business purposes including fraud prevention.

The Service uses cookies and similar tracking technologies. By using the Service you consent to our use of cookies in accordance with our Cookie Policy.

Third-Party Services

The Service integrates with or relies upon certain third-party services including but not limited to:

• U.S. Securities and Exchange Commission (EDGAR) — source of all regulatory filing data
• OpenAI — provider of AI language model capabilities used for generating trade summaries
• Alpaca Markets — provider of paper trading simulation infrastructure
• Brevo (formerly Sendinblue) — provider of email delivery services
• Vercel — provider of frontend hosting infrastructure
• Render — provider of backend hosting infrastructure
• Stripe — provider of payment processing services

Pingr is not responsible for the availability, accuracy, content, products, or practices of any third-party service. Your use of third-party services is governed by their respective terms and privacy policies.

Third-party service outages or disruptions may affect the availability or accuracy of the Pingr Service. Pingr shall not be liable for any loss or damage arising from such third-party disruptions.

Alpaca Paper Trading Integration

Certain features of the Service, including the Shadow Vault and Investor tier portfolio simulation, use Alpaca Markets' paper trading infrastructure. This integration is subject to the following important limitations:

• Paper money only. All Shadow Vault positions are executed with simulated funds. No real money is invested, traded, or at risk through Pingr's Shadow Vault at any time.
• Simulated performance only. Any performance data shown in the Shadow Vault or Investor tier portfolio views reflects simulated paper trading results and does not represent actual investment returns.
• No real brokerage services. Pingr is not a broker-dealer and does not execute real securities transactions on your behalf under any circumstances.
• User-linked accounts. Where users optionally connect their own Alpaca accounts, Pingr accesses that account solely for display and simulation purposes as authorised by the user. Users are responsible for the security of their own Alpaca credentials.

If you connect your own Alpaca API keys to Pingr, you do so at your own risk. Pingr stores API keys using encryption but cannot guarantee absolute security. You should use paper trading API keys only and never connect live trading credentials to third-party services unless you fully understand and accept the associated risks.

Alpaca Markets operates independently of Pingr. Any issues with Alpaca's services, platform, or API are outside Pingr's control and responsibility.

AI-Generated Content

Pingr uses artificial intelligence language models, currently provided by OpenAI, to generate brief summary texts ("AI Synthesis") for each trade signal. You acknowledge and agree that:

• AI-generated summaries are produced automatically without human review
• AI summaries may contain errors, hallucinations, or inaccurate statements
• AI summaries do not constitute financial analysis performed by a licensed professional
• The same AI summary may appear differently across sessions due to the probabilistic nature of language models
• Pingr makes no warranty regarding the accuracy, completeness, or suitability of any AI-generated content
• You should not rely on AI summaries as the basis for any investment decision

Pingr reserves the right to modify, improve, or change its AI provider at any time without notice.

Disclaimers of Warranty

THE SERVICE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO:

• WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT
• WARRANTIES THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE
• WARRANTIES REGARDING THE ACCURACY, RELIABILITY, COMPLETENESS, OR TIMELINESS OF ANY DATA
• WARRANTIES THAT ANY SIGNAL, SCORE, OR CLASSIFICATION WILL PRODUCE ANY PARTICULAR INVESTMENT RESULT
• WARRANTIES THAT DEFECTS WILL BE CORRECTED

Some jurisdictions do not allow the exclusion of implied warranties. In such jurisdictions, the above exclusions apply to the fullest extent permitted by law.

Pingr does not warrant that the Service will meet your specific requirements, that any particular feature will be available at any given time, or that the Service will be compatible with your hardware or software.

Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL PINGR, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, LICENSORS, OR SERVICE PROVIDERS BE LIABLE FOR ANY:

• INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES
• LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OR BUSINESS OPPORTUNITIES
• INVESTMENT LOSSES OR MISSED INVESTMENT GAINS
• DAMAGES ARISING FROM RELIANCE ON ANY SIGNAL, SCORE, AI SUMMARY, OR OTHER CONTENT
• DAMAGES ARISING FROM INTERRUPTION OR DISCONTINUATION OF THE SERVICE
• DAMAGES ARISING FROM UNAUTHORISED ACCESS TO OR ALTERATION OF YOUR ACCOUNT

WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR ANY OTHER LEGAL THEORY, EVEN IF PINGR HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

IN JURISDICTIONS WHERE LIMITATION OF LIABILITY IS RESTRICTED, PINGR'S LIABILITY SHALL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW. IN NO EVENT SHALL PINGR'S TOTAL LIABILITY TO YOU EXCEED THE GREATER OF: (A) THE AMOUNT YOU PAID TO PINGR IN THE 12 MONTHS PRECEDING THE CLAIM; OR (B) ONE HUNDRED DOLLARS ($100).

Some jurisdictions do not allow the limitation of liability for consequential or incidental damages. In such jurisdictions these limitations apply to the fullest extent permitted by law.

Indemnification

You agree to defend, indemnify, and hold harmless Pingr and its officers, directors, employees, contractors, agents, licensors, service providers, successors, and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys' fees) arising out of or relating to:

• Your violation of these Terms
• Your use of the Service in any manner not expressly authorised by these Terms
• Your violation of any third party's rights, including intellectual property rights
• Any investment decision you make based on information from the Service
• Your violation of any applicable law, regulation, or rule
• Any User Content you submit, post, or transmit through the Service
• Your wilful misconduct, gross negligence, or fraud

Investment Risks Acknowledgement

By using the Service, you explicitly acknowledge and accept the following investment risks:

• Total loss risk. Investing in securities carries the risk of total loss of invested capital. You could lose more than you invest if trading on margin.
• Market volatility. Securities prices can be extremely volatile and unpredictable. Past price movements do not predict future movements.
• Information lag. Even real-time data may not reflect the most current market conditions. Markets move faster than any data system.
• Execution risk. Acting on a signal does not guarantee you will be able to execute a trade at a favourable price. Liquidity, market hours, and broker limitations all affect execution.
• Correlation risk. Corporate insider purchases correlate with but do not cause positive stock performance. Many insider buys result in losses. Academic research describes average outcomes across large datasets and does not predict individual trade outcomes.
• Small company risk. Many signals on Pingr relate to small and micro-cap companies which are subject to significantly higher volatility and liquidity risk than large-cap securities.
• Timing risk. Even if an insider's assessment of their company proves correct, the market may take months or years to reflect that view, during which time you may experience significant drawdowns.
• Tax consequences. Investment decisions have tax implications that vary by jurisdiction, holding period, and individual circumstances. Consult a tax professional.

Regulatory Status — EU, Irish Law & MiFID II

What Pingr Is

Pingr is an algorithmic data processing platform. It applies a fixed, uniform mathematical formula to publicly available regulatory filings published by the United States Securities and Exchange Commission (SEC). The same algorithm is applied identically to every filing processed by the platform. No human editorial judgement is applied to any individual signal. No signal receives special treatment. The output — a numerical conviction score between 1 and 99 — is a data point derived from observable, publicly available information.

Pingr operates in a manner analogous to a financial data calculator. Just as a calculator applies a fixed mathematical operation to numbers you provide and returns a result, Pingr applies a fixed scoring methodology to filing data and returns a score. The calculator manufacturer is not providing financial advice when you use the result of a calculation to make a decision. Neither is Pingr.

A further analogy: credit scoring agencies such as Experian apply algorithmic methodologies to publicly available data to produce numerical outputs. Those outputs are data products, not investment recommendations, and credit agencies are not regulated as investment advisers for producing them. Pingr's conviction scores operate on the same principle.

What Pingr Is Not

Pingr explicitly is not, and does not hold itself out to be, any of the following:

• An investment firm as defined under MiFID II (Directive 2014/65/EU)
• A provider of personalised investment advice under MiFID II Article 4(1)(4)
• A portfolio manager exercising discretionary management under MiFID II Article 4(1)(8)
• An investment research producer under ESMA guidelines on investment recommendations
• A regulated financial analyst or licensed investment adviser under any applicable law
• A broker-dealer, custodian, or entity that holds, manages, or has any interest in user funds

MiFID II Position

Under Directive 2014/65/EU (MiFID II) as implemented in Ireland by the European Union (Markets in Financial Instruments) Regulations 2017 (S.I. No. 375 of 2017), the provision of personalised investment advice to retail clients requires authorisation from the Central Bank of Ireland. Pingr does not provide personalised investment advice.

Pingr's scoring methodology is not personalised. It does not take into account any individual user's financial situation, investment objectives, risk tolerance, existing portfolio, tax position, or any other personal circumstances. The identical numerical output would be generated regardless of who is viewing it. This is a fundamental structural characteristic of the platform, not a disclaimer.

Pingr's outputs are general data outputs derived from public regulatory filings. They are not recommendations directed at any specific person. The distinction between general information and personalised investment advice is recognised under MiFID II and Pingr's model falls clearly within the former category.

MAR Article 20 — Investment Recommendations

Under EU Market Abuse Regulation 596/2014 (MAR) Article 20, persons who produce or disseminate investment recommendations must comply with ESMA guidelines on fair presentation and conflict of interest disclosure. To the extent that any output of Pingr's platform could be characterised as an investment recommendation under MAR Article 20, Pingr makes the following disclosures:

• Identity: Pingr is operated by an individual founder based in Ireland.
• Methodology basis: Conviction scores are derived from a fixed algorithmic methodology applied to publicly available SEC Form 4 filings. The methodology is informed by peer-reviewed academic research including Jeng, Metrick & Zeckhauser (Wharton, 2003), Wang, Shin & Francis (2012), and Kang, Kim & Wang (2018).
• Conflicts of interest: Pingr has no financial interest in any security it scores. Pingr does not receive compensation from any company, insider, or third party in connection with any signal it produces. Pingr does not trade in securities it scores ahead of publication.
• Fair presentation: The platform's live track record, including all losses and underperforming signals, is publicly displayed at all times. No signals are retrospectively removed or hidden.
• Risk warning: Past scoring performance does not guarantee future results. All investment carries risk of loss.

No Discretionary Management

Pingr does not exercise any discretion over user assets or portfolios. The term "discretion" in portfolio management regulation refers to an arrangement where a manager makes investment decisions on behalf of a client according to the manager's own judgement. Pingr makes no such decisions. The algorithm is fixed, transparent, and applies identically to all filings. There is no adaptive or personalised judgement applied to any user's situation. Users make all investment decisions independently.

Shadow Vault — Internal Demonstration Only

Pingr operates an internal algorithmic demonstration portfolio (the "Shadow Vault") using Alpaca's paper trading infrastructure. This portfolio uses simulated capital only. No real money is involved at any time. No user funds are connected to, invested in, or at risk in connection with the Shadow Vault. The Shadow Vault is operated entirely by Pingr as a demonstration of how the conviction scoring algorithm would perform if applied to paper trading decisions. Users observe the Shadow Vault's performance as a data display. Users do not participate in the Shadow Vault financially in any way. The Shadow Vault does not constitute portfolio management of user assets.

Third-Party Broker Connections

Where the Service offers optional connectivity to third-party paper trading accounts (such as Alpaca paper trading), the following applies without exception:

• Any such connection is initiated entirely at the user's own election
• Connectivity is restricted to paper trading accounts involving no real money
• The user creates, owns, and controls their own third-party account independently of Pingr
• Pingr acts solely as an authorised API client executing instructions on the user's own account pursuant to the user's explicit prior consent
• The third-party broker (Alpaca) holds all applicable regulatory licences governing the account
• Pingr does not receive, hold, touch, or have any financial interest in any funds in connected accounts
• Connectivity to live funded brokerage accounts involving real money is not permitted

This architecture is structurally analogous to automation tools such as IFTTT or Zapier, which act as authorised API clients on user-owned accounts without themselves being regulated as financial services providers. Pingr is an automation layer, not a financial services provider, in relation to any third-party account connectivity.

GDPR & Irish Data Protection

Pingr collects and processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Irish Data Protection Act 2018. Pingr is the data controller in respect of personal data collected from users. Users have rights including access, rectification, erasure, portability, and objection. To exercise data rights contact [email protected]. Full details are in the Privacy Policy.

Jurisdictional Responsibility

Securities laws and financial data regulations vary by jurisdiction. It is your sole responsibility to ensure your use of Pingr complies with the laws applicable to you. If you access Pingr from outside Ireland or the EU, you do so on your own initiative and are responsible for local compliance. Pingr does not represent that the Service is appropriate or permitted in all jurisdictions.

Prohibited Activities — Securities Law

The following activities are strictly prohibited in connection with the Service and may constitute violations of applicable securities laws:

• Actual insider trading. Using material non-public information — whether or not obtained through Pingr — to trade securities is illegal. All information accessible through Pingr is sourced from public SEC filings.
• Market manipulation. Using information from Pingr to coordinate trading activity intended to artificially influence the price of any security is strictly prohibited.
• Front-running. Using advance knowledge of pending institutional orders or coordinated trading strategies to trade ahead of others is prohibited.
• Pump and dump schemes. Using information from Pingr to promote securities in which you have a financial interest without appropriate disclosure is prohibited.
• Signal sharing for commercial gain. Redistributing Pingr's signals, scores, or data to others for commercial purposes without a commercial licence from Pingr is prohibited.

You represent and warrant that you will not use the Service in connection with any activity that violates any applicable securities law, including the Securities Exchange Act of 1934, the Securities Act of 1933, the Investment Advisers Act of 1940, or any equivalent law in your jurisdiction.

Termination

Pingr may suspend, restrict, or terminate your access to the Service at any time, with or without notice, for any reason, including but not limited to:

• Violation of these Terms or any applicable law
• Non-payment of subscription fees
• Fraudulent or abusive behaviour
• Conduct harmful to Pingr or other users
• Extended inactivity
• Cessation of the Service

Upon termination you must immediately cease all use of the Service. All provisions of these Terms which by their nature should survive termination — including intellectual property provisions, disclaimers, indemnification, and limitations of liability — shall survive termination.

You may terminate your account at any time by requesting deletion through your account settings or by contacting support. Termination does not entitle you to a refund of any prepaid subscription fees.

Modifications to Service & Terms

Pingr reserves the right to modify, suspend, or discontinue any aspect of the Service at any time without notice or liability. This includes adding or removing features, changing pricing, altering data sources, or ceasing operation entirely.

Pingr may modify these Terms at any time by posting the revised Terms on this page with an updated effective date. For material changes, we will provide notice via email or a prominent in-app notification at least 14 days before the changes take effect.

Your continued use of the Service after the effective date of any modification constitutes your acceptance of the modified Terms. If you do not agree to the modified Terms, you must stop using the Service and may cancel your subscription.

It is your responsibility to review these Terms periodically. We encourage you to bookmark this page and check it regularly.

Dispute Resolution

Informal Resolution

Before initiating any formal dispute resolution, you agree to first contact Pingr at [email protected] and provide a written description of the dispute and the relief sought. We will attempt to resolve the dispute informally within 30 days.

Binding Arbitration

If informal resolution fails, any dispute, claim, or controversy arising out of or relating to these Terms or the Service shall be resolved by binding arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, rather than in court. The arbitration shall be conducted in the English language.

Class Action Waiver

YOU AND PINGR AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. No arbitration or proceeding shall be combined with another without the prior written consent of all parties.

Exceptions

Notwithstanding the above, either party may seek injunctive or other equitable relief in any court of competent jurisdiction to prevent the actual or threatened misappropriation of intellectual property or breach of confidentiality obligations.

Small Claims

Either party may bring an individual action in small claims court if the dispute qualifies.

Governing Law & Jurisdiction

Pingr is operated by an individual based in Ireland and is subject to Irish law and, where applicable, European Union law. These Terms shall be governed by and construed in accordance with the laws of Ireland, without regard to conflict of law principles.

For EU/EEA users, nothing in these Terms shall deprive you of any mandatory consumer protection rights afforded to you under the laws of your country of residence. Where EU consumer law provides rights that cannot be contractually excluded, those rights remain fully intact and are not waived by these Terms.

For disputes not resolved under Section 24, you agree to submit to the non-exclusive jurisdiction of the courts of Ireland. Users in other jurisdictions may also have the right to bring proceedings in their local courts where mandatory law so requires.

Pingr processes publicly available data from the US SEC EDGAR system. The data source is US-based but the operator and platform are Irish. Users are responsible for compliance with laws in their own jurisdiction regarding access to financial data and any resulting investment decisions.

Entire Agreement & Miscellaneous

Entire Agreement

These Terms, together with the Privacy Policy and any other policies incorporated herein by reference, constitute the entire agreement between you and Pingr with respect to the Service and supersede all prior agreements, understandings, negotiations, and discussions, whether oral or written.

Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it enforceable.

Waiver

Pingr's failure to enforce any right or provision of these Terms shall not be deemed a waiver of such right or provision. Any waiver must be in writing and signed by an authorised representative of Pingr.

Assignment

You may not assign or transfer these Terms or your rights under them without Pingr's prior written consent. Pingr may assign these Terms freely, including in connection with a merger, acquisition, or sale of assets, with notice to you.

Force Majeure

Pingr shall not be liable for any failure or delay in performance resulting from circumstances beyond its reasonable control, including acts of God, natural disasters, pandemics, government actions, cyberattacks, third-party service outages, or other force majeure events.

No Third-Party Beneficiaries

These Terms do not create any third-party beneficiary rights. No person other than you and Pingr shall have any right to enforce any provision of these Terms.

Language

These Terms are written in English. Any translation is provided for convenience only. In the event of any conflict between the English version and any translation, the English version shall prevail.

Electronic Communications

By using the Service and providing your email address, you consent to receive electronic communications from Pingr, including service-related notices and, if applicable, marketing communications. You may opt out of marketing communications at any time.

Contact Information

If you have questions, concerns, or complaints about these Terms or the Service, please contact us:

We aim to respond to all legal enquiries within 5 business days. For urgent matters please indicate "URGENT" in the subject line of your email.

These Terms of Service were last updated on April 5, 2026. Previous versions are available on request.

EU Consumer Rights

If you are a consumer located in the European Union or European Economic Area, you have certain statutory rights that these Terms cannot override. These include rights under:

• The EU Consumer Rights Directive (2011/83/EU) — including the right to clear information before entering a subscription contract
• The EU Unfair Contract Terms Directive (93/13/EEC) — protecting against unfair terms in consumer contracts
• GDPR (EU) 2016/679 — including rights of access, erasure, portability, and objection
• The EU Digital Services Act (2022/2065) where applicable
• Any mandatory consumer protection laws applicable in your country of residence

Nothing in these Terms shall be interpreted to waive, limit, or exclude any right you have under mandatory EU consumer protection law. Where any provision of these Terms conflicts with mandatory EU consumer law, the mandatory EU consumer law provision prevails.

Right of Withdrawal

EU consumers who subscribe to a paid Pingr plan have a 14-day right of withdrawal from the date of subscription under the Consumer Rights Directive, unless you have expressly consented to the service beginning immediately and acknowledged that the right of withdrawal is lost upon commencement. By subscribing and accessing paid features immediately, you expressly request immediate commencement of the service and acknowledge that your right of withdrawal is thereby waived in respect of any consumed digital content.

Online Dispute Resolution

The European Commission provides an Online Dispute Resolution (ODR) platform for resolving disputes with online traders: https://ec.europa.eu/consumers/odr. Pingr's contact email for ODR purposes is [email protected].

Nature of Conviction Scores — Technical Disclosure

This section provides a technical description of Pingr's conviction scoring methodology for regulatory transparency purposes.

What a Conviction Score Is

A Pingr conviction score is a numerical output produced by applying a fixed mathematical formula to a set of observable, publicly available data points extracted from an SEC Form 4 filing. The score is a measure of the relative strength of observable signals in the filing according to Pingr's proprietary weighting model. It is not a prediction of future stock price performance. It is not a recommendation. It is not an opinion on the merits of any investment. It is a number produced by a calculation.

Inputs to the Score

The conviction score is derived exclusively from the following observable data points contained within or derivable from the relevant SEC Form 4 filing and publicly available market data:

• The filer's corporate role (e.g. Chief Financial Officer, Director, Vice President)
• The total value of the purchase transaction in US dollars
• The percentage increase in the filer's ownership stake resulting from the transaction
• Whether the transaction represents a new position (no prior ownership)
• The number of days elapsed between the transaction date and the filing date
• The current stock price relative to its 52-week high
• The number of distinct insiders who have purchased the same security within a defined time window
• Whether the transaction is designated as a pre-planned 10b5-1 programme trade
• Whether the filing contains derivative instrument transactions

What the Score Does Not Include

The conviction score does not incorporate any of the following:

• Any non-public information of any kind
• Any information about the user viewing the score
• Any human editorial judgement or opinion
• Any proprietary third-party data not derivable from public sources
• Any prediction model trained on future outcomes
• Any consideration of the viewing user's financial circumstances

Academic Basis

The weighting of score components is informed by peer-reviewed academic research on the informational content of insider transactions, including but not limited to:

• Jeng, L.A., Metrick, A. & Zeckhauser, R. (2003). Estimating the Returns to Insider Trading: A Performance-Evaluation Perspective. The Review of Economics and Statistics. Wharton School, University of Pennsylvania.
• Wang, W., Shin, Y. & Francis, B. (2012). Are CFOs' Trades More Informative than CEOs' Trades? Journal of Financial and Quantitative Analysis.
• Kang, M., Kim, W. & Wang, C. (2018). Cluster-Buying by Corporate Insiders. Working Paper.
• Cohen, L., Malloy, C. & Pomorski, L. (2012). Decoding Inside Information. Journal of Finance.

Academic research describes statistical relationships observed across large historical datasets. Academic findings do not guarantee that any individual transaction scored by Pingr will produce above-average returns. Individual results will vary. Past academic findings may not apply to current market conditions.

Score Uniformity

The identical scoring algorithm is applied to every Form 4 filing processed by Pingr without exception. No filing, company, insider, or user receives differential treatment. The algorithm does not adapt to individual users. The algorithm does not learn from outcomes in a way that changes the scoring of current filings. The score you see is the same score every other user sees for the same filing.

Score Limitations

Users must understand and accept the following limitations of conviction scores before relying on them in any way:

• A high conviction score does not mean a stock will increase in value
• A low conviction score does not mean a stock will decrease in value
• Scores are calculated from a subset of available market information and do not reflect all relevant factors
• The weighting model may not be optimal and may contain errors
• Market conditions change and historical relationships between insider buying and subsequent returns may not persist
• Individual trades scored highly have produced both gains and losses in Pingr's live track record
• The live track record, including all losses, is pe
• The conviction score is one input among many that a prudent investor would consider, and should never be used as the sole basis for any investment decision

Golden Vault — Fund Connection, Capital Handling & Absolute Non-Custody Declaration

What the Golden Vault Is

The Golden Vault is a signal relay feature available to Investor tier subscribers. When a user voluntarily connects their own Alpaca Securities LLC brokerage account to Pingr via API keys, Pingr's engine monitors SEC Form 4 filings, calculates conviction scores, and — upon detecting a qualifying signal — submits a market order instruction to the Alpaca API using the user's own credentials. The order is placed in the user's own brokerage account, in the user's own name, under the user's own regulatory identity.

Absolute Non-Custody — The Complete Declaration

Your money is yours. It sits in your Alpaca brokerage account — an account registered in your name, governed by your agreement with Alpaca Securities LLC, protected by SIPC (for live accounts), and subject exclusively to your own control. Pingr is not a party to that account. Pingr has no legal or beneficial interest in that account. Pingr cannot see your account balance except through an authenticated API status call made at your request. Pingr cannot make withdrawals. Pingr cannot transfer funds. Pingr cannot close your account. Pingr has no legal claim over any asset in your account at any time for any reason.

What Pingr Actually Does

Pingr's role is precisely and exclusively the following: it reads publicly available SEC filing data, applies its algorithmic scoring model to that data, determines whether a qualifying signal threshold has been reached, and — if so — submits a structured API call to Alpaca's servers containing an order instruction. That instruction is authenticated with your API keys (which you provided voluntarily and which Pingr stores in encrypted form solely for this purpose). Alpaca then independently decides whether to execute that order based on its own rules, your account status, available buying power, and market conditions. Pingr plays no role in execution. Pingr does not confirm execution. Pingr does not receive any part of the executed order. Pingr does not receive any confirmation, rebate, payment, commission, fee, spread, or financial consideration of any kind from Alpaca or from any party in connection with any order placed.

No Profit, Fee, Commission, or Benefit From Your Capital

Pingr derives zero financial benefit from your capital or from any trade placed in your Alpaca account. Pingr does not charge performance fees. Pingr does not charge management fees. Pingr does not charge transaction fees. Pingr does not receive brokerage rebates. Pingr does not receive payment for order flow. Pingr does not earn interest on your balance. Pingr does not receive any portion of any profit your account generates. Pingr does not receive any compensation for any loss your account incurs. Pingr's only revenue in connection with Investor tier users is the flat subscription fee paid for access to the platform — which is fixed, disclosed, and entirely unrelated to trading performance or account size.

Alpaca Securities LLC

All brokerage services, trade execution, order routing, account custody, margin lending, and regulatory compliance in connection with your live trading account are provided exclusively by Alpaca Securities LLC, a registered broker-dealer and member of FINRA and SIPC. Alpaca is regulated independently of Pingr. Pingr has no ownership interest in Alpaca. Pingr is not an affiliate of Alpaca. Your regulatory protections in respect of your brokerage account are governed by your agreement with Alpaca and applicable US securities law — not by these Terms. Paper trading accounts are not covered by SIPC.

Your Sole Responsibility

By connecting your Alpaca account to the Golden Vault, you unconditionally accept and acknowledge that: you are the sole person responsible for all investment decisions made through your account; you are the sole person liable for all tax obligations arising from trades in your account; you are the sole person responsible for ensuring your use of automated order placement complies with applicable law in your jurisdiction; and you are the sole person who bears all financial risk of loss in connection with your account. Pingr accepts no liability whatsoever for any trading loss, missed opportunity, system outage, API error, order rejection, partial fill, slippage, or other adverse outcome arising from the Golden Vault feature.

Revocation and Disconnection

You may disconnect your Alpaca account from Pingr at any time by using the disconnect function in your dashboard. Upon disconnection, Pingr will cease submitting order instructions to the Alpaca API immediately. Pingr will delete your stored API keys within a reasonable time following disconnection. Disconnecting Pingr does not close your Alpaca account, does not liquidate your positions, and does not affect any orders already submitted prior to disconnection.

Consent Signature

Activation of the Golden Vault live trading feature requires the user to affirmatively tick three separate consent acknowledgements and to type their full legal name as a digital signature. This consent record is timestamped and stored securely. The consent record constitutes an auditable record that the user read and understood this section, the risk disclosures in Section 19, and the non-custody declaration above before any order was placed. Users who connected their Alpaca account prior to the introduction of the consent system must reconnect to generate a consent record before automated order placement resumes.