Terms of Service

Last updated: April 2026

1. Acceptance of Terms

By accessing or using the NakedPnL website, API, or any related services (collectively, the “Service”), you agree to be bound by these Terms of Service (“Terms”). If you do not agree to all of these Terms, do not use the Service. We may update these Terms from time to time. Your continued use of the Service after changes constitutes acceptance of the revised Terms.

2. Description of Service

NakedPnL operates a public registry of verified investment performance. The Service aggregates, verifies, and displays performance data submitted by institutional funds and individual investors.

NakedPnL is not a broker, dealer, investment adviser, or financial institution. The Service does not provide investment advice, recommendations, or solicitations to buy or sell any security or financial instrument. Nothing on the Service constitutes personalized financial, legal, or tax advice.

3. Nature of Service

NakedPnL is a publisher of verified third-party performance data. The Service does not: (a) provide investment advice or financial planning services; (b) manage, hold, or have custody of client assets; (c) execute, facilitate, or route securities or digital asset trades on behalf of users; or (d) solicit investment in any specific trader, strategy, fund, or digital asset.

The display of performance data on the registry does not constitute an endorsement, recommendation, or opinion regarding the suitability of any trader, fund, or strategy for any investor. Users should conduct their own independent due diligence before making any investment decision.

4. No Advisory Relationship

No advisory, fiduciary, or client relationship is formed between NakedPnL and any user of the Service. NakedPnL is not registered as an investment adviser, broker-dealer, or commodity trading advisor with the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Financial Conduct Authority (FCA), or any other regulatory body. Use of the Service does not create any such registration obligation.

5. Permitted Use of Data

Registered investment advisers, broker-dealers, or other regulated entities that reference NakedPnL verification data in their own marketing, client communications, or regulatory filings are solely responsible for compliance with their applicable marketing rules, including without limitation SEC Rule 206(4)-1 (the Marketing Rule), FCA COBS 4, and MiFID II marketing requirements.

NakedPnL makes no representation or warranty that its data is suitable for use in regulated marketing materials. NakedPnL grants no warranty, indemnity, or compliance assurance to any entity incorporating its data into regulated communications.

6. No Copy Trading, No Execution

NakedPnL does not and will not facilitate trade execution, auto-following, copy trading, or any form of automated or semi-automated investment activity. The Service provides verified performance data for informational purposes only. No feature of the Service enables users to replicate, mirror, or automatically execute the trades or positions of any trader listed on the registry.

7. Jurisdictional Limitations

The Service is operated by NakedPnL (entity structure: TODO — Delaware LLC / DIFC entity — to be confirmed with counsel). The Service is not directed at residents of any jurisdiction where its operation would require additional registration, licensing, or regulatory approval.

Users are responsible for determining whether their use of the Service complies with the laws and regulations of their jurisdiction. NakedPnL makes no representation that the Service is appropriate or available for use in any particular location.

8. Account Registration

To access certain features of the Service, you must create an account. You must be at least 18 years of age (or the age of legal majority in your jurisdiction) to register. You agree to provide accurate, current, and complete information during registration and to keep your account information up to date. You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account.

9. Verification Process

NakedPnL offers a multi-tier verification system for performance data:

• SEC Filing Verification: Performance data cross-referenced against publicly available SEC filings.
• Brokerage API Verification: Direct read-only connection to supported brokerage accounts (when available).
• Administrator Attestation: Third-party fund administrator confirmation of reported returns (roadmap).

Verification indicates that the NakedPnL team has reviewed submitted data in accordance with the applicable tier methodology. Verification does not constitute a guarantee of accuracy, completeness, or future performance. NakedPnL reserves the right to reject, revoke, or reclassify any verification at its sole discretion.

10. User Data and Content License

By submitting performance data, account statements, or other materials (“User Content”) to the Service, you grant NakedPnL a worldwide, non-exclusive, royalty-free, sublicensable license to use, reproduce, process, display, and distribute such User Content solely for the purpose of operating, improving, and promoting the Service. You represent and warrant that you have all necessary rights to grant this license and that your User Content does not violate any third-party rights.

11. Pro Subscription

NakedPnL may offer a paid subscription tier (“Pro”) at a price of $39 per month (or such other price as communicated at the time of purchase). Pro subscriptions are billed monthly and renew automatically unless cancelled before the next billing date.

Cancellation and Refunds

You may cancel your Pro subscription at any time through your account settings. Cancellation takes effect at the end of the current billing period. If you are located in the European Union, you have the right to withdraw from your subscription within 14 days of purchase for a full refund, provided you have not fully used the Service during the withdrawal period. To request a refund, contact legal@nakedpnl.com.

12. Prohibited Uses

You agree not to:

• Submit false, misleading, or fabricated performance data.
• Impersonate any person, fund, or entity, or misrepresent your affiliation.
• Use the Service to manipulate, deceive, or defraud other users or third parties.
• Scrape, crawl, or use automated means to access the Service beyond the published API rate limits.
• Reverse-engineer, decompile, or disassemble any part of the Service.
• Interfere with or disrupt the integrity or performance of the Service.
• Use the Service for any unlawful purpose or in violation of any applicable law or regulation.
• Resell, redistribute, or commercially exploit registry data without prior written permission.

13. Intellectual Property

The Service, including its design, software, text, graphics, logos, icons, and compilation of data, is the exclusive property of NakedPnL or its licensors and is protected by French and international intellectual property laws. You may not reproduce, distribute, modify, or create derivative works of any part of the Service without prior written consent, except as expressly permitted by these Terms or applicable law.

14. Disclaimers

THE SERVICE IS PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

Past performance is not indicative of future results. Verified performance data displayed on the registry reflects historical returns and does not predict, guarantee, or imply any future performance. Investment involves risk, including the possible loss of principal.

NakedPnL does not guarantee the accuracy, completeness, or timeliness of any data displayed on the Service. Users should independently verify all information before making any investment decision.

15. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, NAKEDPNL, ITS OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, DATA, USE, OR GOODWILL, ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE SERVICE.

IN NO EVENT SHALL NAKEDPNL’S TOTAL AGGREGATE LIABILITY EXCEED THE GREATER OF (A) THE TOTAL FEES PAID BY YOU TO NAKEDPNL DURING THE TWELVE (12) MONTHS PRECEDING THE CLAIM, OR (B) ONE HUNDRED EUROS (EUR 100).

16. Indemnification

You agree to indemnify, defend, and hold harmless NakedPnL and its officers, directors, employees, agents, and affiliates from and against any claims, liabilities, damages, losses, costs, or expenses (including reasonable legal fees) arising out of or related to your use of the Service, your User Content, your violation of these Terms, or your violation of any rights of a third party.

17. Termination

NakedPnL may suspend or terminate your access to the Service at any time, with or without cause, and with or without notice. Upon termination, your right to use the Service ceases immediately. You may delete your account at any time through your account settings or by contacting legal@nakedpnl.com. Provisions that by their nature should survive termination shall survive, including but not limited to ownership, disclaimers, indemnification, and limitations of liability.

18. Changes to Terms

NakedPnL reserves the right to modify these Terms at any time. We will provide at least 30 days’ notice of material changes by posting the updated Terms on the Service and, where practicable, notifying you by email. Your continued use of the Service after the effective date of the revised Terms constitutes your acceptance of the changes.

19. Governing Law

These Terms shall be governed by and construed in accordance with the laws of France, without regard to its conflict of law provisions. Any dispute arising out of or relating to these Terms or the Service shall be subject to the exclusive jurisdiction of the courts of Paris, France.

20. Dispute Resolution

Before initiating any formal legal proceedings, you agree to first attempt to resolve any dispute informally by contacting NakedPnL at legal@nakedpnl.com. The parties shall negotiate in good faith for a period of at least 30 days. If the dispute cannot be resolved informally, either party may pursue resolution through the courts of Paris, France. For consumers resident in the European Union, you may also be entitled to submit a complaint through the European Commission’s Online Dispute Resolution platform at https://ec.europa.eu/consumers/odr.

21. Independence of Rankings

NakedPnL rankings and verification statuses are determined solely by verified performance data and the applicable verification methodology. Payment for a Pro subscription or any other commercial arrangement with NakedPnL does not influence, affect, or alter an entity’s ranking, verification status, or position in the registry. Rankings cannot be purchased, sponsored, or otherwise commercially influenced.

22. Severability

If any provision of these Terms is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary so that these Terms shall otherwise remain in full force and effect.

23. Entire Agreement

These Terms, together with the Privacy Policy and any other legal notices published on the Service, constitute the entire agreement between you and NakedPnL regarding the Service and supersede all prior agreements and understandings.