Terms of Service

1. Definition of the service

The service is Sunday Letter, a financial independent publication published on the website, with email reminders for new issues. It operates as an independent newsletter publisher under the U.S. Investment Advisers Act of 1940 §202(a)(11)(D) Publisher Exclusion.

The service is not a licensed investment advisory, asset management, or brokerage business, and we do not take custody of client funds. All content is an information publication and does not constitute personalized investment advice tailored to your financial situation, investment objectives, or existing holdings. All investment decisions are made independently by you, and you bear all gains and losses.

2. Subscription

• Early-bird price (first 100 subscribers): Monthly USD $20 / month, Annual USD $200 / year, auto-renewed at the chosen interval
• Standard price (after early-bird spots are filled): Monthly USD $40 / month, Annual USD $400 / year, auto-renewed at the chosen interval
• Early-bird spots: 100 in total across monthly and annual plans; once filled, all new subscriptions are billed at the standard price
• Early-bird price locked for life: early-bird subscribers renew at the early-bird price for as long as they remain subscribed, regardless of changes to the standard price
• Spots are not kept after cancellation: cancelling ends the early-bird price and the spot is not kept, nor is it released to other subscribers; re-subscribing is billed at the price in effect at that time
• Content: full letter body (with holdings table) + market weather
• Delivery: every Sunday at 10am (UTC+8)

Visitors without a subscription can browse each letter’s title and summary, as well as the public deep reads, on the website. The letter body and holdings table are available to paid subscribers only.

3. Auto-renewal

Paid subscriptions auto-renew at the chosen interval (monthly or annual). On the renewal date the fee is automatically charged to your saved payment method. We email a renewal reminder at least 7 days before the next renewal, stating the upcoming charge date and amount.

You may cancel at any time. Cancellation method and effective time are detailed in Refund Policy §4.

4. Payment & currency

• Currency: USD
• Channels: Stripe (card / debit / Apple Pay / Google Pay)
• All payments are processed by Stripe; we do not store your full card number

5. Refunds

See the standalone Refund Policy. The Refund Policy forms part of these Terms with equal effect.

6. Our obligations

• Deliver the content described in section 2 to paid subscribers
• Protect personal information you provide in accordance with our Privacy Policy
• Never request your brokerage password, API key, or any account control
• Not manage client capital and not take a cut of client returns

7. Your obligations

• Provide a valid email and accurate payment information
• Not resell, mass-forward, publicly publish, or commercially exploit our paid-tier content (letter body, holdings table, etc.)
• Not use the service for any unlawful purpose or in any manner that violates the laws of your jurisdiction
• Not impersonate, falsify identity, or use another person’s payment instrument to subscribe
• Independently assess your own risk tolerance and only invest capital you can afford to lose

8. Intellectual property

All content we deliver (letter body, holdings table, market weather data, website design and assets) is our intellectual property or that of our licensors. The content is for your personal reference only.

Permitted: form your own independent trading decisions and positions based on our content; share your own market views after independent processing (without directly or identifiably quoting specific passages of paid content); refer the service to others through any official referral channel we provide.

Not permitted: distributing the full paid-tier content to non-subscribers in any form (oral, written, screenshot, screen-recording, resale, gifting); using our content as training input for any AI model that is publicly offered; re-publishing the holdings table on any public platform.

9. Scope & compliance statement

The service is available globally. Nothing in the service constitutes an offer or solicitation in any jurisdiction where such an offer or solicitation is prohibited or restricted by law.

If you are a U.S. Person, please note:

• The service is a one-to-many newsletter; all subscribers receive identical content, and we do not provide advice tailored to your personal situation
• We are not registered with the U.S. SEC as a Registered Investment Adviser (RIA) and provide services to the public under the Bona Fide Newsletter Exemption established in Lowe v. SEC (1985)
• We will not, and should not be asked to, answer personalized position-sizing questions (e.g. “how should I allocate $500k”), review your holdings and provide buy/sell recommendations based on them, or recommend specific share counts or position sizes based on your capital

10. Termination by us

We may unilaterally terminate your subscription (without refund) in the following situations:

• Breach of section 7 (your obligations) or section 8 (intellectual property)
• Providing falsified identity or using another person’s payment instrument
• Your payment is determined to be of suspicious origin, involves sanctioned parties, or is rejected by the payment channel’s risk controls
• You initiate a malicious chargeback without first contacting us

11. Limitation of liability

To the maximum extent permitted by applicable law, we are not liablefor any direct or indirect loss arising from your investment decisions based on the service’s content. All content is an information publication; investment decisions are made independently by you, and you bear all gains and losses. In any case, our aggregate liability shall not exceed the total subscription fees you actually paid us in the preceding 12 months.

12. Changes to these Terms

We may update these Terms due to business or regulatory changes. Material changes will be notified by email to the address on file at least 14 calendar days in advance. If you do not object in writing within the notice period and continue to use the service, you are deemed to have accepted the change. If you disagree, you may cancel within the notice period.

13. Governing law & dispute resolution

These Terms are governed by the laws of the State of Delaware, USA.

Any dispute arising from these Terms shall first be resolved through good-faith negotiation. If unresolved, the dispute shall be submitted to the Hong Kong International Arbitration Centre (HKIAC) for arbitration under its then-effective rules. The seat of arbitration is Hong Kong; the language is Chinese (the Chinese version of these Terms shall prevail). The tribunal shall consist of a sole arbitrator, and the award shall be final and binding on both parties.

14. Entire agreement

These Terms, together with our Privacy Policy, Refund Policy, and Disclaimer, constitute the entire agreement between you and us.

If any provision is held unenforceable, the remaining provisions remain in full force.

15. Contact

Questions about these Terms: support@timewin.co