IMPORTANT DISCLOSURES


Effective Date: January 1, 2024


PLEASE READ THESE DISCLOSURES CAREFULLY. THEY CONTAIN IMPORTANT INFORMATION ABOUT THE LIMITATIONS AND RISKS ASSOCIATED WITH SUPREME.PM'S SERVICES.


1. REGULATORY DISCLOSURES


1.1 Not a Registered Investment Advisor

SUPREME.PM, INC. IS NOT REGISTERED AS AN INVESTMENT ADVISOR WITH THE SECURITIES AND EXCHANGE COMMISSION OR ANY STATE SECURITIES REGULATOR.


1.2 Not a Broker-Dealer

WE ARE NOT A BROKER-DEALER, FINANCIAL INSTITUTION, OR FIDUCIARY. WE DO NOT EXECUTE TRADES OR HOLD CUSTOMER ASSETS.


1.3 Information Service Only

WE PROVIDE INFORMATION AND TOOLS BASED ON PUBLICLY AVAILABLE DATA. OUR SERVICE IS LIMITED TO EDUCATIONAL AND INFORMATIONAL PURPOSES.


2. NO INVESTMENT ADVICE


2.1 DISCLAIMER.: NOTHING IN OUR SERVICE CONSTITUTES:

  • Investment advice or recommendations
  • Solicitation to buy or sell securities
  • Personal financial planning
  • Tax or legal advice
  • Fiduciary services of any kind

  • 2.2 INDEPENDENT DECISION MAKING. ALL INVESTMENT DECISIONS ARE YOUR SOLE RESPONSIBILITY. YOU SHOULD CONSULT QUALIFIED PROFESSIONALS BEFORE MAKING INVESTMENT DECISIONS.


    3. INVESTMENT RISK DISCLOSURES


    3.1 GENERAL RISKS.: ALL INVESTMENTS INVOLVE RISK, INCLUDING:

  • COMPLETE LOSS OF PRINCIPAL
  • MARKET VOLATILITY
  • LIQUIDITY CONSTRAINTS
  • ECONOMIC DOWNTURNS
  • GEOPOLITICAL EVENTS

  • 3.2 NO GUARANTEES.: WE DO NOT GUARANTEE:

  • Investment returns
  • Preservation of capital
  • Achievement of investment objectives
  • Accuracy of models or data
  • Future performance

  • 4. MODEL LIMITATIONS


    4.1 Data Limitations

  • Models based on quarterly 13F filings with 45-day reporting delays
  • Holdings data may be incomplete or aggregated
  • Short positions not included
  • International holdings may be underreported
  • Data processing errors may occur

  • 4.2 Performance Limitations

  • **HYPOTHETICAL PERFORMANCE ONLY**
  • Past performance does not predict future results
  • Actual results will differ from models
  • Models cannot capture all market factors
  • Timing differences affect outcomes

  • 4.3 Technical Limitations

  • Models are approximations only
  • Cannot replicate exact fund strategies
  • Subject to data quality issues
  • May not reflect all holdings or transactions
  • Updates may be delayed

  • 5. CONFLICTS OF INTEREST


    5.1 Potential Conflicts.: We may have business relationships or financial interests that create conflicts, including:

  • Analysis of funds in which employees invest
  • Compensation from data providers
  • Future business partnerships

  • 5.2 Mitigation. We maintain policies to address conflicts but cannot eliminate all potential conflicts.


    6. FEES AND COSTS


    6.1 Our Fees. Subscription fees as posted on our website.


    6.2 Additional Costs.: You are responsible for:

  • Brokerage commissions
  • Taxes on investment gains
  • Currency conversion fees
  • Other transaction costs

  • 6.3 No Hidden Fees. We do not receive compensation from funds or securities we analyze.


    7. TAX DISCLOSURE


    7.1 NO TAX ADVICE. We do not provide tax advice. Investment decisions have tax consequences that vary by individual situation.


    7.2 YOUR RESPONSIBILITY. You are solely responsible for tax obligations arising from investment activities.


    8. LEGAL DISCLAIMERS


    8.1 Accuracy

    NO WARRANTY OF ACCURACY. While we strive for accuracy, we do not warrant that information is accurate, complete, or current.


    8.2 Suitability

    NO SUITABILITY DETERMINATION. We do not assess whether any investment or strategy is suitable for your circumstances.


    8.3 Professional Advice

    CONSULT PROFESSIONALS. Always consult qualified financial, legal, and tax professionals.


    9. FORWARD-LOOKING STATEMENTS


    Any forward-looking statements are based on current expectations and involve risks and uncertainties. Actual results may differ materially.


    10. INTELLECTUAL PROPERTY


    10.1 Proprietary Information. Our models, algorithms, and methods are proprietary and confidential.


    10.2 Limited Use. Information provided is for your personal, non-commercial use only.


    11. INDEMNIFICATION


    YOU AGREE TO INDEMNIFY AND HOLD HARMLESS SUPREME.PM FROM ANY LOSSES ARISING FROM YOUR INVESTMENT DECISIONS OR USE OF OUR SERVICE.


    12. LIMITATION OF LIABILITY


    OUR LIABILITY IS LIMITED AS SET FORTH IN OUR TERMS OF SERVICE. WE ARE NOT LIABLE FOR ANY INVESTMENT LOSSES.


    13. INTERNATIONAL USERS


    13.1 U.S. Service. Our Service is designed for U.S. users and may not comply with laws of other jurisdictions.


    13.2 Your Responsibility. International users are responsible for compliance with local laws.


    14. CHANGES TO DISCLOSURES


    We may update these disclosures at any time. Continued use constitutes acceptance of updated disclosures.


    15. SEVERABILITY


    If any provision is invalid, the remaining provisions shall continue in effect.


    16. CONTACT INFORMATION


    Compliance Inquiries

    Supreme.PM, Inc.

    Email: [email protected]


    Legal Department

    Email: [email protected]


    BY USING SUPREME.PM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND ACCEPTED ALL RISKS AND LIMITATIONS DESCRIBED IN THESE DISCLOSURES.