Terms of Use & Regulatory Disclosures

Last updated: December 7, 2025

1. Introduction

Welcome to Trails. Trails is a digital platform that allows registered users ("Users") to follow and subscribe to other users ("Creators") in order to view their personal investment activity, portfolio allocations, and trading signals (together with accompanying commentary or rationale).

These Terms of Use and Regulatory Disclosures ("Terms") govern your use of Trails — including use of the website, mobile application, and any associated services (collectively, the "Platform"). By accessing or using the Platform, you agree to abide by these Terms. If you do not agree, you must not use the Platform.

2. Definitions

  • Creator — a User who publishes content on the Platform (signals, trade activity, performance, commentary).
  • Subscriber or Follower — a User who subscribes to a Creator's feed, paying the subscription fee the Creator set.
  • Signals / Posts — content posted by Creators, including but not limited to: past trades, planned trades, commentary, rationale, portfolio snapshots, trade ideas.
  • Subscription Fee — a monthly amount (in USD, or other supported currency) set by the Creator (minimum $5, maximum $100 per month) that a Subscriber pays to get access to a Creator's feed.
  • Platform Fee — Trails deducts a 10% fee from all subscription payments; the remaining 90% goes to the Creator.

3. Platform Purpose; No Advisory / No Recommendation

Trails is a content marketplace and social investing platform. It is not a brokerage, broker-dealer, exchange, registered investment advisor, or fiduciary.

Creators may share information about their own personal trades or planned trades, along with commentary or rationale. That information reflects their own opinions and actions — never a recommendation, offer, or solicitation by Trails or the Creator.

You should not treat any content on the Platform (signals, posts, commentary) as financial advice. All investment and trading decisions you make are made solely at your own risk.

If you require personalized investment or financial advice, you should consult a licensed financial professional.

4. Risk Disclosure

⚠️ Investments involve risk.

All investments — whether in equities, options, or other instruments — carry the possibility of losing some or all of your invested capital.

  • Past performance is not a reliable indicator of future results. There is no guarantee that any Creator's future performance will match or exceed past results.
  • Market conditions, volatility, leverage, illiquidity, or external events may produce significant losses.
  • Trails does not verify, guarantee, or endorse the accuracy, completeness, or success of any Creator's posted trades, positions, or performance.
  • By using the Platform, you acknowledge and accept that all trading and investment decisions are yours alone.

5. Eligibility and Account Registration

  • To use the Platform, you must be at least 18 years old (or the age of majority in your jurisdiction) and have the legal capacity to enter a binding contract.
  • You must provide accurate, complete registration information. You are responsible for maintaining the confidentiality of your account credentials (username, password, API credentials, etc.).
  • You are responsible for all activity under your account.

6. Creator Terms & Content Standards

If you are a Creator on Trails, you agree to:

  • Only share your own personal investment activity, planned investment actions, or opinions.
  • Not provide personalized investment advice or instructions to individual subscribers — only publish general content.
  • Include appropriate risk disclosures in every post or signal, e.g.: "This is not financial advice. All investments involve risk, including loss of funds. I am only sharing my personal investment activity."
  • Not claim or guarantee any future returns or performance.
  • Not share false or misleading information.
  • Comply with all applicable laws and regulations (e.g. securities laws, insider trading laws).
  • Refrain from enabling "copy-trading": do not offer or facilitate automated copying of your trades by subscribers.

Violations of these rules may result in removal of content, suspension, or termination of your account.

7. Subscriber / User Responsibilities

As a Subscriber or user of Trails, you agree that:

  • You will treat all content (past trades, planned trades, commentary) as informational only, not as a recommendation.
  • You will perform your own due diligence and understand the risks of trading/investing.
  • You will not rely solely on a Creator's past performance or signals when making financial decisions.
  • You will comply with all applicable laws and regulations in your jurisdiction.

8. Payments, Subscriptions & Payouts

  • Creators set their own subscription price (in increments of whole USD, between $5 and $100 per month).
  • When a Subscriber signs up, their payment (via the configured payment provider) is collected and Trails deducts a 10% platform fee. The remaining 90% is allocated for payout to the Creator (subject to any applicable payment provider fees, withholding, and compliance checks).
  • Subscriptions recur monthly until canceled by the Subscriber or terminated (for cause) by Trails.
  • Creators are not guaranteed a minimum number of subscribers; revenue depends on user demand.
  • Subscription to a Creator's feed does not grant ownership rights, investment advisory rights, or any guarantee of performance.

9. Prohibited Activities & Conduct

You may not use the Platform (as a Creator or Subscriber) to:

  • Provide personalized investment advice or recommendations to others.
  • Make false, misleading, or deceptive statements regarding trades, returns, or performance.
  • Represent that you can guarantee future returns or outcomes.
  • Engage in insider trading, market manipulation, "pump-and-dump" schemes, or other unlawful or unethical trading practices.
  • Facilitate copy-trading or automatically reproduce trades for other users.
  • Violate any applicable securities law, regulation, or exchange rule.

Trails reserves the right to remove content or suspend/terminate accounts that violate these rules — with or without notice — and to report unlawful activity to regulators if required.

10. Limitation of Liability; No Warranties

  • The Platform, Trails, its officers, employees, affiliates, agents, and service providers do not guarantee the accuracy, completeness, or success of any Creator content or trading signals.
  • To the fullest extent permitted by law, Trails is not liable for any direct or consequential losses, damages, or liabilities resulting from your use of the Platform, reliance on content, or any investment decisions made based on that content.
  • The Platform is provided "as is" and "as available," with no warranties (express or implied) regarding performance, availability, suitability, or results.

11. Compliance and Cooperation with Regulators

  • Trails is not registered as a broker-dealer or investment adviser, and does not provide custodial, execution, or advisory services.
  • Creators operate independently and are responsible for their content.
  • Trails may cooperate with regulators or law enforcement with respect to suspected violations of law (e.g. insider trading, unregistered advisory activity).
  • Trails reserves the right to suspend or terminate accounts in response to suspicious or unlawful conduct.

12. Amendments

Trails may update or modify these Terms at any time. If the changes are material, Subscribers and Creators will be notified via in-app alert or email. Continued use of the Platform after changes constitutes acceptance of the amended Terms.

13. Dispute Resolution; Governing Law & Jurisdiction

These Terms and any disputes, claims, or controversies arising out of or relating to these Terms, the Platform, or any content accessed through it shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law principles.

You agree that any legal action or proceeding arising under or relating to these Terms shall be brought exclusively in the state or federal courts located in the State of Delaware, and you consent to personal jurisdiction and venue therein.

14. Contact & Notice

For any legal, compliance, or regulatory inquiries, please contact:

legal@trails.app