Published: February 6th, 2026

 

Effective: March 1st, 2026

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Welcome to Vinley, the platform operated by NexGen Value Investing Sàrl, including any associated websites, applications, tools, technology and services (the “Platform”).

 

NextGen Value Investing Sàrl, a Luxembourg limited liability company, having its registered address at 9, rue du Laboratoire, L-1911 Luxembourg, registered with the Luxembourg Trade and Companies Register under Number B294378, with VAT number LU36954012 and holding a business licence issued by the Ministry of the Economy, Directorate General for SMEs and Entrepreneurship, 19–21, boulevard Royal, L-2449 Luxembourg ((+352) 247-74700; info.pme@eco.etat.lu) (the “Company” or the “Platform Operator”) and/or its affiliated companies and subsidiaries (together the “Vinley Providers”) provide various websites, applications, tools, technology and other products and services, including mobile applications or software in connection with any of the foregoing (collectively, "Vinley Services").

 

By using the Vinley Services, you agree, on behalf of yourself, to the following conditions.

 

Please read these conditions carefully.

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1. Privacy

Please review our Privacy Notice, which also governs your use of Vinley Services, to understand our practices.

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2. Introduction and Acceptance of Terms

These Terms and Conditions (the “Terms”) govern access to and use of the Vinley Services and the Platform, through which users are granted access to an artificial intelligence-powered application designed to provide financial and investment-related information and analysis primarily grounded in value investing methodologies (the “Application”). By accessing or using the Platform, creating an account, or subscribing to any plan, the user (“User” or “you”) confirms having read, understood and agreed to be legally bound by these Terms. If you do not agree to these Terms, you must not access or use the Platform.

 

3. Regulatory Status and Scope of Services

The User acknowledges and agrees that the Platform operates solely as a technology-enabled financial information and analysis service. The Platform is not registered, licensed, authorized, or supervised by any national competent authority, such as in particular the U.S. Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), the European Securities and Markets Authority (ESMA), any EU national competent authority, the UK Financial Conduct Authority (FCA), the Luxembourg Financial Sector Supervision Commission (CSSF) or any other financial regulatory authority. The Platform does not engage in activities that constitute regulated investment services, including investment advice, portfolio management, investment research, brokerage services, or financial promotions, as those terms are defined under applicable U.S. federal securities laws, EU regulations (including MiFID II), and UK financial services legislation.

 

How we provide the Services. We commit to provide the Services to you with reasonable skill and care in the operation of the Platform, including regular internal quality assurance and control processes and act with professional diligence. We do not promise to offer the Services forever or in their current form for any particular period of time. 

 

4. Eligibility and Jurisdictional Limitations

You must be at least eighteen (18) years old or the minimum legal majority age required in your country to consent to use the Application. If you are under eighteen (18) years of age or under the age of legal majority in your jurisdiction, you must have your parents or legal guardian’s permission to use the application and ask them to read these Terms with you and agree to those Terms on your behalf. Access to or use of the Platform may be restricted or unavailable in certain jurisdictions where the provision of AI-driven financial information and analysis tools is regulated or prohibited. The User is solely responsible for ensuring that their access to and use of the Platform complies with all applicable local laws and regulations of its jurisdiction, without prejudice to any mandatory obligations applicable to the Provider.

 

5. Nature of the AI-Generated Content

The Application provides and generates financial information and analysis supported by automated artificial intelligence models that analyze historical data, publicly available information, and other proprietary and non-proprietary sources using a combination of deterministic, algorithmic, mathematical, and probabilistic techniques. All outputs are generated without human review, editorial oversight, or discretionary judgment. The Application does not consider the User’s personal financial circumstances, investment objectives, risk tolerance, or investment horizon, and does not assess suitability, appropriateness, or best interest, as such concepts are defined under SEC, ESMA, or FCA regulatory frameworks. The User is responsible for assessing whether and how their use of the Application and its outputs is compatible with any relevant AI regulatory framework requirements, including Regulation (EU) 2024/1689 on artificial intelligence, as amended, if any, in light of their specific use case.

 

6. No Investment Advice, Recommendation, or Research

Nothing on the Platform, provided by or generated by the Application constitutes or may be construed as investment advice, investment recommendations, investment research, or financial analysis for regulatory purposes. The Platform does not issue personal recommendations, advice, or research reports subject to regulatory standards on independence, objectivity, methodology, or disclosure. No content shall be construed as an offer, solicitation, inducement, endorsement, or invitation to buy, sell, or hold any security or financial instrument.

 

7. No Fiduciary, Advisory, or Client Relationship

Use of the Platform does not create any fiduciary, advisory, agency, or client relationship between the User and the Platform, its operators, or affiliates. The Platform owes no duties of loyalty, care, suitability, or best interest to the User as such concepts are defined under U.S. securities law, EU MiFID II, UK FCA rules, or any equivalent regulatory regime. All decisions made based on the Platform’s content, information or analysis provided, are made independently by the User and at the User’s sole risk.

 

8. Educational and Informational Purpose

The Platform and Application are provided exclusively for general informational and educational purposes to assist Users in understanding financial data, financial metrics, valuation frameworks and investing concepts. The content is not intended to serve as the primary basis for investment decisions and should not be relied upon as such. Users are strongly encouraged to seek advice from duly licensed financial, legal, or tax professionals before making any investment decision.

 

9. User Responsibility and Independent Judgment

The User bears full and exclusive responsibility for evaluating the relevance, accuracy, and usefulness of any content generated by the Application. The User agrees to independently verify all information and conduct their own due diligence prior to making any financial or investment-related decisions. The Platform Operator shall not be held responsible or liable for any actions taken or decisions made by the User based on any Platform or Application-generated outputs.

 

10. Artificial Intelligence Limitations and Accuracy Disclaimer

Artificial intelligence and machine learning are rapidly evolving fields of study. We are constantly working to improve our Application to make it more accurate, reliable, safe, and beneficial. The User acknowledges that artificial intelligence systems are inherently probabilistic and subject to technical and methodological limitations, including the risk of generating inaccurate, incomplete, misleading, outdated information or the so-called ‘hallucinations’. Given the nature of the technology, the Platform does not guarantee the accuracy, completeness, reliability, or timeliness of any output generated by the Application. Any references to historical performance, valuation metrics, or modeled outcomes are illustrative only and do not guarantee or predict future performance.

 

Outputs generated by the Application may be incomplete or incorrect and do not represent the Platform Operator’s views, opinions or positions. If the Platform content or output references any third party products or services, it does not mean the third party endorses or is affiliated with us.

 

11. Subscription Terms and Fees

11.1     SUBSCRIPTION

Access to the Platform is provided on a subscription basis subject to payment of applicable fees. Subscription plans, billing cycles, renewal terms, and included features are disclosed at the time of subscription and may be modified at the sole discretion of the Platform Operator within a 30-day notice period. Subscriptions renew automatically unless cancelled in accordance with the stated cancellation procedures.

 

11.2     REGISTRATION

You must provide accurate and complete information to register for an account to use our Platform. You are not allowed to share your account credentials or make your account available to anyone else and are responsible for all activities that occur under your account. If you create an account or use our Platform on behalf of another person or entity, you must have the authority to accept these Terms on their behalf.

 

11.3     CANCELLATION PROCEDURE

We may change our prices at our sole discretion with a 30-day notice period. If we increase or change our subscription prices or structure, any price increase will take effect on your next renewal so that you can cancel if you do not agree to those changes. Any such changes will not materially reduce the core functionality or essential features of an active paid subscription during the subscription term without offering the User the right to terminate.

 

12. Intellectual Property Rights

All rights, title, and interest in and to the Platform, Application, software, algorithms, artificial intelligence models, prompts, outputs, content and branding are owned by or licensed to the Platform Operator. The User is granted a limited, non-exclusive, non-transferable, revocable license to access and use the Platform solely for personal, non-commercial purposes in accordance with these Terms. Any unauthorized copying, redistribution, resale, reverse engineering, scraping, or commercial exploitation is strictly prohibited.

 

13. Prohibited and Restricted Uses

The User shall not use the Platform to provide regulated financial advice to third parties, operate or inform automated or algorithmic trading systems, create or distribute financial promotions, or engage in any activity that would require regulatory authorization under applicable securities or financial services laws. Any use of the Platform in violation of these Terms or applicable law remains the sole responsibility of the User and may result in immediate suspension or termination without any refund or compensation and without prejudice to any possible damages for the losses caused to the Platform’s Operator.

 

14. Third-Party Data and Market Information

The Platform may incorporate data, content, or information obtained from third-party providers. Such data is provided “as is” and may be delayed, incomplete, or subject to revision. While we perform regular and reasonable quality assurance and control processes, we cannot fully verify third-party data and, to the extent permitted by applicable law, we shall not be liable for errors, omissions, or interruptions arising from reliance on such sources.

 

Market data may be delayed and is not intended for trading or real-time decision-making.

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15. Investment Risk Disclosure

The User acknowledges that investing in securities and financial instruments involves significant risk, including the potential loss of some or all invested capital. Market volatility, economic conditions, issuer-specific risks and systemic factors may adversely affect investment outcomes. Value investing strategies may underperform other strategies in certain market environments. No financial outcome or performance is guaranteed.

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16. Regulatory Risk Warning

Important Risk Warning: The Platform provides AI-generated financial analysis for informational and educational purposes only. It does not provide investment advice, recommendations or personal guidance. The Application does not assess suitability or appropriateness.

 

17. Limitation of Liability

To the fullest extent permitted by applicable law, the Platform, its operators, affiliates, officers, employees and licensors shall not be liable for any direct, indirect, incidental, consequential, special or punitive damages, including investment losses or lost profits, arising out of or relating to the use of or reliance on the Platform or Application. Where liability cannot be excluded, it shall be limited to the total subscription fees paid by the User in the twelve (12) months preceding the event giving rise to the claim.

 

Nothing in these Terms limits or excludes liability for gross negligence, wilful misconduct, or any liability that cannot be excluded under applicable law.

 

18. Indemnification

The User agrees to indemnify, defend and hold harmless the Platform and its affiliates from and against any third-party claims, losses, liabilities, damages, costs, or expenses arising from the User’s misuse of the Platform, violation of these Terms, reliance on AI-generated content in a manner that is inconsistent with the disclosures, limitations, or intended use described in these Terms, or non-compliance with applicable laws or regulations to the extent such failure is attributable to the User’s conduct or use of the Platform.

 

19. Termination related rights

Your rights. You can stop using our Services and end your relationship with us at any time by simply closing your account and stopping your use of the Application.

 

EEA consumer withdrawal right. If you are an EEA-based consumer, you acknowledge and agree that, by requesting immediate access to the Application upon account creation, you will have no longer any right of withdrawal once the Services have started.

 

Our rights.  We reserve the right, acting reasonably and in good faith, to restrict, suspend, or terminate your access to the Application, or to suspend or close your account, if we determine that:

• you have breached these Terms and Conditions;

• applicable subscription fees have not been paid when due;

• such action is required to comply with applicable laws or regulatory obligations;

• your use of the Application poses, or may reasonably be expected to pose, a risk of harm to us, our users, or any third party; or

• your account has been cancelled.

 

20. Amendments

The Platform reserves the right to amend these Terms at any time to reflect changes in law, regulation, or services, security or safety reasons, circumstances beyond our reasonable control, changes we make in the usual course of developing our Services or to adapt to new technologies. Any material changes to the Terms will be communicated to Users in advance, by email or through the Platform, at least thirty (30) days before they become effective. Updated Terms will also be made available on https://www.vinley.ai/terms-conditions. Continued use of the Platform after the effective date of the revised Terms constitutes acceptance of the revised Terms.

 

Any changes will only apply to our relationship going forward. If you do not agree to the changes, you must stop using our Services.

 

21. Assignment

You may not assign or transfer any rights or obligations under these Terms. We may assign or transfer our rights or obligations under these Terms to any affiliate or subsidiary or any successor in interest of any business associated with our Services. If we do, any rights you have as a consumer will not be affected. If you are not satisfied, you have the right to terminate your relationship with us and stop using our Services at any time.

 

22. Entire Agreement

These Terms constitute the entire agreement between the User and the Platform with respect to the subject matter herein and supersede all prior agreements, representations, or understandings.

 

23. Survival

The provisions of these Terms relating to non-reliance, limitation of liability, indemnification, intellectual property and regulatory responsibility shall survive, to the extent permitted by laws, to termination of the User’s access to the Platform.

 

24. Governing Language

It is the express wish of the parties that these Conditions of Use be drawn up in English. In the event of any inconsistency, discrepancy or conflict between the English version of these Conditions of Use and their translation in another language, the English version shall prevail.

 

25. Governing Law and Mandatory Rights

By using our Platform and any Vinley Services, you agree that the laws of Luxembourg, without regard to principles of conflict of laws, will govern these Conditions of Use and any dispute of any sort that might arise between you and Vinley. If you are a consumer resident in the European Economic Area (EEA), this choice of law shall not deprive you of the protection afforded to you by mandatory provisions of the law of your country of residence.

 

Professional Users also agree that any dispute arising out of, in connection with, directly or indirectly related to the Platform will fall within the exclusive jurisdiction of the Grand Duchy of Luxembourg (“Tribunal d’arrondissement de et à Luxembourg”).

 

Consumers may bring proceedings before the courts of Luxembourg or of their place of residence, in accordance with applicable law. EEA Consumers may also use the European Commission’s online dispute resolution platform (https://ec.europa.eu/consumers/odr).

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