Disclaimer

1. Not investment advice (MiFID II)

HoldTrakr is an information platform. The information on this platform — including returns, positions, trades and creator analyses — is intended solely as information and does not in any way constitute investment advice, an investment recommendation, or an offer to buy or sell financial instruments within the meaning of applicable financial regulations including MiFID II (2014/65/EU).

HoldTrakr is not registered as an investment firm with the Dutch Authority for the Financial Markets (AFM) and does not provide asset management, investment advice, or order execution. All decisions you make based on information on this platform are your own responsibility.

2. Past performance is no guarantee

All returns shown on this platform are historical results. Past performance does not guarantee future results. Investing involves risks, including the risk of losing your entire investment.

The returns shown are calculated based on broker data uploaded by creators. HoldTrakr verifies the consistency and plausibility of this data but does not guarantee absolute accuracy.

3. Limitation of liability

HoldTrakr B.V. (in formation) is not liable in any way for direct or indirect damage arising from the use of information on this platform, including but not limited to investment losses, lost profits or other financial disadvantages.

HoldTrakr is also not liable for damage caused by technical malfunctions, incorrect or incomplete creator data, or errors in return calculations insofar as these are beyond our reasonable control.

4. Verification system — what it does and does not guarantee

HoldTrakr uses a four-tier verification system (Tier 0 to 3). Verification means that the broker data uploaded by a creator is internally consistent and matches publicly available market data. Verification is not an audit by an external auditor or investment institution.

Verification does guarantee:

• Internal consistency of uploaded data (dates, prices, calculations)
• Alignment with historical market prices (OHLC range)
• That the displayed returns are calculated from the uploaded data

Verification does not guarantee:

• That the broker data is complete and unmanipulated
• That future returns will be comparable
• The suitability of a creator as an investment reference for your personal situation

5. Governing law

This disclaimer and the use of this platform are governed by Dutch law. Disputes shall be submitted to the competent court in the district of Amsterdam.