User agreement

Sep 30, 2022
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If you decide to invest in one of Twenties Research’s ideas and lose all your money, don’t blame me. I am just a guy in his twenties posting stuff on the internet and you should know better. Now I let legal do the talking.

1. GENERAL

1.1. Services on this website are provided by Twenties Ventures OÜ (registry code 16291413), address Narva mnt 7, 10117 Tallinn, Estonia (hereinafter the Service Provider). The purpose of the following provisions in this user agreement (hereinafter the Agreement) is to govern legal relationship between the Service Provider and subscriber (hereinafter the User). The Agreement applies to the use of the Website and services provided by the Service Provider.

1.2. The term “You” in the context of the Agreement refers to the User.

1.3. Services refer to providing access to a Website, where Users are able to read publications, articles, and other written resources on the topic of financial investments and the markets associated with these.

1.4. Website is a platform where the services are provided by the Service Provider.

1.5. You confirm that you have read all the terms herein and agree that you have clearly understood and accepted the Agreement and in case You do not agree or fail to comply with the conditions herein, You are not entitled to engage in establishing a business or customer relationship with the Service Provider nor use the services or the Website.

1.6. You understand that when it comes to investing there are no certainties, only probabilities. No matter how much work went into an idea, it might not pan out as expected. All you can do as investors is put the odds on your side by following sound investment principles. The user should be aware that trading stocks and all other financial instruments involves risk. Past performance is no guarantee of future results, and the Service Provider does not claim that their research will lead to profits. Twenties Ventures OÜ will not be liable for any financial loss incurred by the user arising from one of its recommendations.

1.7. The Service Provider’s analysis may contain errors and the User shouldn’t make any investment decision based solely on what they read on the Website, social media or other medium. It’s the User’s money and their responsibility so the User must do their own due diligence. All investment decisions that the User makes are theirs alone, Twenties Ventures OÜ or any of its employees and agents will not be liable for any losses the Users may incur.

1.8. Twenties Ventures OÜ is a publishing company and all of the content on the Service, premium or free, is provided for informational and educational purposes only and should not be construed as personalised investment advice. The Service Provider is a research firm: not a registered investment adviser; not an independent financial adviser; not a financial planner. Therefore, the provided recommendations may not be suitable for the User’s individual situation and goals. Recommendations do not take into account the individual situation of the User. Every User receives the same newsletter regardless of their personal circumstances. Services provided on the platform can not be deemed as an investment services pursuant to Securities Market Act of Estonia § 43.

1.9. Personal data is any information that relates to an identified or identifiable individual.

1.10. Cookies are data generated by a website and saved by User’s web browser. Its purpose is to remember information about you, similar to a preference file created by a software application.

1.11. Device could be any device with internet that can access the service such as a mobile phone, a computer or a digital tablet.

1.12. The Service Provider communicates, forwards requests and contacts the User via email correspondence, in urgent cases that need immediate attention and/or action the Service Provider may contact the User by telephone, if provided.

2. RESTRICTIONS AND AGE REQUIREMENT

2.1. You agree not to, and You will not permit others to:

2.1.1. license, sell, rent, lease, assign, distribute, transmit, host, outsource, disclose or otherwise commercially exploit the Website or make the platform available to any third party;

2.1.2. modify, make derivative works of, disassemble, decrypt, reverse compile or reverse engineer any part of the Website;

2.1.3. remove, alter or obscure any proprietary notice (including any notice of copyright or trademark) of the Service Provider or its affiliates, partners, suppliers or the licensors of the Website;

2.1.4. use the Website in any way that violates national and/or international applicable laws and regulations;

2.1.5. introduce any viruses, trojan horses, logic bombs, worms or other material which is malicious or technologically harmful;

2.1.6. attempt to gain unauthorized access to, interfere with, damage or disrupt any parts of the Website, the server on which the Website is stored, or any server, computer or database connected to the Website.

2.2. The Service Provider is a limited liability company registered in Estonia. Access to the Website or services offered on the Website by certain persons or in certain countries may be contrary to the law. It is the User’s responsibility to determine whether the use of the Website and/or services offered on the Website comply with the local applicable regulations.

2.3. By using the Website and services provided through the Website, the User warrants that he/she:

​2.3.1. is 18 years old or older;

2.3.2. is of legal age in the User’s jurisdiction and place of residence.

2.4. The User is not entitled to use a right of withdrawal of 14 days from the Agreement nor from transactions governed by the Agreement for providing services on the Website according to the Law of Obligations Act § 53 subsection 4.

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3. REGISTRATION AND THE ACCOUNT

3.1. Upon registering account for using the services (hereinafter the Account) and when using the services, the User agrees to provide the Service Provider the following data:

3.1.1. first name and surname;

3.1.2. e-mail address;

3.1.3. residential address;

3.1.4. other data that is required to be collected and verified by the Service Provider according to the requirements of the jurisdiction and legislation of residence of the Service Provider;

3.1.5. based on the request of the Service Provider, the User may be obliged to submit additional documents and in a requested format, to ensure that the Service Provider meets the requirements derived from the jurisdiction and legislation of residence of the Service Provider;

3.1.6. optionally the User may also submit their telephone number.

3.2. The User warrants that:

​3.2.1. he/she is the only person authorized to use the Account and shall not share the credentials that are used to access the Account with any other person and the User shall do everything within his/her power to prevent access of any other persons to the Account and is solely responsible for maintaining the confidentiality and security of the credentials of the Account;

3.2.2. that data provided to the Service Provider for registering account is true, current and complete and the User is aware of the consequences arising from the submission of inaccurate data;

3.2.3. he/she notifies the Service Provider if there are any changes or amendments in the personal data provided to the Service Provider.

3.2.4. the Account shall not be used for illegal activities;

3.2.5. the Service Provider shall be notified immediately if the User has reasons to believe that the Account has been stolen, used for illegal activities or the User is not able to access the Account due to unknown reasons;

3.2.6. he/she will cooperate with the Service Provider in a full capacity and timely manner within the process of gathering information and documents related to the User’s identification and personal data in cases provided in the provisions of 3.2.4 and 3.2.5 of the Agreement;

3.2.7. he/she has given a consent to transfer personal data to third party service providers that the Service Provider is using related to the fulfilment of its obligations and necessary features for seamless service provision.

​3.3. The Service Provider reserves the right to decide whether to open the Account and conduct service provision without providing any justification or reasoning for a rejection.

3.4. The Service Provider reserves the right in its sole and absolute discretion, without providing any justification or reasoning, to refuse to open, suspend or close the Account and/or limit access to the Website and services, especially in cases, including but not limited:

​3.4.1. the User has provided the Service Provider personal data or information that is requested in relation to fulfilment of obligations derived from the requirements of the jurisdiction and legislation of residence of the Service Provider, and such personal data and information is untrue, false or expired;

3.4.2. the User fails to provide or update personal data accordingly, also upon request of the Service Provider;

3.4.3. the User fails to respond to the Service Provider’s requests;

3.4.4. due to suspicious activity that may relate to any unlawful activity;

3.4.5. the Account is being used by any person other than the User;

3.4.6. due to technical errors.

3.5. The Service Provider reserves the right to immediately close the Account, limit access to the Website and terminate the Agreement with the User without any prior notification or reasoning, if the Service Provider has reasons to believe that the account is being used for any unlawful activity.

4. SERVICES 

4.1. The Service Provider undertakes to provide the following services through the Website:

4.1.1. Newsletters – the service of providing longer publications called Newsletters, each of which provides research notes about actionable investment opportunities, which mostly cover individual stock ideas but are not limited to any one asset class or market;

4.1.2. Articles – the service of providing shorter publications called Articles, which mostly cover news items and the general state of the market;

4.1.3. Resources – the service of providing materials, which are educative in nature, providing general knowledge and tools for investing and trading to the User.

4.2. The Service Provider will facilitate orders, transactions and other actions necessary for the service provision with professional care, due diligence and according to its best knowledge.

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5. PAYMENTS

5.1. Upon registering and using the services on the Website the User agrees to pay all fees or charges that arise from or using the services. You will find all fees related to the use of the Website and services from here once a paywall is put up.

5.2. The Service Provider reserves the right at any time to change its prices and billing methods, either immediately upon posting on the Website or by e-mail delivery to the Users. Any attorney fees, court costs, or other costs incurred in collection of delinquent undisputed amounts shall be the responsibility of and paid for by the User.

5.3. The User is responsible for any third-party fees that the User may incur when using the Service.

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6. CHANGES AND MODIFICATIONS TO THE AGREEMENT AND THE WEBSITE

6.1. The User acknowledges and agrees that the Service Provider can at its sole discretion decide to change, modify, replace or update the Agreement at any time. If a revision is material, the Service Provider will provide at least 30-day notice prior to any new terms taking effect. What constitutes a material change will be determined at the Service Provider’s sole discretion.

6.2. The User, by continuing to access or use the Website after any revisions become effective, agrees to be bound by the revised terms. If the User does not agree to the new terms, the User is no longer authorized to use the Website or services.

6.3. The Service Provider reserves the right to modify, suspend or discontinue, temporarily or permanently, the Website or any service to which it connects, without prior notice and without liability to the User.

6.4. The Service Provider may from time to time provide enhancements or improvements to the features/ functionality of the Website, which may include patches, bug fixes, updates, upgrades and other modifications.

6.5. Updates may modify or delete certain features and/or functionality of the Website. The User agrees that the Service Provider has no obligation to provide any updates or continue to provide or enable any particular features and/or functionalities of the website to the User.

6.6. The User agrees that all updates will be deemed to constitute an integral part of the Website and subject to the provisions of this Agreement.

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7. THIRD PARTY SERVICES

​7.1. The Service Provider may display, include or make available third-party content (including data, information, applications and other products/services) or provide links to third-party websites or services or use third parties in conducting its business (hereinafter Third-Party Services).

7.2. The User acknowledges and agrees that the Service Provider shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof, unless related to the fulfilment of the Service Provider’s lawful obligations on personal data processing. The Service Provider does not assume and shall not have any liability or responsibility to the User or any other person or entity for any Third-Party Services.

7.3. Third-Party Services and links thereto are provided solely for convenience to the User and the User access and use them entirely at the User’s own risk and subject to such third parties’ terms and conditions.

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8. TERM AND TERMINATION OF THE AGREEMENT

8.1. This Agreement shall remain in effect until terminated by the User or the Service Provider.

8.2. The Service Provider may, in its sole discretion, at any time and for any or no reason, suspend or terminate this Agreement with or without prior notice.

8.3. This Agreement will be terminated immediately, without prior notice from the Service Provider in the event that the User fails to comply with any provision of this Agreement. 

8.4. Termination of this Agreement will not limit the Service Provider’s rights or remedies at law or in equity in case of breach by the User (during the term of this Agreement) of any of the User’s obligations under the present Agreement.

8.5. The User is entitled to terminate this Agreement at any time by requesting the Service Provider to close the Account by sending a written notice to twentiesresearch@substack.com, or by logging in to the platform and submitting the request there. The Service Provider shall not close the Account in case there is an open investigation by a regulatory authority.​

8.6. In case of the User wishing to terminate this Agreement, the Service Provider reserves the right to refuse any claims of refund for the User’s unused portion of any paid fees.​

8.7. In case the Agreement is terminated pursuant to the Service Provider ceasing to provide Services pursuant to this Agreement, the User will be refunded on a pro rata principle for the time they would be unable to use the Services already paid for.

8.8. The Service Provider reserves the right to restrict access if there are reasons to suspect or believe that the Account has been or is being used as described in the provisions 3.2.4, 3.2.5 and 3.2.6 or there is an open investigation by a regulatory authority.​

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9. INDEMNIFICATION

You agree to indemnify and hold the Service Provider and its parents, subsidiaries, affiliates, officers, employees, agents, partners and licensors (if any) harmless from any claim or demand, including reasonable attorneys’ fees, arising out of the User’s use of the website or violation of any right of a third party.

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10. NO WARRANTIES

10.1. The Website is provided to You “as is” and “as available” and with all faults and defects without warranty of any kind.

10.2. To the maximum extent permitted under applicable law, the Service Provider, on its own behalf and on behalf of its affiliates and its and their respective licensors and service providers, expressly disclaims all warranties, whether expressed, implied, statutory or otherwise, with respect to the website, including all implied warranties or merchantability, fitness for a particular purpose, title and non-infringement, and warranties that may arise out of course of dealing, course of performance, usage or trade practice.

10.3. Without limitation, the Service Provider provides no warranty or undertaking, and makes no representation of any kind that the Website will meet the User’s requirements, achieve any intended results, be compatible or work with any other software, systems or services, operate without interruption, meet any performance or reliability standards or be error free or that any errors or defects can or will be corrected.

10.4. Without limitation, the Service Provider shall not make any representation or warranty of any kind, expressed or implied:

​10.4.1. as to the operation or availability of the Website, or the information, content, and materials or products included thereon;

10.4.2. that the Website will be uninterrupted or error-free;

10.4.3. as to the accuracy, reliability, or currency of any information or content provided through the Website;

10.4.4. that the Website, its servers, the content, or e-mails sent from or on behalf of the Service Provider are free of viruses, scripts, trojan horses, worms, malware, timebombs or other harmful components.

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11. LIMITATION OF LIABILITY

11.1. Notwithstanding any damages that the User might incur, the entire liability of the Service Provider and any of its suppliers under any provision of this Agreement and the User’s exclusive remedy for all of the foregoing shall be limited to the amount actually paid by the User for the use of the Website and the services contained therein.

11.2. To the maximum extent permitted by applicable law, in no event shall the Service Provider or its suppliers be liable for any special, incidental, indirect, or consequential damages whatsoever (including, but not limited to, damages for loss of profits, for loss of data or other information, for business interruption, for personal injury, for loss of privacy arising out of or in any way related to the use of or inability to use the Website, third-party software and/or third-party hardware used with the Website, or otherwise in connection with any provision of this Agreement), even if the Service Provider or any supplier has been advised of the possibility of such damages and even if the remedy fails of its essential purpose.

11.3. The Service Provider is not responsible for any financial loss incurred by the User arising from one of the recommendations provided by the Service Provider.

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12. FORCE MAJEURE

The Service Provider is not held responsible to fulfil or to partially fulfil any obligations under this Agreement if such failure has occurred as a result of any abnormal or unforeseeable circumstance outside the Service Provider’s reasonable control and that could not be envisaged, escaped, or eliminated, including but not limited to governmental action and acts that have affected the activities of the Service Provider, political unrest, strikes, declared and undeclared wars and acts of God.

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13. SEVERABILITY

​If any provision of this Agreement is held to be unenforceable or invalid, such provision will be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law and the remaining provisions will continue in full force and effect.

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14. WAIVER

​Except as provided herein, the failure to exercise a right or to require performance of an obligation under this Agreement shall not affect a party’s ability to exercise such right or require such performance at any time thereafter nor constitute waiver of any subsequent breach.

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15. PRIVACY POLICY

​In order to operate the Website, the Service Provider employs third party service providers that may process personal data for the purpose of providing services (e.g. facilitating transactions and processing personal data) and/or for the purpose of complying with legal obligations. The Service Provider undertakes to adhere to best practices and principles of personal data processing, compliant with all applicable legislation, including the European Union General Data Protection Regulation. Any personal data processed shall be processed in a fair and transparent manner. The Service Provider limits the amount of personal data collected to what is required for efficient operation of the Website. The Service Provider implements security measures necessary to ensure the confidentiality, security and integrity of collected personal data.

​Details on how personal data is collected, stored, secured and processed is described in the Privacy Policy of the Service Provider which is an integral part of the basis for the service provision.

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16. DISCLAIMER

16.1. The Service Provider is not responsible for any content, code or any other imprecision. 

​16.2. The Service Provider does not provide warranties or guarantees.

​16.3. In no event shall the Service Provider be liable for any special, direct, indirect, consequential, or incidental damages or any damages whatsoever, whether in an action of contract, negligence or other tort, arising out of or in connection with the use of the Website or services or the contents of the Website or services.

​16.4. The Service Provider reserves the right to make additions, deletions, or modifications to the contents on the Website and services at any time without prior notice.

16.5. The Service Provider may write an annual report to review the performance of the securities selected in the newsletter. This report will not be audited or account for costs such as fees, taxes and FX rates. Past performance does not guarantee future returns. The Service Provider may track the performance of the recommended investments and will do so for guidance purposes only. Users investing in these securities may receive varying results.

16.6. Authors of the publications provided in the Service may have a financial interest in any security they recommend. In such an event, the User shall be informed of this. 

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17. FINAL PROVISIONS

​17.1. The Agreement constitutes the entire agreement between the User and the Service Provider regarding use of the Website and services, and supersedes all prior and contemporaneous written or oral agreements between the User and the Service Provider.

​17.2. All matters relating to the Website or any particular services offered on the Website and all matters related to the Agreement and any claims or disputes arising therefrom or related thereto, shall be governed by the laws of Estonia without giving effect to any choice or conflict of law provision or rule.

​17.3. The Harju County Court shall have an exclusive jurisdiction to solve any disputes or claims if it is not possible to settle them in an extrajudicial manner or by a negotiation.

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The Service Provider presumes that the User has understood and accepted the current “User Agreement”, “Privacy policy” and “Terms and Conditions” before using the Website and services.