Terms of Service

Our website and services are intended solely for adults who have the legal capacity to enter into binding contracts. By using our website, you confirm that you are at least 18 years of age, meet the legal requirements in your jurisdiction, and agree to these Terms in full.

GemAlgo provides access to a systematic, automated equities algorithm ("Orion") that executes trades within your own U.S. regulated brokerage account. GemAlgo is a software and technology company. We are not a registered investment advisor, broker-dealer, or financial institution.

Our services include:

• Access to the Orion automated equities algorithm
• Account setup and onboarding support
• Performance reporting and transparency tools
• Ongoing technical support and system maintenance

GemAlgo does not provide personalized investment advice, financial planning, tax advice, or legal counsel. Nothing on our website, in our communications, or through our services constitutes an offer to sell securities, a solicitation to buy securities, or a recommendation of any specific investment strategy.

You are solely responsible for determining whether GemAlgo's services are appropriate for your financial situation, investment objectives, and risk tolerance. We strongly encourage you to consult a qualified registered investment advisor, attorney, or tax professional before making any investment decision.

Past performance data presented on our website or through our services is not indicative of future results. All performance figures are for informational purposes only.

Investing in equities involves substantial risk, including the possible loss of some or all capital invested. You should not allocate capital you cannot afford to lose. Specific risks include but are not limited to:

• Market risk — equity values can decline significantly and rapidly
• Systematic risk — algorithmic strategies may underperform or experience drawdowns
• Technology risk — system outages, connectivity issues, or API failures may affect performance
• Liquidity risk — positions may not always be exited at desired prices
• Regulatory risk — changes in regulations may affect strategy operation

GemAlgo does not guarantee any specific level of performance, return, or capital preservation. All performance data presented reflects historical results that may not be repeated.

GemAlgo connects to your personal Interactive Brokers brokerage account via API for the sole purpose of executing trades. At no point does GemAlgo hold, custody, pool, or control your funds. You maintain full ownership and control of your brokerage account at all times.

By using our services, you acknowledge and agree that:

• You are responsible for maintaining your brokerage account in good standing
• You are responsible for ensuring sufficient capital is maintained in your account
• You are responsible for all brokerage fees, commissions, and costs associated with trading
• GemAlgo's API access is limited to trade execution only — we cannot withdraw or transfer funds from your account

A minimum of $25,000 in available capital is required to access GemAlgo's services. This minimum must be maintained in your connected brokerage account at all times during active use of the algorithm. Falling below this minimum may affect system performance and is grounds for suspension of services.

All content on gemalgo.com — including but not limited to text, graphics, data, performance reports, strategy documentation, software, algorithms, and branding — is the proprietary intellectual property of GemAlgo LLC and is protected by applicable copyright, trademark, and trade secret laws.

You may not copy, reproduce, distribute, modify, reverse engineer, or create derivative works from any GemAlgo content without our prior written consent. Unauthorized use of our intellectual property may result in legal action.

The Orion algorithm, its signal architecture, factor weightings, and optimization methodology are confidential proprietary systems. You agree not to attempt to reverse engineer, replicate, or disclose any aspect of the algorithm's proprietary construction.

To access our services you will be required to create an account. By doing so, you agree to:

• Provide accurate, complete, and current information
• Maintain the security and confidentiality of your account credentials
• Notify us immediately of any unauthorized access or security breach
• Accept full responsibility for all activity conducted under your account
• Maintain only a single account

GemAlgo reserves the right to suspend or terminate your account at its discretion for violation of these Terms or for any conduct we deem harmful to our platform, other users, or our services.

You agree to use GemAlgo's website and services only for lawful purposes and in accordance with these Terms. You agree not to:

• Use our services in violation of any applicable law or regulation
• Attempt to gain unauthorized access to any portion of our systems
• Interfere with or disrupt the operation of our website or services
• Use automated tools to scrape, harvest, or extract data from our website
• Misrepresent your identity or financial information
• Share, transfer, or sublicense your account access to any third party
• Use our services for any purpose other than personal algorithmic trading within your own brokerage account

Access to GemAlgo's services requires payment of a license fee as specified at the time of enrollment. All fees are:

• Denominated in U.S. Dollars
• Due at the time specified in your enrollment agreement
• Non-refundable except as expressly provided in Section 11

We accept major U.S. issued credit and debit cards including Visa, MasterCard, American Express, and Discover. By submitting payment information, you represent that you are authorized to use the payment method provided and that all payment information is accurate and complete.

GemAlgo is not responsible for any fees or charges applied by your bank or card issuer in connection with payments made to us.

11.1 Guarantee Overview

GemAlgo offers a twelve (12) month satisfaction guarantee on the initial license fee. If, after twelve consecutive months of compliant use, you are not satisfied with the service, you may request a refund of the initial license fee minus any net profits earned during that period.

11.2 Guarantee Period

The twelve month period begins on your enrollment date. Refund requests must be submitted within seven (7) calendar days of the guarantee period's expiration. Requests submitted before the period ends or after the seven day window will not be processed.

11.3 Conditions

The guarantee is valid only if all of the following conditions are met continuously throughout the twelve month period:

• The algorithm remains connected and actively trading — defined as executing a minimum of two trades per calendar month
• You have not modified, tampered with, or overridden any system settings or risk parameters
• You have operated the system exclusively on approved brokerage platforms via approved API connections
• You have maintained a minimum of $25,000 in trading capital at all times
• You have applied all system updates within five business days of release
• You can provide complete, verifiable brokerage account statements for the entire period upon request

11.4 Refund Calculation

Eligible refunds equal the initial license fee paid minus any net profits realized during the twelve month period. If net profits equal or exceed the license fee, no refund will be issued.

Example: If the license fee was $10,000 and net profits were $4,000, the refund would be $6,000.

11.5 Exclusions

The guarantee does not apply to losses or underperformance caused by third-party service outages, force majeure events, market halts, regulatory actions, or client negligence including failure to maintain API connectivity, VPS uptime, or adequate account capital.

11.6 How To Request

Submit your request and supporting brokerage documentation to support@gemalgo.com within the applicable window. Approved refunds will be processed within thirty (30) days of verification.

You expressly agree not to initiate chargebacks or payment disputes with your bank or card issuer for fees paid to GemAlgo. Initiating a chargeback constitutes a material breach of this Agreement and may result in immediate termination of your account and pursuit of the full amount owed through collections or legal action.

Your use of our website and services is also governed by our Privacy Policy, which is incorporated into these Terms by reference. Please review it carefully.

Our services integrate with third-party platforms including Interactive Brokers. We are not responsible for the availability, accuracy, or conduct of any third-party service. Your use of third-party platforms is governed by their respective terms of service and privacy policies, which we encourage you to review carefully.

Our website may also contain links to external websites. GemAlgo is not responsible for the content, privacy practices, or terms of any external website.

GemAlgo maintains a presence on various social media platforms. Content posted on our social media channels is for informational purposes only and does not constitute investment advice. User comments and opinions expressed on our social media channels do not reflect the views of GemAlgo. We are not responsible for the content, terms, or privacy practices of any social media platform.

18.1 Informal Resolution

Before initiating any formal dispute, you agree to contact GemAlgo in writing with a description of the dispute and proposed resolution. Send written notice to: support@gemalgo.com or GemAlgo LLC, Attn: Legal Department, 1712 Pioneer Ave Suite 500, Cheyenne, WY 82001. Both parties agree to negotiate in good faith for a period of sixty (60) days before pursuing arbitration.

18.2 Binding Arbitration

If informal resolution fails, any and all disputes arising from or related to these Terms or our services shall be resolved through final and binding confidential arbitration before a single arbitrator of the American Arbitration Association (AAA), governed by the AAA's Commercial Dispute Resolution Procedures.

BY AGREEING TO ARBITRATION YOU WAIVE YOUR RIGHT TO A JURY TRIAL AND YOUR RIGHT TO PARTICIPATE IN ANY CLASS ACTION.

18.3 Exceptions

The following are exempt from mandatory arbitration and may be brought in courts of competent jurisdiction:

• Claims properly filed in small claims court on an individual basis
• Actions by GemAlgo to protect intellectual property rights
• Actions seeking temporary injunctive or emergency relief

18.4 Class Action Waiver

All disputes must be brought in your individual capacity only. You may not bring claims as a plaintiff or class member in any class or representative proceeding. If this waiver is deemed unenforceable, the entire arbitration provision shall be void.

18.5 Time Limitation

Any claim must be initiated within one (1) year of the date the claim arose, including the informal resolution period. Claims not brought within this period are permanently barred.

18.6 Location & Governing Law

Arbitration shall be conducted in Cheyenne, Wyoming unless otherwise agreed. The arbitrator shall apply the substantive law of the State of Wyoming without regard to conflict of law principles.

18.7 Opt-Out

You may opt out of this arbitration provision by sending written notice to GemAlgo within thirty (30) days of first using our services. Your opt-out notice must be sent to: GemAlgo LLC, Attn: Legal Department, 1712 Pioneer Ave Suite 500, Cheyenne, WY 82001. Opting out does not affect any other provision of these Terms.

You agree to indemnify, defend, and hold harmless GemAlgo LLC and its officers, directors, employees, contractors, and agents from and against any claims, liabilities, damages, losses, and expenses — including reasonable attorneys' fees — arising from or related to your breach of these Terms, your misuse of our services, or your violation of any applicable law or third-party rights.

If you believe any content on our website infringes your copyright, please send written notice to support@gemalgo.com with the following information:

• A description of the copyrighted work claimed to be infringed
• The location of the allegedly infringing material on our website
• Your contact information including name, address, and email
• A statement of good faith belief that the use is not authorized
• A statement under penalty of perjury that the information is accurate and you are authorized to act on behalf of the copyright owner
• Your physical or electronic signature

We will review all valid notices and take appropriate action in accordance with the Digital Millennium Copyright Act (DMCA).

GemAlgo reserves the right to update or modify these Terms at any time. The "Last Updated" date at the top of this page reflects the most recent revision. Material changes will be communicated via email or prominent notice on our website. Your continued use of our services following any changes constitutes your acceptance of the updated Terms.

GemAlgo reserves the right to suspend or terminate your access to our services at any time, with or without cause, and with or without notice. Upon termination, all licenses granted under these Terms immediately cease. Sections relating to intellectual property, disclaimers, limitation of liability, indemnification, and dispute resolution survive termination.

These Terms are governed by the laws of the State of Wyoming without regard to its conflict of law provisions, except where federal law applies.

These Terms, together with our Privacy Policy and any enrollment agreement you have signed, constitute the entire agreement between you and GemAlgo with respect to your use of our website and services. They supersede all prior agreements, representations, and understandings.

For questions about these Terms or our services: