Terms of Service

These Terms of Service ("Terms") govern your access to and use of the Luum Wealth portfolio analytics platform (the "Platform"), operated by Luum Wealth ("Luum", "we", "us", or "our"), a Canadian company. By creating an account or using the Platform, you agree to these Terms. If you do not agree, do not use the Platform.

Our Privacy Policy and our Investment Disclosures form part of these Terms and are incorporated by reference.

Not investment advice. Luum is an educational analytics tool. Nothing on the Platform is personalized investment advice, a suitability assessment, or a recommendation to buy or sell any security. You are solely responsible for your investment decisions. See Section 10 and our Investment Disclosures.

1. What the Platform is

Luum is a portfolio analytics platform for retail investors. It lets you record holdings manually, import them by CSV, or connect a brokerage account, and then analyze allocation, performance, income, fees, risk, drift, goal progress, and tax summaries, and explore market data and educational content.

What the Platform is not. Luum is not a registered investment dealer, adviser, portfolio manager, or investment fund manager under Canadian securities law. We do not hold, trade, or have custody of your money or securities, we cannot place orders on your behalf, and using the Platform does not create an advisory or fiduciary relationship between you and us.

2. Eligibility

You must be at least 18 years old and legally able to enter a binding contract. The Platform is currently offered to residents of Canada. It is not directed at residents of other jurisdictions, and nothing on it is an offer or solicitation where that would be unlawful.

US availability is planned but not open. When it opens, the US Terms of Service Supplement will apply to US residents and will prevail over these Terms where they conflict.

3. Your account

You need an account to use the Platform. You are responsible for keeping your sign-in credentials confidential and for activity under your account. Tell us immediately at support@luumwealth.com if you suspect unauthorized access.

You must give accurate registration information and keep it current. One person, one account — you may not create multiple accounts to obtain additional free allowances, and we monitor for this.

4. The free plan, and what happens if you stop paying

New accounts start on the free Starter tier. Starter has no time limit and no payment method is required to use it. What each plan includes is set out on our pricing page and in Section 5.

If you cancel a paid plan, or a payment fails and is not resolved, your account returns to Starter. Nothing is deleted. Your portfolios, transactions and history stay in your account; the Investor and Wealth features are switched off until you subscribe again, and subscribing again restores access to them.

An unused free account does have a limit, which is the one exception to the paragraph above and is set out in section 19.3: a Starter account that goes unused for 90 days becomes read-only, is suspended after a further 30 days, and is deleted 30 days after that. Using the Platform at any point resets it, and restoring the account before deletion takes a single action and costs nothing. This never applies to a paid plan.

Exporting your data. Export is available on every plan, including Starter, at Settings → Your Data → Export. There is no automatic export.

5. Plans, pricing, and billing

5.1 Plans

Plan	Monthly	Annual	Portfolios	Brokerage connections	AI assistant
Starter	Free	Free	1	None	Not included
Investor	$9.90	$75	3	1	Not included
Wealth	$29	$249	Unlimited	Unlimited	Included, metered

Some features are limited to specific plans — the capital gains tax report requires Investor or above, and contribution room tracking and editing scheduled contributions require Investor or above. Current plan features and prices are set out on our pricing page and may change under Section 5.6.

5.2 Billing

Paid subscriptions are billed in advance through Stripe, in Canadian dollars, and include GST/HST where applicable. By subscribing you authorize us, through Stripe, to charge your payment method on a recurring basis — monthly or annually, matching the term you choose — until you cancel.

5.3 Cancellation

You may cancel at any time from the billing portal in Settings, or by contacting us. Cancellation takes effect at the end of the period you have already paid for, and you keep paid access until then.

30-day money-back on your first annual subscription. If you cancel within 30 days of your first annual subscription payment, we will refund that payment in full. This applies once per account, to the first annual term only — not to a renewal, not to a later annual term, and not to a plan change within an annual term.

Apart from that window, we do not provide pro-rated refunds for partial periods, on either the monthly or the annual plan, except as provided in section 19.2 and except where Canadian consumer protection law requires it.

5.4 Payment failure

If a payment fails we will email you and retry for a reasonable period. If payment is still not received, your account moves to Starter-tier access — your data is retained, but features above the Starter limits become unavailable until billing is resolved.

5.5 AI credits

The AI assistant on the Wealth plan is metered in AI answers. Every question costs one answer, whatever depth of analysis it requires. The Platform shows you the cost before you spend it.

The Wealth plan includes 64 AI answers per billing month.
Unused answers carry over for one month only, capped at one month's allowance, so your balance at the start of a month will not exceed 128 answers.
You may buy additional answers as one-time top-ups. Top-ups are priced and charged in Canadian dollars, and include GST/HST where applicable, on the same footing as your subscription.
Purchased answers are added to your current balance and are subject to the same carry-over cap.
AI answers have no cash value, are not transferable, and are not refundable once purchased, except where required by law. Unused answers are lost when your account is closed or deleted.

Internally the Platform meters answers in smaller units, which the detailed ledger in Settings shows; three of those units make one answer.

5.6 Changes to price and features

We will give you at least 30 days' notice by email before increasing the price of your subscription or materially reducing the features of your plan. If you do not accept the change, you may cancel before it takes effect and will not be charged the new price.

6. Acceptable use

You agree not to:

Use the Platform unlawfully, or in breach of any applicable regulation.
Attempt to access any part of the Platform, or another user's account or data, without authorization.
Reverse-engineer, decompile, or attempt to extract the Platform's source code, or circumvent plan limits, rate limits, or entitlement checks.
Create multiple accounts to obtain additional free allowances or AI credits.
Transmit malware or other harmful code.
Scrape, crawl, or bulk-extract data from the Platform, or use it to build a competing dataset or service, without our written permission.
Resell, sublicense, or provide the Platform to third parties as a service.
Misrepresent your identity or affiliation.
Use the Platform in a way that degrades performance for other users.

7. Your data

You own the financial data you enter, upload, or connect. You grant us a limited, non-exclusive licence to store and process it solely to provide the Platform to you, to maintain security and backups, and as otherwise described in the Privacy Policy. We do not sell your data and we do not use your financial data to train AI models.

You are responsible for the accuracy of the data you provide. The Platform's analytics are only as accurate as the data behind them — an incorrect cost base or a missing transaction will produce incorrect returns, gains, and tax figures.

Our own staff cannot view or modify your financial data. See Section 5 of the Privacy Policy for what that means for the support we can offer.

7.1 How we measure the Platform

Operating the Platform includes measuring it. We record, anonymously, which pages are opened, which features are used, when an error or an empty screen is shown to you, and how quickly pages load. We use this to find what is broken, to see which features are actually used, and to decide what to build.

This measurement is anonymous by construction, not merely by policy: nothing is written to your device, no account identifier or email address is attached, and page addresses are reduced to the kind of page they were before they are sent, so the particular security or portfolio you were looking at is not transmitted. It never includes your holdings, balances, or transaction amounts. It is part of providing and securing the Platform under Section 7 and does not depend on a separate consent.

Associating that activity with your account, so it can be recognised across sessions and devices, is different, and it happens only if you opt in at Settings → Investor Profile → Analytics. You can withdraw at any time, and if your browser sends a Global Privacy Control signal we will not do it at all. Section 3.6 of the Privacy Policy sets out both layers in full.

8. Brokerage connections

If you connect a brokerage account, the connection is established through Snaptrade using credentials you provide to them. The connection is read-only — neither we nor Snaptrade can place trades, move money, or change anything in your brokerage account through it.

You are responsible for complying with your brokerage's own terms when connecting. Brokerage data may be delayed, incomplete, or fail to synchronize; your brokerage's own statements are authoritative, not ours. You can remove a connection at any time from Settings.

9. Market data

Market data on the Platform — prices, quotes, fundamentals, ETF holdings, news, and IPO information — is provided by third-party data vendors and is delayed. It may be incomplete, inaccurate, or unavailable.

Do not rely on the Platform for real-time trading decisions. We do not warrant the accuracy, completeness, or timeliness of any market data, and we are not liable for losses arising from reliance on it. Data vendors may impose their own restrictions on redistribution of their data, and you may not redistribute it.

10. No investment advice

The Platform does not provide personalized investment advice. All analytics, scores, insights, simulations, projections, AI responses, and observations are for educational and informational purposes only. They are not:

a recommendation to buy, hold, or sell any security;
a suitability assessment for you or any investment;
financial planning, wealth management, or retirement advice;
tax, accounting, or legal advice.

Investing involves risk, including loss of principal. Past performance does not guarantee future results, and projections are illustrative arithmetic, not forecasts. Consult a registered adviser, portfolio manager, or other qualified professional before making investment decisions.

The full statement, including how to read each analytical surface, is in our Investment Disclosures, which forms part of these Terms.

11. Tax information

The Platform produces capital gains calculations, contribution room estimates, and other tax-related summaries from data you provide or import. These are informational only and are not tax advice, and the Platform does not prepare tax returns.

Specifically, you should be aware that:

Capital gains use the average cost base (ACB) method, pooled per security across your non-registered accounts.
The calculations do not apply the superficial loss rules, and do not allocate cost base on a spin-off.
Foreign-currency dispositions are converted at the published rate for each transaction date. Where no rate is available for a currency, the affected security is excluded from the report and identified, rather than converted at an assumed rate.
Return of capital, phantom distributions and stock splits are reflected only where they appear in the transaction history you provide or import. We have no independent corporate-actions feed. Mergers, spin-offs, attribution rules and foreign property reporting are not reflected.
Gains inside registered accounts are not reported, as they are not reportable dispositions.
Transactions the Platform cannot account for — a disposition with no purchase history, a disposition exceeding the units on record — are identified on the report rather than omitted from it, but they are not computed.
Contribution room figures are estimates based on what you tell us. The Canada Revenue Agency's own records are authoritative for your contribution room.
Slips and summaries issued by your financial institution are authoritative for filing.

Verify everything with the CRA or a qualified tax professional before filing.

12. The AI assistant

The AI assistant generates responses using Anthropic's Claude API. Responses are grounded in your own portfolio data, but AI systems can produce errors, including confident and plausible-sounding ones.

AI responses are not financial, tax, or legal advice.
Do not rely on AI output as the sole basis for any decision. Verify figures against the underlying data.
Your use of the assistant is also subject to Anthropic's usage policies.
We may set or change usage limits and credit costs, and may suspend the feature for abuse or where a provider becomes unavailable.

13. Availability and changes to the Platform

We aim to keep the Platform available but do not guarantee uninterrupted service. We may modify, suspend, or discontinue features. If we discontinue a material feature of a paid plan, Section 5.6 applies. Planned maintenance may make the Platform temporarily unavailable.

14. Intellectual property

The Platform — its software, design, analytics methodology, scoring models, help content, and other content excluding your own data — is owned by us or our licensors and protected by copyright and other intellectual property law. You may not reproduce, modify, distribute, or create derivative works from it without our written permission. You may use and share output about your own portfolio for your own purposes.

15. Third-party services

The Platform relies on third-party services including Clerk (authentication), Stripe (payments), Snaptrade (brokerage connections), Anthropic (AI), and market data vendors. Your use of those services may also be governed by their terms. We are not responsible for their availability, accuracy, or conduct, and an outage or error at a provider may affect the Platform.

16. Disclaimer of warranties

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE PLATFORM IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE PLATFORM WILL BE UNINTERRUPTED OR ERROR-FREE, OR THAT ANY MARKET DATA, ANALYTICS, TAX CALCULATION, OR AI RESPONSE WILL BE ACCURATE OR COMPLETE.

Nothing in these Terms excludes or limits any warranty, condition, or right that cannot lawfully be excluded or limited, including under provincial consumer protection legislation.

17. Limitation of liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR FOR ANY LOST PROFITS, LOST DATA, OR INVESTMENT LOSSES, ARISING FROM YOUR USE OF OR INABILITY TO USE THE PLATFORM, EVEN IF WE WERE ADVISED OF THE POSSIBILITY.

OUR TOTAL AGGREGATE LIABILITY FOR ALL CLAIMS ARISING FROM THESE TERMS OR THE PLATFORM WILL NOT EXCEED THE GREATER OF (A) THE AMOUNT YOU PAID US IN THE 12 MONTHS BEFORE THE CLAIM AROSE, AND (B) CAD $100.

These limits do not apply to liability that cannot be limited by law, including for fraud, death or personal injury caused by negligence, or gross negligence or intentional fault where provincial law prohibits limitation.

18. Indemnification

You agree to indemnify and hold harmless Luum and its officers, directors, employees, and agents from claims, damages, losses, and reasonable legal costs arising from your use of the Platform in breach of these Terms, or your infringement of a third party's rights.

19. Termination

19.1 By you

You may delete your account at any time from Settings. Deletion begins a 60-day grace period, during which your financial data is inaccessible but the deletion can be reversed by contacting us. After 60 days your account and financial data are permanently deleted, except billing records and security audit entries retained as described in the Privacy Policy.

Deleting your account does not entitle you to a refund of amounts already paid, except a refund available under section 5.3 and except as required by law.

19.2 By us

We may suspend or terminate your account if you materially breach these Terms, if you engage in fraud or abuse, or if we are required to by law. We will give you notice and, where the breach is capable of being cured, a reasonable opportunity to cure it, unless immediate suspension is necessary to protect the Platform, other users, or us, or unless prohibited by law.

Where we terminate your account for reasons other than your breach, we will refund the unused portion of any prepaid subscription period. On termination, we will make your data available for export for at least 30 days unless legally prohibited.

19.3 Unused free accounts

A Starter account that is not used for 90 days is retired on the following schedule. This is not a termination for breach and section 19.2 does not apply to it.

Days since the account was last used	What happens
83	We email a warning, seven days before anything changes
90	The account becomes read-only. It can still be read and exported
120	The account is suspended. Signing in offers to restore it
143	We email a final warning, seven days before deletion
150	The account and its financial data are permanently deleted

Paid plans are excluded. While a subscription is active the account is never treated as unused, whatever the interval between sign-ins.
Any use of the Platform resets the schedule, measured from your last authenticated use rather than your last sign-in.
You can reverse every step before deletion yourself. From day 90 the Platform offers Restore my account, which clears the schedule in full, including the deletion date. It is free and requires no contact with us.
Export stays available throughout, in the read-only and the suspended phase alike, at Settings → Your Data → Export.
Deletion is permanent and is not reversible once it has occurred. What survives it is limited to the billing records and de-linked security audit entries described in the Privacy Policy, Section 9.3.

20. Governing law and disputes

These Terms are governed by the laws of the Province of Ontario and the federal laws of Canada applicable there, without regard to conflict-of-law rules. Disputes will be resolved in the courts of Ontario, and you consent to their exclusive jurisdiction.

Nothing in this section deprives you of the right to bring a claim in the courts of your own province where provincial consumer protection law gives you that right, or of your right to complain to a consumer protection authority.

21. Changes to these Terms

We may update these Terms. We will communicate material changes by email at least 30 days before they take effect, and post the updated Terms with a revised last-updated date. If you do not accept a change, you may stop using the Platform and delete your account before the change takes effect. Changes will not apply retroactively to a dispute that arose earlier.

22. General

Entire agreement. These Terms, the Privacy Policy, and the Investment Disclosures are the whole agreement between us about the Platform.
Severability. If a provision is unenforceable, the rest remains in effect.
No waiver. Not enforcing a provision is not a waiver of it.
Assignment. You may not assign these Terms. We may assign them to a successor in a merger, acquisition, or sale of assets, on notice to you.

23. Contact

Questions about these Terms: legal@luumwealth.com Support: support@luumwealth.com Privacy: privacy@luumwealth.com