Terms of Service

1. Who we are and what the Service is

"Winnow" (also "we", "us", "our") refers to the operators of the website at winnow.markets and the associated email newsletter and any future related services. Winnow is currently operated as a sole-proprietor venture based in Singapore, with incorporation as a Singapore private limited company pending. References in these Terms to "Winnow" include its eventual incorporated entity.

The Service provides interpretive research and educational content covering commodities markets (initially grains, oilseeds, maize, and feeds; with future expansion into metals and equities). Content includes briefings, summaries of public data releases (such as USDA WASDE reports, CFTC Commitments of Traders data, NOAA weather outlooks, CONAB and ANEC reports), and contextual analysis intended to help readers understand how professional desks read these releases.

Winnow operates from Singapore and intentionally serves users globally, including in the United States, the European Union, the United Kingdom, and other jurisdictions where it is lawful for us to do so. These Terms have been drafted to address the regulatory frameworks of each of these markets; the regulatory disclaimers in Section 3 below apply to all users worldwide.

2. Acceptance of these Terms

By accessing, browsing, or otherwise using the Service, you confirm that:

• You are at least 18 years old and have the legal capacity to enter into a binding contract under the law of your jurisdiction
• You have read, understood, and agreed to be bound by these Terms and our Privacy Policy
• Your use of the Service is for lawful purposes and consistent with these Terms

If you do not meet these conditions or do not agree to these Terms, you must not access or use the Service.

3. Educational and informational purpose only — NOT investment advice

This section is the most important part of these Terms. Please read it in full.

3.1 The Service is educational

All content provided by Winnow — including briefings, newsletter issues, demo responses, summaries, charts, tables, commentary, opinions, and any other material — is provided for general informational and educational purposes only. Content is intended to help readers improve their understanding of how commodities markets function and how professional traders interpret public data releases.

3.2 The Service is NOT regulated investment advice in any jurisdiction

Winnow is not licensed, registered, or authorised by any financial-services regulator in any jurisdiction. Specifically:

• Singapore. Winnow is not licensed by the Monetary Authority of Singapore ("MAS") as a financial adviser, capital markets services licensee, or in any other regulated capacity under the Financial Advisers Act 2001 or the Securities and Futures Act 2001.
• United States — SEC. Winnow is not registered with the U.S. Securities and Exchange Commission ("SEC") as an investment adviser, broker-dealer, or municipal advisor. Our publications constitute impersonal commentary distributed in regular and general circulation, and we rely on the publishers' exclusion to the definition of "investment adviser" under §202(a)(11)(D) of the Investment Advisers Act of 1940 (15 U.S.C. § 80b-2(a)(11)(D)), as interpreted by the U.S. Supreme Court in Lowe v. SEC, 472 U.S. 181 (1985).
• United States — CFTC. Winnow is not registered with the U.S. Commodity Futures Trading Commission ("CFTC") as a Commodity Trading Advisor ("CTA"), Commodity Pool Operator, Introducing Broker, Futures Commission Merchant, or in any other regulated capacity. Our publications constitute impersonal commentary distributed broadly, and we rely on the publishers' exemption from CTA registration under §4m(1) of the Commodity Exchange Act (7 U.S.C. § 6m(1)) and CFTC Regulation 4.14(a)(9) (17 C.F.R. § 4.14(a)(9)).
• United Kingdom. Winnow is not authorised by the UK Financial Conduct Authority ("FCA") under the Financial Services and Markets Act 2000 ("FSMA"). Our publications are intended to constitute generic commentary that does not amount to a "financial promotion" within the meaning of section 21 FSMA or the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005, nor to "regulated advice" within the meaning of Article 53 of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001.
• European Union. Winnow is not authorised under the EU Markets in Financial Instruments Directive II ("MiFID II", Directive 2014/65/EU) as a MiFID firm in any EU member state. Our publications do not constitute "investment advice" within the meaning of MiFID II Article 4(1)(4), which requires a personal recommendation. Where our content may constitute an "investment recommendation" within the meaning of Regulation (EU) No 596/2014 (Market Abuse Regulation) and Commission Delegated Regulation (EU) 2016/958, we make reasonable efforts to comply with applicable disclosure requirements.
• Other jurisdictions. Where you are subject to the financial-services regulatory regime of a jurisdiction not listed above, you remain responsible for ensuring your use of the Service complies with the applicable laws of your jurisdiction.

Winnow does not, and does not purport to, provide:

• Personalised investment recommendations tailored to your financial situation, risk tolerance, objectives, or needs
• Advice on the suitability of any particular investment, security, contract, or instrument for you
• Solicitation to buy, sell, or hold any security, contract, derivative, or instrument
• Brokerage, execution, custody, clearing, or portfolio management services
• Tax, accounting, legal, or other professional advice

3.3 No fiduciary relationship

Nothing in these Terms or in any content we publish creates a fiduciary, advisory, agency, partnership, or similar professional relationship between Winnow and any reader, subscriber, or user.

3.4 You are responsible for your trading decisions

If you decide to make any investment or trading decision based, in whole or in part, on content from Winnow, that decision is yours alone. We strongly recommend you:

• Conduct your own independent research and due diligence
• Consult a licensed financial adviser or other qualified professional
• Consider your own financial situation, objectives, and risk tolerance
• Only risk capital you can afford to lose

3.5 Trading risk acknowledgement

You acknowledge that:

• Trading commodities, futures, options, and other leveraged instruments involves substantial risk of loss
• It is possible to lose more than your initial investment when trading on margin or with leverage
• Markets can move rapidly and unpredictably; past performance is not indicative of future results
• Backtests, scenarios, historical positioning analyses, and similar content are not predictions of future market behaviour
• No content from Winnow guarantees any outcome, return, or result

4. Accuracy of information

We make reasonable efforts to ensure that content is accurate as of the time of publication. However:

• Markets and underlying data change continuously; content may become stale or superseded quickly
• We rely on public data sources (USDA, CFTC, NOAA, CONAB, ANEC, etc.) whose accuracy we cannot independently verify
• Errors, omissions, typographical mistakes, and misinterpretations are possible despite our best efforts
• We do not warrant that content is complete, current, accurate, free from error, or fit for any particular purpose

If you identify a factual error in our content, we appreciate corrections sent to enquiry@winnow.markets.

5. Your obligations and acceptable use

When using the Service, you agree to:

• Use the Service only for lawful purposes and in accordance with these Terms
• Not redistribute, republish, sell, license, or otherwise commercially exploit our content without our prior written permission
• Not use automated tools (scrapers, bots, crawlers beyond standard search engine indexing) to access the Service or extract content at scale
• Not attempt to gain unauthorised access to any part of the Service, our servers, or any related systems
• Not interfere with, disrupt, or impose undue load on the Service
• Not misrepresent yourself or your affiliation when interacting with us
• Not use the Service in a manner that could harm Winnow, other users, or third parties

We reserve the right to suspend or terminate access for any user who breaches these obligations.

6. Intellectual property

6.1 Our content

All content on the Service — including text, briefings, design, layout, code, graphics, and any compilations — is owned by Winnow or licensed to us, and is protected by copyright, trademark, and other intellectual property laws. The name "Winnow" and our logo are our trademarks. You may not use them without our prior written permission, except as expressly permitted below.

6.2 Limited licence to you

We grant you a personal, non-exclusive, non-transferable, revocable licence to:

• Access and view our content for your own personal, non-commercial use
• Quote brief excerpts from our content for purposes of review, commentary, or news reporting, provided you attribute the excerpt clearly to Winnow and link back to the source where reasonable
• Share links to our pages on social media or via private messages

This licence does not permit you to reproduce substantial portions of our content, create derivative works, or use our content for any commercial purpose without our prior written permission.

6.3 Third-party content and data

Public data we summarise (USDA, CFTC, etc.) is owned by its respective publishers and used under fair-use or equivalent doctrines. We make no claim to ownership of that underlying data; our content reflects our interpretation and commentary on it.

7. Subscriptions and payment (future)

Our current offering — newsletter signup and access to publicly available briefings — is free of charge. We anticipate launching a paid subscription tier in the future. When we do, these Terms will be updated to include:

• Subscription pricing, billing cycle, and renewal terms
• Refund policy (if any)
• Cancellation procedure
• Payment processor and applicable third-party terms

Until such time, no payment is required from you and we do not collect payment information.

8. Disclaimers and limitation of liability

8.1 "As is" and "as available"

The Service and all content are provided "as is" and "as available", without warranty of any kind, whether express, implied, statutory, or otherwise. To the maximum extent permitted by law, we disclaim all warranties, including without limitation any warranties of merchantability, fitness for a particular purpose, non-infringement, accuracy, completeness, timeliness, or uninterrupted operation.

8.2 Limitation of liability

To the maximum extent permitted by law, in no event shall Winnow, its operators, founders, officers, employees, contractors, or affiliates be liable to you or any third party for:

• Any trading or investment losses incurred by you, directly or indirectly, in connection with your use of the Service
• Any indirect, incidental, special, consequential, exemplary, or punitive damages
• Any loss of profits, revenue, data, business opportunities, or goodwill
• Any damages arising from your reliance on the accuracy, completeness, or timeliness of our content
• Any damages arising from interruptions, errors, or failures in the Service

This limitation applies regardless of the legal theory under which damages are sought (contract, tort, statute, or otherwise) and whether or not we have been advised of the possibility of such damages.

8.3 Aggregate liability cap

To the maximum extent permitted by law, our total aggregate liability to you for all claims arising out of or related to the Service or these Terms shall not exceed the greater of: (a) the total amount you have paid Winnow in the 12 months preceding the claim; or (b) SGD 100.

8.4 Statutory rights and Unfair Contract Terms Act

Nothing in these Terms excludes or limits any liability that cannot be excluded or limited under applicable law, including under the Singapore Unfair Contract Terms Act, the Consumer Protection (Fair Trading) Act, or equivalent legislation in your jurisdiction. Specifically, we do not exclude liability for:

• Death or personal injury caused by our negligence
• Fraud or fraudulent misrepresentation
• Any other liability that cannot be excluded as a matter of law

9. Indemnification

You agree to indemnify and hold harmless Winnow, its operators, founders, officers, employees, contractors, and affiliates from and against any claims, losses, damages, liabilities, costs, and expenses (including reasonable legal fees) arising out of or related to:

• Your use of the Service
• Your breach of these Terms
• Your violation of any applicable law or third-party right
• Any trading or investment decision you make in connection with content from the Service

10. Termination

We may suspend or terminate your access to the Service at any time, with or without notice, for any reason, including but not limited to breach of these Terms. You may stop using the Service at any time and may unsubscribe from our newsletter using the link in any email.

Termination does not affect provisions of these Terms that, by their nature, are intended to survive termination — including intellectual property, disclaimers, limitations of liability, indemnification, and governing law.

11. Changes to these Terms

We may update these Terms from time to time. When we do, we will:

• Change the "Last updated" date at the top of this page
• Where the change is material, notify current subscribers via email at least 14 days before the updated Terms take effect

Continued use of the Service after a change indicates acceptance of the updated Terms. If you do not agree, you must stop using the Service.

12. Governing law, jurisdiction, and geographic responsibility

12.1 Governing law

These Terms and any dispute arising from or related to them or to your use of the Service shall be governed by and construed in accordance with the laws of the Republic of Singapore, without regard to its conflict of laws principles.

12.2 Jurisdiction

Any dispute, controversy, or claim arising out of or relating to these Terms shall be referred to and finally resolved by the courts of Singapore, which shall have exclusive jurisdiction. You and we both irrevocably submit to the jurisdiction of the Singapore courts.

12.3 Mandatory consumer rights

If you are a consumer based in the European Union, the United Kingdom, the United States, or another jurisdiction that grants mandatory consumer protection rights — including under the EU Consumer Rights Directive (2011/83/EU), the UK Consumer Rights Act 2015, applicable US state consumer protection statutes, or equivalent legislation — this clause does not affect your right to bring proceedings in the courts of your country of residence under those mandatory rules. Where such mandatory rules conflict with these Terms, the mandatory rules prevail to the extent of the conflict.

12.4 Geographic responsibility

You are responsible for ensuring that your access to and use of the Service complies with the laws of your country of residence. If access to or use of the Service, or any part of the Service, is prohibited or restricted in your jurisdiction, you must refrain from such access or use. Winnow makes no representation that the Service is appropriate or available for use in any particular jurisdiction outside Singapore.

13. Miscellaneous

• Entire agreement. These Terms, together with our Privacy Policy, constitute the entire agreement between you and Winnow regarding the Service and supersede any prior agreements.
• Severability. If any provision of these Terms is held to be invalid or unenforceable, the remaining provisions remain in full force and effect.
• No waiver. Our failure to enforce any right or provision does not constitute a waiver of that right or provision.
• Assignment. You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign these Terms freely, including to a successor entity (such as the Singapore private limited company we are incorporating).
• Force majeure. Neither party is liable for delays or failures in performance caused by events beyond their reasonable control.
• No third-party beneficiaries. These Terms are between you and Winnow only; no third party has rights under them. The Contracts (Rights of Third Parties) Act of Singapore does not apply.
• Language. These Terms are written in English; any translation is provided for convenience only and the English version controls.

14. Contact

For questions about these Terms, please contact us at enquiry@winnow.markets with the subject line "Terms".

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These Terms have been drafted to reflect the actual nature of our Service and the actual risks of the markets we cover. We have included a prominent investment-advice disclaimer because we believe readers deserve to understand exactly what we are and are not providing.