Terms of Use

1. Introduction and Parties to the Agreement

These Terms of Use ("Terms") govern your access to and use of the portfolio review services, content, and features (collectively, the "Service") provided by Kolmira UG (haftungsbeschränkt) ("we," "us," or "our") through the website roastmyportfolio.com.

Important Distinction: All purchases and financial transactions for the Service are processed by our authorized Merchant of Record, Lemon Squeezy, LLC ("LemonSqueezy"). Your purchase is subject to their Terms of Sale, which you must agree to during the checkout process.

These Terms constitute a separate, legally binding agreement between you and Kolmira UG regarding your use of the Service itself. By accessing or using our Service, you agree to be bound by these Terms.

If you do not agree to these Terms, do not use our Service.

2. Service Description

RoastMyPortfolio provides automated portfolio analysis for educational and informational purposes. Our Service:

• Analyzes investment portfolios submitted by users
• Generates written commentary on portfolio composition, concentration risk, diversification, and behavioral patterns
• Delivers analysis in a direct, critical, and entertaining style
• Offers a free "teaser" analysis and paid full analysis via one-time payment
• Supports portfolio data entry via text input or screenshot upload (OCR)
• Provides a free weekly COT (Commitments of Traders) newsletter with market positioning analysis based on public CFTC data

3. License to Use the Service

Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, and revocable license to access and use the Service for your personal, non-commercial purposes as intended through the provided functionality.

This license does not grant you any ownership rights to the Service, its content, or its underlying technology. All rights not expressly granted herein are reserved by Kolmira UG.

4. User Content and Obligations

You retain all ownership rights to the portfolio data, images, text, and other content you submit to the Service ("User Content").

By submitting User Content, you grant Kolmira UG a worldwide, non-exclusive, royalty-free license to use, reproduce, modify, and display such content solely for the purpose of providing the portfolio review Service to you. This license terminates when your User Content is deleted from our systems (24 hours after submission).

You represent and warrant that:

• You have all necessary rights to submit the User Content
• Your User Content does not infringe upon any third-party intellectual property rights, privacy rights, or other rights
• Your User Content is accurate and truthful to the best of your knowledge
• You are at least 18 years of age

6. Newsletter & Email Communications

We offer a free weekly newsletter analyzing publicly available CFTC Commitments of Traders (COT) data. By subscribing, you agree to the following:

• You consent to receive weekly emails at the email address you provide
• Newsletter content is educational and informational only — the same disclaimer in Section 5 applies to all newsletter content
• CFTC data reflects trader positions as of the prior Tuesday and is published with a delay; it may not reflect current market conditions
• Chart signals and labels (e.g., BULLISH, BEARISH, NEUTRAL) are analytical indicators, not trading recommendations
• You may unsubscribe at any time via the link included in every newsletter email
• Email delivery is handled by Brevo, a third-party processor — see our Privacy Policy for details

7. Acceptable Use and Prohibited Conduct

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

• Use for illegal activities: Violate any applicable local, national, or international law
• Submit false or fraudulent information: Upload misleading, defamatory, or fraudulent portfolio data
• Infringe intellectual property: Submit content that violates third-party copyrights, trademarks, or other IP rights
• Reverse engineer or extract technology: Decompile, disassemble, or attempt to derive the source code of our AI models, algorithms, or software
• Use automated tools: Deploy bots, scrapers, crawlers, or other automated scripts to access the Service
• Interfere with Service security: Attempt to gain unauthorized access to our systems, servers, or networks
• Disrupt Service integrity: Introduce viruses, malware, or any code designed to damage or interfere with the Service
• Circumvent payment systems: Abuse the free analysis feature or attempt to bypass payment requirements
• Resell or redistribute: Commercially exploit, resell, or redistribute our analysis without authorization
• Misrepresent the Service: Claim our analysis as financial advice, professional recommendations, or investment guidance
• Violate third-party rights: Use the Service in a manner that violates the rights of others

8. Fees, Payments, and Refunds

Pricing

We offer:

• Free Mini Roast: Limited analysis with teaser content
• Full Analysis (One-Time Payment): Complete Five Blades analysis. Current pricing displayed at checkout.

Prices are displayed in EUR (€) and may include regional discounts based on your location (Purchasing Power Parity pricing). All prices include applicable VAT/sales tax as required by law.

Payment Processing

All fees for the Service are processed by our Merchant of Record, LemonSqueezy. All transactions are subject to LemonSqueezy's Terms of Sale and payment policies, which you agree to during checkout.

We do not process or handle payments directly. Your payment contract is with LemonSqueezy, not with Kolmira UG.

Refunds

Any requests for refunds must be directed to LemonSqueezy and will be handled in accordance with their refund policy.

For complete information about refunds, please see:

• Our Refund Policy
• LemonSqueezy's official Refund Documentation
• Contact LemonSqueezy support: lemonsqueezy.com/help

9. Merchant of Record

Payment processing for RoastMyPortfolio is handled by Lemon Squeezy, LLC ("LemonSqueezy") as our Merchant of Record.

LemonSqueezy provides:

• Secure payment processing and fraud prevention
• VAT/sales tax calculation and remittance
• Customer service for payment-related inquiries
• Refund processing
• Compliance with payment regulations

For payment or refund issues, contact LemonSqueezy support at lemonsqueezy.com/help.

10. Limitation of Liability

11. Intellectual Property

All content, design, logos, branding, software, algorithms, and analysis methodology used in the Service are protected by copyright, trademark, and other intellectual property laws. These materials are owned by or licensed to Kolmira UG.

Your Rights: Upon payment, you receive a personal, non-transferable license to use the analysis we generate for your portfolio. You may view, download, and print the analysis for personal use only.

Our Rights: We retain all rights to our branding, algorithms, methodology, software, and any derivative works. You may not copy, modify, distribute, sell, or lease any part of our Service or technology without explicit written permission.

12. Data Retention

Portfolio data and generated roasts are stored for 24 hours, then automatically deleted from our systems. Newsletter email addresses are retained until you unsubscribe. Payment transaction data is managed by LemonSqueezy in accordance with their privacy policy.

See our Privacy Policy for complete details on data handling, GDPR rights, and third-party data processors.

13. Termination

We may terminate or suspend your license and access to the Service immediately, without prior notice or liability, if you breach these Terms of Use.

Upon termination:

• Your right to use the Service will cease immediately
• Your User Content may be deleted from our systems
• Any licenses granted to you under these Terms will be revoked

We also reserve the right to:

• Refuse service to anyone for any reason
• Discontinue the Service at any time without notice
• Modify or remove features at our discretion

14. Governing Law and Dispute Resolution

Governing Law: These Terms shall be governed by the laws of Germany, excluding its conflict of law provisions.

Jurisdiction: For business customers, the exclusive jurisdiction for all disputes arising from this agreement shall be the courts of Stuttgart, Germany.

Dispute Resolution Process: Any disputes will be resolved through:

1. Good faith negotiation between the parties
2. Mediation (if negotiation fails)
3. Courts of Stuttgart, Germany (as last resort)

Note for EU Consumers: Information about the European Commission's Online Dispute Resolution (ODR) platform is available in our Imprint.

15. Changes to These Terms

We may update these Terms at any time. The "Last updated" date at the top of this page will reflect changes.

Continued use of the Service after changes constitutes acceptance of the updated Terms. If you do not agree to the revised Terms, you must stop using the Service.

16. Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining provisions remain in full force and effect. The invalid provision will be modified to the minimum extent necessary to make it valid and enforceable.

17. Entire Agreement

These Terms, together with our Privacy Policy and Financial Disclaimer, constitute the entire agreement between you and Kolmira UG regarding your use of the Service.

These Terms do not govern your purchase transaction, which is governed by LemonSqueezy's Terms of Sale.