Effective date: June 2026 · SoftSignal, LLC

Author Disclosure

SoftSignal is an independent data and research project. The author is professionally employed in commodity risk consulting with a specialty in cocoa. Cocoa coverage is limited to publicly available CFTC positioning data; substantive market commentary is intentionally withheld given the author's professional role.

1. What SoftSignal Provides

SoftSignal Research is a subscription-based commodity market intelligence service. Our AI-assisted tools and weekly reports draw on publicly available data sources — including CFTC Commitments of Traders reports, USDA supply and demand data, ERA5-Land agro-climatic data, EIA storage reports, and the US Drought Monitor — to help subscribers understand market positioning and fundamental conditions.

All content is provided for general information purposes only and is subject to change without notice. Market data and conditions change rapidly; information presented may not reflect the most current available data at any given moment.

2. Data Accuracy & No Warranty

SoftSignal makes every reasonable effort to ensure that data and analysis presented through this platform are accurate, timely, and sourced correctly. However:

• We draw on third-party data providers (CFTC, USDA, EIA, NOAA, and others) whose data may contain errors, revisions, or delays outside our control
• Data processing, aggregation, and AI-assisted interpretation may introduce additional error
• Historical data is subject to revision by the originating agency; we cannot guarantee that archived figures reflect subsequent revisions
• Derived metrics, indicators, and model outputs are provided as analytical tools, not as authoritative data

SoftSignal makes no representations or warranties, express or implied, as to the accuracy, completeness, timeliness, or fitness for any particular purpose of any data, analysis, or report provided through this service. Your use of any data or analytical output is entirely at your own risk.

3. Not Investment Advice

SoftSignal, LLC is not a registered investment adviser, commodity trading adviser, broker-dealer, or financial planner under the US Investment Advisers Act of 1940, the Commodity Exchange Act, or any equivalent legislation in any other jurisdiction. The information and analysis provided through our platform:

• Does not constitute investment advice, a personalised recommendation, or a solicitation to trade
• Is not tailored to your individual financial situation, risk tolerance, capital position, or investment objectives
• Should not be the sole or primary basis for any trading or investment decision
• Does not guarantee any particular market outcome or price level
• May include forward-looking statements, projections, or scenario analysis — these are illustrative only and subject to material uncertainty

Past positioning patterns, historical supply and demand data, and agro-climatic conditions are not indicative of future results. Commodity markets involve substantial risk of loss. Always consult a qualified financial or commodity trading adviser who understands your individual circumstances before making investment or trading decisions.

4. Limitation of Liability

To the fullest extent permitted by applicable law, SoftSignal, LLC shall not be liable for any direct, indirect, incidental, special, or consequential damages arising from your use of or reliance on information provided through this platform, including but not limited to trading losses, lost profits, or data inaccuracies.

5. Acceptable Use

Your subscription is personal and non-transferable. You agree not to:

• Share your access credentials or session token with others
• Attempt to circumvent rate limits or daily query allowances
• Use the platform for automated scraping or bulk data extraction
• Reproduce or redistribute SoftSignal content commercially without written permission

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6. Data We Collect

We collect and store only what is necessary to provide and secure the service:

• Email address — collected at login, used to verify your active subscription against our records and to enforce daily usage limits. Stored in our secure database.
• Session token — a randomly generated credential stored in your browser and our database. Expires automatically after 7 days.
• Daily usage count — a rolling counter of queries used each day, stored alongside your session. Resets at midnight UTC. Used solely to enforce fair usage limits.
• Terms acceptance — a record that you have reviewed and agreed to these terms, stored with your session.

We do not collect, store, or log chat conversation content. Your questions and the AI responses exist only in your browser during the active session. When you close the page or your session expires, that conversation is permanently gone. We have no record of what you asked.

7. How We Use Your Data

Your email address is used exclusively for:

• Verifying that you hold an active premium subscription
• Session authentication and rate limiting
• Delivering subscriber reports and service communications to active subscribers

We will never use your email for unsolicited marketing, sell it to third parties, or share it with anyone outside of the service providers listed below.

8. Third-Party Service Providers

We use the following services to operate the platform. Each processes data only as necessary to provide their service to us:

• Google Cloud (Firebase / Firestore / Cloud Run) — infrastructure, database, and compute hosting. Data stored in the United States (us-central1).
• Anthropic — AI language model processing. Your messages are sent to Anthropic's API to generate responses. Anthropic processes these in accordance with their Privacy Policy. Messages are not used to train models under our commercial API agreement.
• Stripe — payment processing and subscription management. Holds your billing information and subscription status in accordance with their Privacy Policy. SoftSignal does not store payment card details.
• Cloudflare — network routing and DDoS protection. Processes requests in transit.

9. Data Retention

• Session records — automatically expire after 7 days of inactivity
• Usage counts — reset daily; only the current day's count is retained
• Email address — retained for the duration of your active subscription. Removed upon request (see Section 11)
• Chat conversations — not retained. Zero retention by design

10. Your Rights (GDPR / UK GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation or equivalent legislation. The legal basis for processing your personal data is contract performance (to provide the subscription service you have purchased) and legitimate interest (session security and rate limiting).

You have the right to:

• Access — request a copy of personal data we hold about you
• Rectification — correct inaccurate personal data
• Erasure — request deletion of your personal data ("right to be forgotten")
• Restriction — ask us to limit how we use your data
• Portability — receive your data in a structured, machine-readable format
• Object — object to processing based on legitimate interest

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with your local supervisory authority.

Note: our infrastructure is hosted in the United States. By using the service, you consent to your data being transferred to and processed in the US.

11. Data Deletion Requests

To request deletion of all personal data we hold: email [email protected] from the address associated with your subscription. We will confirm deletion within 30 days. Deletion of your account data will terminate your access to the chat service.

12. Changes to These Terms

We may update these terms from time to time. Significant changes will be communicated via email to subscribers. Continued use of the service after notification constitutes acceptance of the updated terms.

13. Governing Law

These terms are governed by the laws of the State of Utah, United States, without regard to conflict of law principles. Any disputes shall be resolved in the courts of Utah.