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Terms of Service

Version of 9 October 2026

The Polish version of these Terms is binding; this English version is a translation for convenience.

1. General

  1. These Terms set out the rules for using the Alpha22 mobile app and the alpha22.app website (the Service).
  2. The Service is provided by [to be completed: name], [to be completed: address], as an unregistered business activity (Article 5 of the Polish Entrepreneurs' Law) (the Provider). Contact: contact@alpha22.app, phone [to be completed: phone number].
  3. The Terms are available free of charge on alpha22.app and in the app (Settings → Legal) in a form that can be downloaded, saved and printed.
  4. The Service is intended for adults.

2. Definitions

  • App – the Alpha22 app for iPhone, available on the App Store.
  • Report – the monthly publication with a ranking of up to 22 companies, their scores, analysis and the portfolio simulation.
  • Free version – access to a Report with one unlocked company, the ranking with the scores of the other companies and the simulation result.
  • Subscription – paid, renewable access to full Reports, purchased through the App Store.
  • User – a person using the Service.
  • Consumer – a natural person who enters into a contract not directly related to their business or profession (Article 22¹ of the Polish Civil Code).
  • Sole trader with consumer rights – a natural person who enters into a contract directly related to their business where the contract shows that it is not of a professional nature for them (Article 385⁵ of the Polish Civil Code). The provisions of these Terms on Consumers apply to them to the extent provided by law.

3. Scope of the Service

  1. The Provider publishes Reports on the 15th of every month. For technical reasons or because data becomes available late, publication may be delayed by no more than 5 days; the Provider announces this in the App or on the website.
  2. In the Free version the User has access to one company of every Report. A Subscription unlocks all companies, full analyses, current company prices and the simulated trades.
  3. The portfolio simulation is hypothetical: it assumes 100,000 USD of capital, equal weights and rebalancing at every Report, without fees, taxes or dividends. The portfolio is valued at prices the Provider enters from public quotes as of each Report and a few times a month between Reports; they are neither real-time nor daily quotes. The method is described at alpha22.app/en/methodology.

4. Nature of the content

  1. Reports are for information only. They are the same for every User and do not take into account anyone's financial situation, objectives or knowledge.
  2. Reports are not investment advice within the meaning of the Polish Act on Trading in Financial Instruments and are not personal recommendations. The Provider is not an investment firm and does not provide investment advice.
  3. Reports are investment recommendations within the meaning of the Market Abuse Regulation (EU 596/2014). The information required by MAR, including conflicts of interest, is given in every Report and in the Disclosures document.
  4. Investing involves the risk of losing some or all of your capital. Past results, hypothetical results and simulations do not guarantee future results. Users make their investment decisions themselves and at their own risk.

5. Technical requirements and rules of use

  1. The App requires an iPhone with iOS 26.4 or later, internet access and an Apple Account (to buy a Subscription). The website works in current web browsers.
  2. Users use the Service in accordance with the law, these Terms and good practice.
  3. Supplying unlawful content, including in messages sent to the Provider, and disrupting the Service, in particular by circumventing its security or by mass automated downloading of data from its servers, are prohibited.

6. Conclusion and termination of the contract

  1. The contract for the Free version and the website is concluded when the User starts using the App or the website, for an indefinite period. The User may terminate it at any time and free of charge by no longer using the Service, in particular by deleting the App from the device.
  2. The Subscription contract is concluded when the Subscription is bought on the App Store, for the period of the chosen plan, and is extended in accordance with section 7(4). It expires at the end of the period in which the User cancelled the Subscription. Deleting the App does not cancel the Subscription.
  3. The Provider may terminate the contract with 7 days' notice only with a User who seriously or persistently breaches these Terms, in particular by distributing paid Reports contrary to section 9 or by disrupting the Service contrary to section 5(3), after an unsuccessful request to stop, where the User can be contacted. Where the breach threatens the security of the Service, the Provider may block access from the devices or addresses it comes from at once.
  4. If the Service is discontinued, the Provider announces it on the website and in the App at least 30 days in advance, stops selling Subscriptions and switches off their renewal as far as the App Store allows. A Consumer whose paid Subscription period lasts longer than the Service is entitled to a refund of the proportional part of the price; they may ask Apple at reportaproblem.apple.com and, if Apple does not grant it, the Provider at contact@alpha22.app.

7. Subscription and payments

  1. Subscriptions are bought in the App through the App Store. The User buys the Subscription from Apple, which handles sales, payments, renewals, cancellations and refunds under the App Store terms.
  2. The price is shown in the App before purchase and includes applicable taxes.
  3. Monthly and yearly plans are available. The yearly plan may include a free trial; unless the User cancels it, the Subscription becomes paid when the trial ends.
  4. A Subscription renews automatically for another period unless it is cancelled at least 24 hours before the end of the current period. It can be cancelled in the Apple Account settings (Settings → your name → Subscriptions) and in the App (Settings → Manage subscription); access lasts until the end of the paid period.
  5. A price change does not affect a period already paid for. Apple notifies the User of price changes in advance; a price increase for a renewing Subscription requires the User's consent where the App Store rules say so, and without that consent the Subscription will not renew.
  6. Users may ask Apple for a refund at reportaproblem.apple.com.

8. Digital content and withdrawal

  1. Reports are digital content not supplied on a tangible medium.
  2. Apple sells the Subscription in its own name, so withdrawal from the purchase of a Subscription and refunds are handled by Apple under the App Store terms. Consumers may submit a withdrawal or a refund request at reportaproblem.apple.com.
  3. Where a Consumer has a right of withdrawal against the Provider, it expires once the supply of digital content has started, provided the Consumer agreed to this before the withdrawal period ended, acknowledged losing the right and received a confirmation (Article 38(1)(13) of the Polish Consumer Rights Act). Otherwise the Consumer may withdraw within 14 days without giving a reason by writing to contact@alpha22.app.

9. Copyright

Reports, analyses and other content of the Service are protected by copyright. Users may use them for their own purposes only, subject to the permitted uses provided by law, including the right of quotation. Beyond those limits, copying, sharing or distributing Reports or parts of them, including screenshots of the paid part of the App, without the Provider's consent is prohibited.

10. Liability

  1. The Provider takes care that the content is accurate but relies on the companies' financial statements, publicly available information and public quotes, which may contain errors or be incomplete, and does not guarantee that the content is free of errors or complete.
  2. The Provider uses artificial intelligence (AI) tools to help rate the forward-looking indicators and prepare the qualitative analysis. The Provider reviews their output, but the ratings and descriptions may still contain errors or inaccuracies.
  3. The Provider is not liable for Users' investment decisions or their consequences.
  4. The Provider may temporarily limit access to the Service for technical reasons, giving notice in advance where possible.
  5. This section does not exclude or limit liability towards Consumers where the law prohibits it.

11. Complaints

  1. Complaints about the Service can be sent to contact@alpha22.app with a description of the problem and contact details.
  2. The Provider replies to the email address the complaint came from within 14 days of receiving it. If the Provider does not reply to a Consumer's complaint within that time, the complaint is deemed accepted.
  3. If digital content does not conform to the contract, in particular a Report has not been supplied or does not work properly, the Consumer has the rights set out in Chapter 5b of the Polish Consumer Rights Act: they may demand that it be brought into conformity and, in the cases provided by that Act, a price reduction or withdrawal from the contract. The Provider handles such complaints.
  4. Complaints about payments and refunds are handled by Apple. Refunds for Subscriptions bought on the App Store are made by Apple, so where needed the Provider will refer the Consumer to Apple; this does not limit the Consumer's rights against the Provider.
  5. Consumers may use out-of-court dispute resolution, e.g. the help of a municipal or district consumer ombudsman or the Trade Inspection.

12. Changes to the Terms

  1. The Provider may change the Terms only for the following important reasons: a) changes in the law or a court ruling or an authority's decision affecting the Terms; b) changes in the scope or features of the Service; c) changes in the App Store rules or payment methods; d) the need to remove ambiguities or errors in the Terms; e) changes in the Provider's details.
  2. The Provider announces changes on the website and in the App at least 14 days before they take effect. The current version of the Terms is shown on the website and in the App's Settings.
  3. A User who does not accept the changes may terminate the contract before they take effect by cancelling the Subscription and no longer using the Service; Subscription access lasts until the end of the paid period. Changes do not affect rights acquired before they take effect.

13. Final provisions

  1. Polish law governs contracts concluded under these Terms. This choice of law does not deprive Consumers of the protection of mandatory provisions of the country of their habitual residence.
  2. Matters not covered by these Terms are governed by Polish law, in particular the Civil Code, the Act on Providing Services by Electronic Means and the Consumer Rights Act.
  3. Disputes with Users who are neither Consumers nor sole traders with consumer rights are settled by the court having jurisdiction over the Provider's place of residence.
  4. These Terms apply from the date shown as their version.