Terms & Conditions

1. Purpose and Scope

The Company provides proprietary investment research, economic and geopolitical analysis, market commentary, data, models, forecasts, investment strategies, and other informational materials through its website and related services (collectively, the “Materials”).

These Materials are intended solely for authorized users and are provided subject to the confidentiality, use restrictions, and other obligations set forth in this Agreement.

2. Proprietary and Confidential Information

You acknowledge that the Materials, together with any nonpublic information disclosed by or on behalf of the Company, may contain valuable proprietary, confidential, commercially sensitive, and competitively significant information.

“Confidential Information” includes, without limitation:

• Investment research, reports, forecasts, market analysis, and geopolitical assessments.

• Investment strategies, trading methodologies, models, signals, positions, and portfolio-related information.

• Research processes, analytical frameworks, proprietary tools, formulas, datasets, and software.

• Business plans, operational information, commercial relationships, and other nonpublic information concerning the Company.

• Any notes, extracts, summaries, analyses, reproductions, or derivative materials based on the foregoing.

Confidential Information includes information identified as confidential or proprietary, as well as information that a reasonable person would understand to be confidential given its nature or the circumstances of its disclosure.

3. Confidentiality and Non-Disclosure Obligations

As a condition of receiving access to the Materials, you agree to maintain the strict confidentiality of all Confidential Information and to take reasonable measures to prevent its unauthorized disclosure, access, copying, or use.

Without the Company's prior written consent, you shall not, directly or indirectly:

a. Disclose, publish, distribute, transmit, sell, license, share, or otherwise make any Confidential Information available to any third party.

b. Forward, repost, upload, reproduce, screenshot, record, or redistribute any Materials, in whole or in part, except as expressly authorized in writing by the Company.

c. Share your account credentials or permit another person to access restricted Materials through your account.

d. Use Confidential Information for any purpose other than your own authorized review and evaluation, subject to the restrictions in this Agreement.

e. Use Confidential Information to develop, market, or operate a competing research, advisory, investment, trading, or information service, or to obtain an unauthorized commercial or competitive advantage.

f. Remove, obscure, or alter confidentiality notices, proprietary legends, copyright notices, or other ownership designations appearing on the Materials.

g. Use any Confidential Information to train, fine-tune, or otherwise develop an artificial intelligence or machine-learning system, or submit Confidential Information to an external AI service, without the Company's prior written consent.

You shall promptly notify the Company if you become aware of any unauthorized access, disclosure, copying, or use of Confidential Information involving your account or any Materials made available to you.

These obligations apply whether the information is received electronically, in writing, orally, through downloads, or by any other means.

4. Permitted Disclosures and Exclusions

Your confidentiality obligations do not apply to information that you can demonstrate:

a. Is publicly available through no breach of this Agreement or other duty of confidentiality.

b. Was lawfully known to you, without an obligation of confidentiality, before disclosure by the Company.

c. Was lawfully obtained from a third party that was not under an obligation to maintain its confidentiality.

d. Was independently developed by you without use of or reference to the Confidential Information.

If you are legally compelled to disclose Confidential Information, you may disclose only the portion legally required and, where legally permitted, shall provide the Company with prompt advance notice so that appropriate protective measures may be considered.

Nothing in this Agreement prohibits disclosures protected by applicable law, communications with government or regulatory authorities, or other legally protected activity. No advance notice or Company consent is required where prohibited by law.

5. Ownership and Intellectual Property

All rights, title, and interest in and to the Materials and Confidential Information, including applicable copyrights, trademarks, trade secrets, database rights, and other intellectual property rights, remain with the Company or its respective licensors.

Access to the Website or Materials does not transfer ownership or grant you any license except the limited, revocable, non-exclusive, non-transferable right to access and review the Materials for authorized purposes under this Agreement.

No rights are granted by implication, estoppel, or otherwise beyond those expressly stated herein.

6. No Unauthorized Reliance or Redistribution

The Materials are provided for informational and research purposes only. They may include estimates, forecasts, opinions, assumptions, scenarios, and analytical judgments that may change without notice.

You may not represent the Materials as your own work, remove attribution, or imply that the Company endorses any third-party publication, product, investment, or service without prior written authorization.

7. Investment and Financial Information Disclaimer

Unless expressly agreed in a separate written agreement, the Materials are not intended to constitute individualized investment advice, a recommendation to buy, sell, or hold any security or other financial instrument, an offer to sell, or a solicitation of an offer to purchase any investment, fund interest, or other financial product.

The Materials are not tailored to your financial circumstances, investment objectives, risk tolerance, or legal or tax situation. You are responsible for independently evaluating any investment decision and consulting your own qualified professional advisers as appropriate.

Financial markets involve substantial risk, including the possible loss of principal. Past performance, hypothetical results, estimates, and forecasts are not necessarily indicative of future results. Information may be incomplete, delayed, inaccurate, or subject to revision.

Nothing on the Website, by itself, creates an investment advisory, fiduciary, agency, partnership, client, or other similar relationship between you and the Company.

8. No Guarantee of Accuracy or Availability

The Company endeavors to provide useful and timely information but does not warrant that the Website or Materials will be accurate, complete, current, uninterrupted, or error-free.

To the extent permitted by applicable law, the Website and Materials are provided on an “AS IS” and “AS AVAILABLE” basis, without warranties of any kind, whether express, implied, or statutory.

Nothing in this section excludes any warranty or liability that cannot lawfully be excluded.

9. Account Security and Acceptable Use

You agree to provide accurate account information, maintain the confidentiality of your login credentials, and use the Website only for lawful and authorized purposes.

You shall not attempt to bypass access controls, access another user's account, interfere with the Website's security or operation, scrape or systematically extract restricted Materials, or use automated means to collect or reproduce the Company's proprietary content without prior written authorization.

The Company may suspend or terminate your account if it reasonably believes that you have violated this Agreement, misused the Website, or created a security or confidentiality risk.

10. Termination and Continuing Obligations

You may discontinue use of the Website at any time. The Company may suspend, restrict, or terminate your access at its discretion, subject to applicable law and any separate agreement between the parties.

Upon termination or written request, you shall cease using the Confidential Information and, to the extent reasonably practicable and legally permissible, destroy or delete copies in your possession or control, except for records required to be retained by law or maintained in routine backup systems that are not readily accessible, which shall remain subject to this Agreement.

Your confidentiality, non-disclosure, intellectual property, permitted-use, and other provisions that by their nature should survive termination shall continue to apply. Confidentiality obligations shall continue for as long as the information remains confidential, subject to the exclusions in Section 4 and applicable law. Information qualifying as a trade secret shall remain subject to applicable trade secret protections for as long as it retains that status under applicable law.

11. Remedies for Breach

You acknowledge that unauthorized use or disclosure of Confidential Information may cause harm to the Company that may be difficult to quantify.

To the extent permitted by applicable law, the Company may seek appropriate legal and equitable remedies, including injunctive relief, for an actual or threatened breach of this Agreement, in addition to any other remedies available under applicable law.

Nothing in this Agreement guarantees that a particular remedy will be granted or limits any defenses or requirements imposed by law.

12. Limitation of Liability

To the fullest extent permitted by applicable law, the Company shall not be liable for indirect, incidental, consequential, special, exemplary, or punitive damages arising from or relating to your access to or use of the Website or Materials.

Nothing in this Agreement excludes or limits liability to the extent such exclusion or limitation is prohibited by applicable law.

13. Privacy

Your use of the Website is also subject to the Company's Privacy Policy, which describes how personal information is collected, used, stored, and disclosed. The Privacy Policy is incorporated into this Agreement by reference to the extent permitted by law.

Privacy Policy: https://mullionmanagement.com/privacy-policy

14. Amendments

The Company may update this Agreement from time to time. Material changes will be communicated through the Website, by email, or by other reasonable means as appropriate.

Where required by applicable law, the Company will obtain your renewed acceptance before applying revised terms to your continued access. The updated Agreement will identify its effective date.

15. Governing Law and Jurisdiction

This Agreement shall be governed by and construed in accordance with the laws of the State of Connecticut, without regard to its conflict-of-law principles, except to the extent applicable federal law governs.

Subject to applicable law, the parties consent to the jurisdiction of the state and federal courts located in Connecticut for disputes arising out of or relating to this Agreement.

16. General Provisions

If any provision of this Agreement is held unenforceable, the remaining provisions shall remain in effect to the extent permitted by law.

This Agreement, together with the Privacy Policy and any applicable supplemental terms expressly incorporated herein, constitutes the agreement between you and the Company concerning your use of the Website and the confidentiality of the Materials, superseding prior agreements on that subject to the extent permitted by law.

Your obligations under any separate confidentiality agreement, subscription agreement, advisory agreement, or other written contract remain unaffected except as expressly stated in that agreement.

A failure to enforce any provision does not constitute a waiver of the right to enforce it later.

You may not assign or transfer your rights or obligations under this Agreement without the Company's prior written consent.

17. Contact Information

Questions or notices concerning this Agreement may be directed to:

Mullion Management, LLC
Email: contact@mullionmanagement.com
Website: https://mullionmanagement.com

18. Invitation-Only Access and Approval

Access to restricted portions of the Website is limited to individuals expressly approved by Mullion Management, LLC. Registration, submission of an account request, or receipt of an invitation does not guarantee approval or access.

The Company reserves the right to approve or reject any account request, determine the scope of access granted to an approved user, and suspend or revoke access at any time, subject to applicable law and any separate written agreement.

Approval is personal to the individual approved and may not be transferred, assigned, or extended to another person without the Company's prior written authorization.

19. Authorized Use and Access Restrictions

Access to the Website and its restricted Materials is granted solely for the specific purposes authorized by the Company. Users shall not permit unauthorized individuals to access restricted Materials, whether through shared credentials, screenshots, screen recordings, downloads, forwarded communications, or any other means.

Users may not invite, register, or authorize other individuals to access the private portal on the Company's behalf unless expressly authorized in writing.

The Company may use reasonable access controls to protect the confidentiality and security of its Materials, including individual account approval, authentication requirements, access restrictions, and account suspension.

20. No Expectation of Continued Access

The Company makes no representation that access to the Website, any particular Material, or any research service will remain available for any specific period. The Company may modify, restrict, suspend, or discontinue access, subject to applicable law and any separate written agreement.

Suspension, termination, or expiration of account access does not release a user from confidentiality, non-disclosure, intellectual property, or other obligations that survive under the Agreement.

21. No Third-Party Rights or Implied Relationship

Approval to access the Website does not, by itself, establish an investment advisory, fiduciary, client, partnership, employment, or other business relationship with the Company. Any such relationship must be established separately through appropriate documentation.

Access to the Website does not authorize a user to represent the Company, distribute its Materials, or make commitments on its behalf.

USER ACKNOWLEDGMENT AND ACCEPTANCE

By selecting the acceptance checkbox and creating an account, you acknowledge and agree that:

1. You have read and understood this Agreement.

2. You understand that the Materials may contain proprietary and confidential information belonging to the Company or its licensors.

3. You agree not to disclose, distribute, reproduce, or otherwise share Confidential Information except as expressly permitted under this Agreement.

4. You agree to use the Materials only for authorized purposes and to protect them against unauthorized access or disclosure.

5. You understand that violation of these obligations may result in termination of access and legal remedies as permitted by law.