AI Usage Policy

"Soren" is the conversational AI assistant inside EasySwing.trading. Soren is powered by large language models (LLMs) operated by third-party providers (currently Anthropic and/or OpenAI, accessed directly or via OpenRouter). Soren can:

• Answer questions about setups, indicators, market regime, and methodology in plain English;
• Trigger internal tools to run scans, look up a ticker, fetch market data, or surface stored journal entries;
• Format and explain outputs that the screener and other internal systems generate.

Soren operates inside the Service. Outputs are produced in real time based on (a) your message, (b) the current state of your account, and (c) public market data. Soren has no memory of other users' accounts or conversations.

Soren is not a financial adviser, broker, fiduciary, or regulated entity.Specifically, Soren:

• Does not provide personalised investment advice or recommendations within the meaning of MiFID II, the Investment Advisers Act, FINRA, FCA COBS 9, or any equivalent regime;
• Does not know your full financial situation, tax position, investment objectives, or risk tolerance — and cannot tailor advice to them;
• Does not place orders, manage positions, transfer funds, or take any action on your broker account on its own initiative;
• Does not predict the market;
• Is not a substitute for a human professional where one is appropriate.

When Soren describes a setup, sizes a position from inputs you supply, or summarises a backtest, it is producing illustrative output, not a personal recommendation. You decide whether to act, and you are solely responsible for the outcome. See the Risk Disclaimer.

Large language models are stochastic. They can produce confident, well-written outputs that are wrong, outdated, incomplete, biased, or fabricated ("hallucinated"), including fake earnings figures, made-up news, incorrect tickers, or invented historical prices. Algorithmic rankings rely on historical data and rule-based scoring that may not hold in future market conditions.

Verify before you act. Always cross-check any factual claim Soren makes against a primary source (your broker, an SEC filing, an exchange feed) before placing a trade. We do not warrant the accuracy, timeliness, or completeness of any AI output.

1. You send a message to Soren in the EasySwing.trading app.
2. Your message, recent conversation context, and a system prompt describing Soren's behaviour are sent to the AI model provider's API (e.g. Anthropic).
3. The provider returns a response, which we display to you and store in your account's chat history.
4. If Soren needs market data, screener output, or your journal contents to answer, it calls internal tools — those calls run on our infrastructure, not the AI provider's.

What's sent off-platform: your chat message, the system prompt, and minimal account context (e.g. a stable user ID for rate limiting, your current screener filter set when relevant to the question). We do not send your email address, name, payment data, or full broker activity to AI providers.

• No training on your data. We use our model providers under enterprise / API terms that prohibit them from using your inputs and outputs to train their general-purpose models. Where a provider offers zero-data-retention, we prefer that option; where the default is short-term API logging (typically 30 days for abuse monitoring), that is the maximum the provider keeps.
• Our retention. Your chat history is stored in our database for 90 days rolling. You can delete individual conversations or your full history at any time from your account; deletion is final and immediate from our systems. Backups roll off within 30 days.
• Aggregated analytics. We may compute aggregated, de-identified statistics from chat usage (e.g. "how often does Soren get asked about VCP setups") to improve the product. These statistics are not personal data and are not shared externally.
• We do not train our own foundation models. If we ever fine-tune a model on customer chat data, we will (a) announce it before doing so, (b) obtain affirmative consent, and (c) offer an opt-out without losing access to the rest of the Service.

Neither Soren nor any algorithmic ranking feature makes decisions that produce legal effects or similarly significantly affect you within the meaning of GDPR Article 22. The Service does not make automated decisions about access, pricing, or service eligibility based on profiling. See Section 9 of the Privacy Policy.

The EU AI Act (Regulation (EU) 2024/1689) categorises AI systems by risk and phases its obligations in over several years. The relevant dates are:

• 2 February 2025 — Prohibitions on unacceptable-risk AI systems (Art. 5) in force. The Service uses none of the prohibited practices (social scoring, real-time biometric ID, etc.).
• 2 August 2025 — Obligations for providers of general-purpose AI (GPAI) models in force. These bind the upstream foundation-model providers (Anthropic, OpenAI), not Sofus as a downstream deployer.
• 2 August 2026 — Article 50 transparency obligations for deployers begin to apply. From that date we will, at first interaction or exposure, clearly inform you that you are interacting with an AI system (Soren), and we will label AI-generated outputs in the interface where required. We have implemented these notices voluntarily in advance.
• 2 August 2027 — Full applicability of the high-risk obligations and most remaining provisions.

Soren is a general-purpose AI assistant used in a non-high-risk informational context (consumer-facing chat about publicly available market data). Soren is not used for credit scoring, employment, biometric identification, education, or other Annex III high-risk uses. We are following the development of the European Commission's AI Code of Practice on transparent AI systems (workshops concluding May 2026) and intend to align with its measures once published, which under Article 56 will give us a presumption of conformity with Article 50.

If the regulatory classification of Soren changes — for example, if the EU AI Office issues guidance that brings consumer financial-information AI into a higher-risk category — we will update this Policy and notify users.

• Turn off AI features. You can disable Soren in account settings without losing access to the screener, watchlists, alerts, or journal.
• Delete your chat history. You can clear conversations individually or in bulk from the Soren panel. Deletion is permanent.
• Export your chat history. Use the Privacy export tool in account settings, or email privacy@easyswing.trading.
• Object or restrict processing. You may exercise your GDPR rights as described in the Privacy Policy at any time.

By using Soren, you agree that you will:

• Treat AI outputs as starting points for your own research, not as instructions to act;
• Independently verify any number, price, news event, or filing claim Soren references;
• Not represent AI outputs as your own professional analysis to third parties for compensation;
• Not use Soren to attempt to extract our system prompt, jailbreak the model, generate content that violates our Acceptable Use Policy, or otherwise circumvent the Service's guardrails;
• Not feed Soren material non-public information ("MNPI") about any security; Soren is not a confidential channel.

The limitation-of-liability and disclaimer-of-warranty provisions in Section 10 and 11 of the Terms of Service apply in full to AI features. No warranty is given on AI output accuracy or fitness for any purpose.

We may update this AI Usage Policy as the underlying models, providers, regulations, or features change. Material changes will be notified to registered users by email at least 14 days before they take effect.

Questions about AI handling?
Sofus (trading as EasySwing.trading)
Amsterdam, Netherlands
privacy@easyswing.trading