Terms of Service

1. Who we are and what these terms cover

These Terms of Service (the "Terms") govern your access to and use of the LOCK IN mobile applications, the lockin.trade website, and all related features, content and services (together, the "Service"). The Service is provided by LOCKIN (CY) LIMITED, a company incorporated in the Republic of Cyprus ("LOCK IN", "we", "us" or "our").

By creating an account, entering an access code, installing or using any LOCK IN application, subscribing to a paid plan, or otherwise using the Service, you confirm that you have read, understood and agree to be bound by these Terms and by our Privacy Policy, which is incorporated into these Terms by reference. If you do not agree, you must not use the Service.

If you use the Service on behalf of a company or other legal entity, you represent that you have authority to bind that entity, and "you" refers to that entity.

These Terms contain provisions that limit our liability, allocate risk to you, and — where permitted by the law applicable to you — affect how disputes are resolved. Sections 17 to 22 are particularly important and should be read carefully.

2. Definitions

Account

the account you create to access the Service.

Access Code

a code issued by us or by an authorised community partner that permits entry to the Service during limited-availability periods.

AXEL

the conversational assistant within the Service, which produces output using large language models and other automated techniques.

Connected Venue

an exchange, broker or trading platform that you link to the Service.

Trading Data

the records obtained from a Connected Venue about your account, including balances, positions, orders, executions, transfers and their timestamps.

Output

any analysis, score, archetype, alert, summary, plan, statistic or other material the Service generates, including anything produced by AXEL.

Subscription

a paid plan giving access to the Service for a recurring period.

3. Eligibility

To use the Service you must be at least 18 years old and have the legal capacity to enter into a binding contract. The Service is not directed to, and must not be used by, anyone under 18.

You may not use the Service if you are resident in, located in, or acting on behalf of any person in a country or territory subject to comprehensive sanctions administered by the European Union, the United Nations, the United Kingdom or the United States, or if you are listed on, or owned or controlled by a person listed on, any applicable sanctions list. You represent that none of these apply to you and undertake to stop using the Service immediately if any of them becomes true.

You are responsible for determining whether your use of the Service is lawful in your jurisdiction. We make no representation that the Service is appropriate or available for use in any particular location, and we may restrict availability in any jurisdiction at our discretion.

4. What the Service is

LOCK IN is a behavioural analytics and education tool for traders. It reads the trading history of accounts you choose to connect, identifies patterns in how you trade, and presents that analysis back to you together with market context and educational material.

The Service is an information and education product. It exists to help you understand your own past behaviour and to give you a basis for your own decisions.

5. What the Service is not

LOCK IN IS NOT A BROKER, DEALER, EXCHANGE, CUSTODIAN, PORTFOLIO MANAGER OR INVESTMENT ADVISER, AND IS NOT AUTHORISED OR REGULATED AS ANY OF THEM. NOTHING IN THE SERVICE IS INVESTMENT ADVICE, A PERSONAL RECOMMENDATION, AN INVITATION OR INDUCEMENT TO TRADE, OR AN OFFER TO BUY OR SELL ANY FINANCIAL INSTRUMENT. NO OUTPUT TAKES ACCOUNT OF YOUR OBJECTIVES, FINANCIAL SITUATION, TAX POSITION OR NEEDS.

For the avoidance of doubt, and without limitation, the Service does not and will not:

• place, cancel, modify or route any order, or execute any transaction on your behalf;
• hold, receive, transmit, control or take custody of your money, digital assets or other property at any time;
• operate any account with discretionary authority, or manage a portfolio on your behalf;
• provide investment, legal, tax or accounting advice, or a personal recommendation of any kind;
• guarantee, forecast or predict the price or performance of any market, instrument or strategy;
• guarantee any trading result, profit, reduction in loss, or improvement in performance.

Any improvement in your trading is the result of your own decisions and discipline. You alone are responsible for every trading decision you make and for every consequence of it, whether or not you consulted the Service first.

6. Risk warning

TRADING CARRIES A SUBSTANTIAL RISK OF LOSS AND IS NOT SUITABLE FOR EVERYONE. LEVERAGE AND MARGIN MAGNIFY BOTH GAINS AND LOSSES AND CAN RESULT IN LOSSES EXCEEDING YOUR DEPOSIT. DIGITAL ASSET MARKETS ARE VOLATILE, MAY BE THINLY TRADED, OPERATE CONTINUOUSLY, AND MAY BECOME ILLIQUID WITHOUT WARNING. PAST BEHAVIOUR AND PAST PERFORMANCE DO NOT PREDICT FUTURE RESULTS. YOU SHOULD NOT TRADE WITH MONEY YOU CANNOT AFFORD TO LOSE, AND YOU SHOULD SEEK INDEPENDENT ADVICE FROM A LICENSED PROFESSIONAL IF YOU ARE IN ANY DOUBT.

Any figures, examples, screenshots or illustrations shown in the Service or on our website are illustrative of the product’s output and are not a representation of results you or anyone else will achieve. Where we describe outcomes reported by users, those are self-reported, unaudited, and not verified by us.

7. Accounts, access codes and security

You must provide accurate and complete information when creating an Account and keep it up to date. You may hold only one Account unless we agree otherwise in writing.

Access to the Service may be limited and issued in batches by Access Code. An Access Code is personal to you, is not transferable, and may not be sold, auctioned or otherwise dealt with. We may cancel any Access Code that we reasonably believe has been shared, sold or obtained improperly.

You are responsible for maintaining the confidentiality of your credentials and for all activity that occurs under your Account. You must notify us at the address in section 24 as soon as you become aware of any unauthorised use or suspected compromise of your Account.

8. Connecting a venue, and your API keys

The Service works by connecting to accounts you hold at third-party venues using credentials you supply, ordinarily an application programming interface ("API") key issued to you by that venue.

YOU MUST ONLY EVER SUPPLY READ-ONLY CREDENTIALS. Do not create or provide an API key with trading, withdrawal, transfer or account-management permissions. The Service does not require them and will not use them. If you supply a key with permissions beyond reading, you do so contrary to these Terms and entirely at your own risk, and you remain solely responsible for anything done with that key.

You represent that you are the lawful holder of every account you connect, that you are permitted to connect it, and that doing so does not breach your agreement with the venue. You are responsible for complying with the terms, rate limits and API policies of each Connected Venue.

You may revoke a connection at any time, both within the Service and directly at the venue. Revoking at the venue takes effect immediately and is the definitive method. We will cease accessing that venue on your behalf once revocation takes effect.

Connected Venues are independent third parties. We do not control them, we are not responsible for their acts, omissions, availability, solvency, security or the accuracy of the data they return, and we have no liability for any loss arising from them. Data may be delayed, incomplete, revised or wrong at source, and Output built on it inherits those limitations.

9. Subscriptions, fees and billing

Certain features require a paid Subscription. Prices, billing periods and what each plan includes are described at the point of purchase, and those descriptions form part of these Terms.

Subscriptions renew automatically at the end of each billing period at the then-current price until cancelled. You authorise us and our payment processor to charge your chosen payment method on each renewal. You may cancel at any time; cancellation takes effect at the end of the current billing period and you retain access until then.

Where you purchase through a third-party app store, that store handles billing, renewal and refunds under its own terms, and you may need to cancel through the store rather than through us.

All fees are stated exclusive of value added tax and any other applicable taxes or duties, which will be added where required. You are responsible for any taxes arising from your own trading activity.

We may change our prices. We will give you at least 30 days’ notice before a change takes effect for you, and the change will apply from your next billing period after that notice. If you do not accept the new price you may cancel before it takes effect.

DISCLOSURE OF INTEREST. We offer a reduced subscription price to users who open an account at a supported venue through us. Where you do so, we may receive payments from that venue, including a share of the fees or spread you generate. This is a financial interest that could reasonably be seen to conflict with your interests, and you should take it into account. It does not change what the Service does: we do not select venues on the basis of what they pay, no Output is influenced by any such arrangement, and we neither recommend that you trade nor recommend how much. You are free to use any supported venue on the standard plan with no such arrangement in place.

10. Trials, pre-release builds and changes to the Service

Parts of the Service may be made available as beta, preview or test builds, including through Apple TestFlight or as a directly distributed Android package. Pre-release software is provided for evaluation, may be incomplete or unstable, may lose data, and may be withdrawn or expire at any time. It is provided "as is" and the warranty disclaimer in section 17 applies to it in full.

We are continually developing the Service and may add, change, suspend or remove features. Where a change materially reduces the core functionality of a plan you are paying for, we will give you reasonable notice and, if you do not accept it, you may cancel and receive a pro-rata refund of the unused portion of your current billing period.

11. AXEL and automated output

AXEL and other automated features produce Output using large language models and statistical methods. Such systems are probabilistic. They can be confidently wrong, can misread data, can produce statements that are inaccurate, incomplete or out of date, and can generate content that appears authoritative but is not.

Output is provided for information and education only. You must not rely on it as a sole basis for any decision, and you should verify anything material against your own records and the venue’s own reporting before acting on it.

We do not warrant that Output is accurate, complete, current or fit for any purpose. To the extent permitted by law we exclude all liability arising from your reliance on Output.

You must not submit to AXEL any information you are not entitled to disclose, and you must not use the Service to attempt to extract, reverse engineer or reconstruct any underlying model, prompt or training data.

12. Referral and ambassador programmes

We operate programmes under which you may earn a share of revenue for introducing other users, or rewards for producing content. Participation is subject to the specific programme rules published for it, which form part of these Terms for participants.

You may not earn on your own Account or on accounts you control, and you may not obtain referrals by spam, paid traffic misrepresenting LOCK IN, impersonation, incentivised sign-ups, fabricated engagement, or any statement about LOCK IN that is misleading — in particular any claim of guaranteed returns, of performance we have not published, or that the Service constitutes advice.

You must clearly disclose your commercial relationship with us wherever the law or platform rules require it. You are solely responsible for your own tax obligations on anything you earn.

We may withhold, reverse or cancel any payment, and remove you from any programme, where we reasonably determine that these rules have been breached, that the underlying activity was fraudulent, or that the referred user has charged back or obtained a refund.

13. Acceptable use

You agree not to, and not to permit anyone else to:

• use the Service for any unlawful purpose, or in breach of any sanctions, market abuse, anti-money-laundering or securities law;
• access or attempt to access any account, system or data that is not yours, or probe, scan or test the vulnerability of our systems;
• circumvent, disable or interfere with any security, authentication, rate-limiting or access-control feature;
• scrape, crawl, harvest or use automated means to extract data from the Service, except as expressly permitted;
• copy, modify, translate, reverse engineer, decompile or disassemble any part of the Service, or attempt to derive its source code, models or prompts, except to the extent this restriction is prohibited by law;
• resell, sublicense, rent, or provide the Service to any third party, or use it to build or train a competing product or model;
• share, sell or transfer an Account or Access Code;
• upload or transmit malware, or anything that damages or impairs the Service;
• misrepresent your identity or your affiliation with us; or
• use the Service in any way that imposes an unreasonable load on our infrastructure or that of a Connected Venue.

14. Your content and your data

You retain all rights in the content and data you provide, including your Trading Data. You grant us a worldwide, non-exclusive, royalty-free licence to host, store, reproduce, process, adapt and transmit it strictly to the extent necessary to operate and improve the Service, to provide Output to you, and to comply with law. This licence ends when the relevant data is deleted, save for backups pending expiry and anything we must retain by law.

We may create and use aggregated or de-identified data that does not identify you or any individual, including for analytics, benchmarking, research and improving the Service. We will not attempt to re-identify such data, and it does not carry any of your identifying information when used.

Where you post content publicly — for example in a community channel, or in material produced as an ambassador — you grant us a non-exclusive, royalty-free licence to reproduce and display that content in connection with promoting the Service, and you confirm you have all necessary rights to do so.

How we handle personal data is set out in our Privacy Policy.

15. Intellectual property

The Service, and all software, models, designs, text, graphics, interfaces, trade marks and other material in it, are owned by us or our licensors and are protected by intellectual property laws. Nothing in these Terms transfers any of those rights to you.

Subject to your compliance with these Terms, we grant you a limited, personal, non-exclusive, non-transferable, revocable licence to use the Service for your own internal, non-commercial trading activity, for as long as your right to use it continues.

If you send us feedback, ideas or suggestions, you grant us an unrestricted, perpetual, irrevocable, royalty-free right to use them for any purpose, without obligation or attribution to you.

16. Third-party services

The Service integrates with, links to, or is distributed through third parties, including Connected Venues, app stores, payment processors, analytics providers, model providers and communication platforms. Your use of those services is governed by their own terms and privacy policies.

We do not control and are not responsible for third-party services, and their inclusion is not an endorsement. We are not liable for any loss arising from their acts, omissions, availability, pricing, security or content.

17. Disclaimer of warranties

TO THE FULLEST EXTENT PERMITTED BY LAW, THE SERVICE AND ALL OUTPUT ARE PROVIDED "AS IS" AND "AS AVAILABLE", WITHOUT WARRANTY OF ANY KIND, EXPRESS, IMPLIED OR STATUTORY, INCLUDING ANY IMPLIED WARRANTY OF MERCHANTABILITY, SATISFACTORY QUALITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, OR NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE OR ERROR-FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT ANY DATA OR OUTPUT WILL BE ACCURATE OR COMPLETE.

Nothing in these Terms excludes or limits any warranty, right or remedy that cannot lawfully be excluded or limited, including the statutory rights of consumers.

18. Limitation of liability

Nothing in these Terms limits or excludes our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot lawfully be limited or excluded.

Subject to that, and to the fullest extent permitted by law:

• we are not liable for any trading loss, lost profit, lost opportunity, loss of anticipated savings, loss of goodwill, loss or corruption of data, or any indirect, incidental, special, consequential or punitive damages, however arising and whether or not we were advised of the possibility;
• we are not liable for any loss arising from your reliance on Output, from the acts or omissions of any Connected Venue or other third party, from any inaccuracy or delay in third-party data, or from any unavailability of the Service; and
• our total aggregate liability arising out of or in connection with these Terms and the Service, whether in contract, tort (including negligence), breach of statutory duty or otherwise, is limited to the greater of the total fees you paid us in the twelve months immediately before the event giving rise to the claim, or one hundred euro (€100).

This allocation of risk is a fundamental basis of the bargain between us and is reflected in the price of the Service.

19. Indemnity

To the extent permitted by law, you agree to indemnify and hold harmless LOCK IN, its affiliates, and their officers, directors, employees and agents against any claim, liability, damage, loss, cost or expense (including reasonable legal fees) arising out of or in connection with your use of the Service, your breach of these Terms, your breach of any law or of any agreement with a Connected Venue, your trading activity, or any content you submit or publish. This section does not apply to a consumer to the extent the law applicable to that consumer does not permit it.

20. Suspension and termination

You may stop using the Service and close your Account at any time.

We may suspend or terminate your access, immediately and without refund where the cause is attributable to you, if we reasonably believe that you have breached these Terms, that your use presents a security, legal or regulatory risk, that any information you gave us is false, or that we are required to do so by law. Where circumstances allow we will tell you why and give you an opportunity to put it right.

We may also discontinue the Service, or any plan, on 30 days’ notice, in which case we will refund the unused portion of any Subscription you have paid for.

On termination your licence ends and you must stop using the Service. Sections 5, 6, 11, 14, 15, 17, 18, 19, 22 and 23 survive termination, together with any other provision that by its nature should.

21. Force majeure

We are not liable for any failure or delay in performing our obligations caused by events beyond our reasonable control, including acts of God, war, terrorism, civil unrest, epidemic, industrial action, failure of utilities, telecommunications or internet infrastructure, failure or unavailability of a Connected Venue or other third-party provider, cyber attack, or any act of government or regulator.

22. Governing law and disputes

These Terms and any dispute arising out of or in connection with them or the Service, including any non-contractual dispute, are governed by the laws of the Republic of Cyprus.

We would like to resolve any complaint directly and quickly. Please contact us first at the address in section 24, giving details of the issue and what you would like us to do. We will acknowledge your complaint and aim to respond substantively within 30 days.

If a dispute cannot be resolved, the courts of the Republic of Cyprus have exclusive jurisdiction.

IF YOU ARE A CONSUMER IN THE EUROPEAN UNION OR THE UNITED KINGDOM, THIS SECTION DOES NOT DEPRIVE YOU OF THE PROTECTION OF THE MANDATORY RULES OF THE LAW OF YOUR COUNTRY OF RESIDENCE, AND YOU MAY BRING PROCEEDINGS IN THE COURTS OF THAT COUNTRY. NOTHING HERE AFFECTS YOUR STATUTORY RIGHTS, INCLUDING ANY RIGHT TO WITHDRAW FROM A DISTANCE CONTRACT WITHIN 14 DAYS. EU CONSUMERS MAY ALSO USE THE EUROPEAN COMMISSION’S ONLINE DISPUTE RESOLUTION PLATFORM.

23. General

• Entire agreement: these Terms, the Privacy Policy and any plan or programme rules referred to in them are the entire agreement between us about the Service, and replace any prior understanding.
• Changes: we may amend these Terms. For material changes we will give at least 30 days’ notice by email or in the Service before they take effect; other changes take effect when posted. If you do not accept a material change, your remedy is to stop using the Service and cancel before it takes effect.
• Severability: if any provision is held unenforceable, it is modified to the minimum extent necessary or severed, and the rest remains in force.
• No waiver: a failure to enforce any provision is not a waiver of it.
• Assignment: you may not assign or transfer these Terms without our written consent. We may assign them to an affiliate or in connection with a merger, reorganisation or sale of assets.
• No third-party rights: no one other than you and us has any right to enforce these Terms.
• Notices: we may give notice by email to the address on your Account or by posting in the Service. Notices to us must be sent to the address in section 24.
• Language: these Terms are written in English, and the English version prevails over any translation.

24. Contact

The Service is operated by LOCKIN (CY) LIMITED, a company incorporated in the Republic of Cyprus.

For any question about these Terms, or to give notice under them, contact us at: support@lockin.trade