Risk Warning & Disclaimer

EasySwing.trading (the "Service"), operated by Sofus(eenmanszaak, Amsterdam, NL), is a technology tool that aggregates publicly available market data and applies algorithmic filters to screen US equities against technical and fundamental criteria.

Nothing on the Service is investment advice. In particular, no output of the Service constitutes "investment advice" or a "personal recommendation" within the meaning of:

• MiFID II (Directive 2014/65/EU, Art. 4(1)(4)) or the Dutch Financial Supervision Act (Wet op het financieel toezicht, Wft);
• The U.S. Investment Advisers Act of 1940, SEC Regulation Best Interest (Reg BI), or FINRA Rule 2111 (Suitability);
• The UK Financial Services and Markets Act 2000 (FSMA) and FCA Handbook COBS 9 / 9A;
• Equivalent rules in any other jurisdiction.

The Service does not:

• Make personalised investment recommendations to you;
• Take into account your individual financial situation, investment objectives, time horizon, tax position, or risk tolerance;
• Manage your assets or act as a portfolio manager;
• Promise or guarantee any investment outcome, return, or risk-adjusted profile.

EU/UK — ESMA four-criteria test for investment advice. Under ESMA's supervisory briefing on the definition of investment advice (and the underlying MiFID II Art. 4(1)(4) and Commission Directive 2006/73/EC Art. 52 framework), a service is "investment advice" only where all four of the following criteria are met cumulatively: (i) a recommendation is made; (ii) the recommendation concerns one or more transactions in specific financial instruments; (iii) the recommendation is presented as suitable for, or based on a consideration of, the personal circumstances of the recipient; and (iv) the recommendation is issued otherwise than exclusively through distribution channels or to the public. The Service is designed to fail criterion (iii) (no personal suitability consideration) and criterion (iv) (outputs are distributed to all subscribers applying the same filters), and is therefore not investment advice within the meaning of MiFID II.

US — publisher exclusion under §202(a)(11)(D) of the Investment Advisers Act.Sofus structures the Service to operate within the publisher exclusion from the definition of "investment adviser" under §202(a)(11)(D) of the Investment Advisers Act of 1940, as interpreted by the U.S. Supreme Court in Lowe v. SEC, 472 U.S. 181 (1985). The Service is (a) bona fide — providing disinterested commentary and algorithmic analysis, not promotional material or "touting"; (b) of general and regular circulation — outputs are available to all subscribers running the same filters, not tailored bulletins to specific clients; and (c) impersonal — the Service does not offer individualised advice attuned to any specific client's portfolio, financial situation, or particular needs. Soren and other AI features are extensions of the same publication structure and do not transform the Service into a regulated investment adviser. We continue to monitor SEC interpretation and will adjust the Service if regulatory guidance changes.

Sofus is:

• Not registered with the Dutch Authority for the Financial Markets (AFM — Autoriteit Financiële Markten) as an investment firm or financial adviser;
• Not registered with the U.S. Securities and Exchange Commission (SEC) as a Registered Investment Adviser (RIA) or broker-dealer, nor with any U.S. state securities regulator;
• Not a member of FINRA or any equivalent self-regulatory organisation;
• Not authorised by the UK Financial Conduct Authority (FCA) or any European national competent authority to provide regulated investment services.

Users who require regulated investment advice should consult a licensed financial professional in their jurisdiction. The Service is not a substitute for personal advice from a qualified adviser.

Trading stocks, options, futures, and other financial instruments carries significant risk, including:

• Loss of capital — you may lose some or all of the capital you invest, and in margin or leveraged accounts you may lose more than you deposit.
• Volatility — small-, mid-, and momentum-driven stocks (a primary focus of the Service) can move sharply and unpredictably.
• Liquidity risk — low-float or low-volume stocks may have limited liquidity, making it difficult to exit positions at desired prices.
• Gap and slippage risk — stocks can open significantly higher or lower than the previous close, bypassing stop-loss orders.
• Pattern Day Trader (PDT) rules — U.S. traders with margin accounts below $25,000 face restrictions on day trading. The Service does not manage your PDT status.
• System and connectivity risk — outages of the Service, your broker, or market infrastructure may prevent timely action.
• Personal risk — trading can be psychologically demanding and is unsuitable for capital you cannot afford to lose.

The Service may display historical scan results, strategy statistics, leaderboards, equity curves, backtested performance, simulated trade outcomes, paper-trading results, and similar metrics. All such figures are illustrative only and do not predict future results.

Hypothetical and backtested results have inherent limitations. Unlike an actual performance record, simulated results do not represent real trading and may not account for the impact of certain real-world factors, including but not limited to:

• Order execution slippage, partial fills, and gaps;
• Broker commissions, financing costs, market-maker spreads, and regulatory fees;
• Tax consequences (including short-term vs long-term treatment);
• The psychological pressure of trading real capital, which routinely changes user behaviour relative to a simulation;
• Survivorship bias (delisted tickers may be missing from historical universes);
• Look-ahead and selection bias in strategy definition and parameter tuning;
• Liquidity constraints — fills shown at the displayed price may not be achievable at the size implied by your sizing logic.

No representation is made that any account will or is likely to achieve profits or losses similar to those shown. Trading involves risk of substantial loss; past performance, whether actual or hypothetical, is not a reliable indicator of future performance.

The Service includes an AI assistant ("Soren") and algorithmic ranking features. AI outputs are generated by statistical language models and quantitative filters, not by a human analyst or licensed adviser.

• AI outputs can be wrong, incomplete, outdated, or fabricated ("hallucinated"), including names, numbers, prices, and earnings figures. Always verify any factual claim against a primary source before acting on it.
• Algorithmic rankings reflect rule-based scoring against historical data. They are not recommendations.
• Soren does not know your personal financial situation, tax position, or risk tolerance, and cannot give personal advice. Conversations with Soren are not advisory relationships.

Full AI handling — including data flow, model providers, retention, and your ability to opt out — is described in the AI Usage Policy.

The Service sources data from third parties including a market-data provider, the optional broker integration (where you enable it), and our AI model providers. We do not own or control that data. While we monitor for obvious defects:

• Market data may be delayed, incomplete, or contain errors;
• Real-time quotes may differ from actual execution prices;
• Fundamental data (EPS, revenue, ratios) may not reflect the most recent filings;
• Corporate-action adjustments may lag the live market;
• Alert delivery via Telegram is best-effort and may be delayed or missed.

We make no warranty, express or implied, as to the accuracy, completeness, timeliness, or suitability for any purpose of any data or information provided through the Service.

Where the Service offers an optional broker integration, users who connect their account acknowledge:

• The Service transmits order parameters to the connected broker on your behalf when you trigger them; all orders are routed, executed, and settled by the broker under the broker's own terms, execution policies, and regulatory oversight.
• The Service is not responsible for execution quality, slippage, partial fills, or any broker-side error.
• Stop-loss and take-profit orders are not guaranteed to execute at specified prices, especially during volatile market conditions or off-hours.
• Sofus does not have custody of your funds or securities — all assets are held by the connected broker.
• Live trading is opt-in and requires explicit enablement. Paper trading is the default where the integration is active. The connected broker is identified in the in-app integration screen.

By using the Service, you acknowledge and accept that:

• You are solely responsible for every trading decision you make;
• You have read and understand this Disclaimer, the Terms of Service, and the AI Usage Policy;
• You understand the risks associated with trading and will not trade with capital you cannot afford to lose;
• You will independently verify any data, signal, or AI output before acting on it;
• You will not hold Sofus liable for trading losses, missed opportunities, or other harm arising from your use of the Service or reliance on its outputs;
• You will seek independent professional advice (financial, tax, legal) where appropriate for your personal circumstances.

To the maximum extent permitted by applicable law, Sofus shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising from your trading activities or reliance on information provided through the Service. This includes, without limitation, losses resulting from scan results, alert triggers, AI outputs, backtest data, or order execution through any broker integration.

See Section 11 of the Terms of Service for the full limitation-of-liability clause, including the aggregate liability cap and the carve-outs that apply under Dutch and EU consumer law.

United States. The Service is not registered with the SEC or any state securities regulator, nor is it a member of FINRA. Screener outputs, AI responses, and alerts do not constitute "recommendations" within the meaning of Reg BI, FINRA Rule 2111, or the Investment Advisers Act. U.S. users are responsible for complying with all applicable securities laws, including PDT rules and short-sale restrictions.

European Union / Netherlands. The Service provides market-data and screening functionality under what we believe to be the "information services" category outside of MiFID II's investment-advice definition (Art. 4(1)(4)). Sofus is not authorised by the AFM to provide investment services.

United Kingdom. The Service is not authorised by the Financial Conduct Authority. Nothing on the Service is a "financial promotion" within the meaning of FSMA s. 21, and the Service is not directed at retail clients in the UK for the purpose of promoting regulated investment services.

Other jurisdictions. Users outside the US, EEA, and UK are responsible for ensuring their use of the Service complies with local regulations regarding financial information, securities trading, and cross-border data services.

Legal or compliance inquiries:
Sofus (trading as EasySwing.trading)
Amsterdam, Netherlands
privacy@easyswing.trading