Terms of Service

These Terms of Service (“Terms”) form a binding agreement between you and Tengu, Inc. (“Tengu”, “we”, “our”) covering your access to and use of tengu.co, the Tengu application, the API, and every related feature (together, the “Service”). By creating an account, accessing the Service, or clicking through an acceptance screen, you agree to these Terms and to our Privacy Policy.

You must be at least 18 years old and able to enter into a binding contract under the laws of your jurisdiction. If you are using the Service on behalf of an organization, you represent that you have the authority to bind that organization, and the word “you” in these Terms refers both to you individually and to that organization. You are responsible for complying with the laws and regulations that apply to you, including those that govern who may trade specific instruments in your country of residence.

Tengu is a software platform that helps you research, monitor, and operate your own portfolio. When you connect a brokerage account, Tengu can read your positions and, on the orders you authorize, route those orders to your connected brokerage for execution. Tengu also provides AI-assisted research, portfolio analytics, watchlists, news, alerts, and a marketplace of strategies authored by third parties or by Tengu.

Tengu is not:

• a broker-dealer, custodian, or member of FINRA or SIPC;
• a registered investment adviser or financial planner;
• a bank, lender, or payment-transfer service;
• a pooled investment vehicle or issuer of securities;
• a tax, legal, accounting, or insurance professional.

Your funds and securities remain at the brokerage you connected. Tengu does not take custody of cash or assets. Where the interface uses terms like “portfolio,” “strategy,” “fund,” “capital,” or “performance,” those are product labels for software features, not references to a regulated investment product, unless we say so under a separate written agreement.

Brokerage connectivity is provided through third-party connectors such as SnapTrade, Plaid, Interactive Brokers, Kraken, and any other partner we add over time. When you authorize a connection, Tengu receives read access to your account and a scoped trade permission limited to the actions you have approved. You can revoke that authorization at any time, either inside Tengu or directly from your brokerage.

When you submit an order through Tengu, the order is forwarded to your connected brokerage for execution. The brokerage applies its own rules, eligibility checks, market-data feeds, and risk gates, and the brokerage is the entity that fills or rejects the order. Tengu’s pre-trade checks (such as position-size limits, drawdown gates, and a leverage cap) are a supplement to, not a replacement for, the protections your brokerage provides.

You acknowledge that:

• order routing depends on third-party connectivity that can be delayed, degraded, or unavailable;
• quotes, fills, balances, and holdings shown in Tengu can lag or diverge from your brokerage’s books of record, and the brokerage statement is authoritative;
• you are responsible for the orders you submit, including orders submitted through automation, scheduled jobs, or AI-assisted workflows you configure;
• tax, settlement, margin, options approval, and account-eligibility decisions are made by your brokerage, not by Tengu.

Tengu’s AI-assisted features (including Ask Tengu, chat, summaries, screens, agents, and any portfolio-aware research surface) are powered by one or more third-party model providers, which currently include OpenAI, Anthropic, Google, xAI, and Perplexity. Your prompt and any portfolio context you choose to attach may be routed to the selected provider in order to generate a response.

AI models produce content that can be wrong, incomplete, outdated, or misleading. Numerical figures, security identifiers, dates, news summaries, and inferences about your portfolio may contain errors. You must verify any output before relying on it, because the Service is not a substitute for your own analysis or for a licensed professional.

Words used in AI output such as “buy,” “sell,” “hold,” “trim,” “rotate,” “hedge,” or any equivalent are informational only and do not constitute investment advice, a recommendation, or a solicitation to enter into a securities transaction. The same is true for confidence scores, rankings, ratings, simulated returns, and back-tested results that Tengu may display.

The Tengu marketplace lets you discover, evaluate, and subscribe to strategies authored by third parties (each, an “Author”) or by Tengu. Author content (including names, descriptions, code, signals, and any performance history) is supplied by the Author, and Tengu does not endorse, guarantee, or verify it.

When you subscribe to or deploy a marketplace strategy:

• You authorize Tengu to act on signals produced by that strategy through the brokerage connection you have linked. You can pause, unsubscribe, or disconnect at any time.
• You are responsible for understanding the strategy’s logic, position-sizing, risk profile, and historical assumptions before deploying it with real capital.
• Past performance (whether live, paper, simulated, or back-tested) does not predict future results and may have been generated under conditions that differ materially from live execution.
• Tengu may share revenue with Authors. Revenue share is between Tengu and the Author. Your subscription fee is between Tengu and you.

Tengu may remove a strategy, suspend an Author, or restrict access to marketplace content at our discretion, including for terms violations, safety concerns, regulatory reasons, or operational failure.

Nothing on the Service constitutes personalized investment advice, a recommendation to buy, sell, hold, or tender any security, or an offer or solicitation to enter into any securities transaction. Even where the Service uses your portfolio, watchlist, or prompts to organize or contextualize information, that functionality does not turn Tengu into a personalized advisory program or create a fiduciary relationship.

You remain solely responsible for every investing, trading, and tax decision you make through the Service. If you need personalized advice, consult a licensed financial, tax, or legal professional.

Tengu may send you alerts, push notifications, emails, and in-product messages based on criteria you choose or criteria built into the Service. Delivery depends on third-party data feeds, connectivity, your device, and platform permissions. Alerts can be delayed, duplicated, misfired, or never delivered at all.

The fact that a feature appears to be “watching” a security, an event, or your portfolio does not create an obligation for Tengu to monitor continuously or to notify you of every relevant event. You remain solely responsible for monitoring your positions, orders, and risk.

The Service relies on market data, news, filings, fundamentals, and other content supplied by third parties. That content may be delayed, incomplete, inconsistent, or wrong. References to public figures, institutional filings, or community activity are informational only and are not endorsements. Confirm important information with primary sources (your brokerage statement, official exchange feeds, issuer filings) before acting on it.

You are responsible for the security of your account credentials, your devices, and all activity that occurs under your account. Notify us promptly at support@tengu.co if you suspect unauthorized access.

You agree not to:

• use the Service in violation of any law, regulation, exchange rule, or brokerage agreement;
• engage in market manipulation, spoofing, layering, wash trading, or other abusive conduct;
• scrape, mirror, resell, or redistribute the Service or protected content without our written consent;
• interfere with the security or integrity of the Service, attempt to gain unauthorized access, or probe for vulnerabilities outside the boundaries of our responsible-disclosure program;
• misrepresent Service output as a guarantee, an official advisory communication, or personalized professional advice;
• upload content (including in marketplace listings) that you do not have the right to share;
• use bots, scripts, or automated means in ways that burden the Service or bypass rate limits or access controls;
• reverse engineer, decompile, or extract source code, except to the limited extent permitted by applicable law.

We may set product, usage, query, API, prompt, or storage limits and may change them at any time for operational, security, or commercial reasons.

Some features require a paid subscription, a per-purchase fee, or a marketplace strategy fee. Billing may be handled by a third-party payment processor (such as Stripe, Apple, or a crypto payment provider). By purchasing, you authorize the applicable processor to charge the fees, taxes, and other amounts disclosed at checkout.

Unless we say otherwise, subscriptions renew automatically until you cancel. Cancellation stops future renewals but generally does not refund amounts already paid except where required by law or by our then-current refund policy. We may change pricing, packaging, or feature availability over time; the new price applies on a future renewal date after any required notice.

Where a purchase is governed by Apple App Store or another marketplace, that marketplace’s mandatory rules control to the extent they conflict with these Terms for the relevant purchase.

You retain ownership of the prompts, messages, watchlists, uploads, and other content you submit, to the extent you have the legal right to that content. You grant Tengu a non-exclusive, worldwide, royalty-free license to host, reproduce, process, adapt, transmit, and display your content as needed to operate, secure, improve, and support the Service.

If you give us feedback, suggestions, or ideas, we may use them without restriction or compensation to you. You consent to receive electronic communications from us relating to the Service, including account, billing, legal, and operational notices.

The Service, including our software, brand, name, logos, design, text, visual assets, and any compiled datasets or outputs protected by law, is owned by Tengu or its licensors. We grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Service in accordance with these Terms. All other rights are reserved.

The Service depends on and may link to third-party services, including SnapTrade, Plaid, Interactive Brokers, Kraken, Stripe, Apple, OpenAI, Anthropic, Google, xAI, Perplexity, market-data vendors, and any other provider we add over time. Your use of those services may also be governed by their own terms, policies, and consents. Tengu does not control those services and is not responsible for their accuracy, availability, security, billing, regulatory status, or outcomes.

To the maximum extent permitted by law, the Service is provided “as is” and “as available”, without warranties of any kind, whether express, implied, or statutory, including warranties of merchantability, fitness for a particular purpose, title, non-infringement, accuracy, completeness, or that the Service will be uninterrupted, secure, or error-free. Tengu does not warrant that the Service is suitable for trading, investing, tax, legal, accounting, or compliance purposes, and you assume the entire risk of using it.

To the maximum extent permitted by law, Tengu and its affiliates, officers, directors, employees, contractors, licensors, and service providers will not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages, or for any loss of profits, revenue, goodwill, data, business opportunity, trading opportunity, or investment value, arising out of or related to the Service. This applies even if Tengu has been advised of the possibility of such damages.

Without limiting the previous sentence, Tengu will not be liable for losses arising from: investment or trading decisions; orders that do not execute, partially execute, or execute outside your expected price; delayed, incorrect, or missing market data; AI output; alerts or notifications that are delayed or not delivered; service interruptions; third-party connectivity failures (SnapTrade, Plaid, Interactive Brokers, Kraken, or any other connector); marketplace-strategy performance; account compromise; or any third-party service.

To the extent permitted by law, Tengu’s aggregate liability for all claims arising out of or relating to the Service will not exceed the greater of (a) the amount you paid Tengu for the Service in the twelve months before the event giving rise to the claim, and (b) one hundred U.S. dollars. Nothing in these Terms limits liability that cannot be limited under applicable law.

You will defend, indemnify, and hold Tengu and its affiliates, officers, directors, employees, contractors, licensors, and service providers harmless from any claim, demand, action, liability, judgment, loss, or expense (including reasonable attorneys’ fees) arising out of or related to: your use of the Service; your content; orders you submit through the Service; your violation of these Terms; or your violation of any law or third-party right.

We may modify, suspend, or discontinue any part of the Service at any time. We may suspend or terminate your access if we believe you have violated these Terms, created risk for Tengu or others, or as required for legal, security, or operational reasons. We may update these Terms from time to time; the updated version takes effect when we post it, unless a later effective date is specified. Provisions that by their nature should survive termination (including those covering intellectual property, disclaimers, liability limits, indemnification, and dispute terms) will survive.

These Terms are governed by the laws of the State of Delaware, without regard to its conflict-of-laws rules. To the extent a dispute is permitted to proceed in court, you and Tengu agree to the exclusive jurisdiction and venue of the state and federal courts located in Delaware, except where applicable law requires otherwise. Nothing in this section limits the right of either party to seek equitable relief in any court of competent jurisdiction.

These Terms, together with our Privacy Policy, Cookie Policy, and Disclosures, form the entire agreement between you and Tengu regarding the Service. If any provision is held unenforceable, the remaining provisions remain in full force and effect. Our failure to enforce a provision is not a waiver of it. You may not assign these Terms without our prior written consent; Tengu may assign them in connection with a merger, acquisition, financing, or sale of assets.

Questions about these Terms: support@tengu.co. Security reports: support@tengu.co.