Terms and Conditions

Version August 29, 2026 · English (operative version)

Preliminary note on contract formation

In addition to the following general terms, the process of contract formation is described here, since no separate, individually signed subscriber contract exists. The contract is concluded exclusively electronically via the website; the content of the contract is these general terms.

The process is as follows:

1. The prospective subscriber selects one of the subscriptions offered and the desired term on the website.
2. On the provider's order page the prospective subscriber is informed that these general terms apply. The prospective subscriber is then directed to the payment page of the payment service provider Stripe, where these general terms, the privacy policy and the right of withdrawal instruction are linked, and enters their email address and payment details.
3. By submitting the order via the clearly labelled order button (§ 312j (3) BGB), the prospective subscriber makes an offer to conclude a subscription contract.
4. The provider accepts the offer by confirming the order in text form and activating access.

Beyond this process, no communication takes place that would be the subject of a contractual agreement. Only the data required for the performance of the contract is collected, namely the email address and the details required for payment processing. Information on the subscriber's financial situation, investment objectives, risk tolerance, knowledge and experience or assets is neither collected nor processed nor taken into account.

§ 1 Provider and Scope

1. The provider is:
   Andreas Safar, trading as Accelith Investment Research, Scheffelstr. 32, 04277 Leipzig, Germany, email: support@accelith.com.
2. These general terms apply to all subscription contracts for the publications issued by the provider under the Accelith brand.
3. Deviating terms of the subscriber do not become part of the contract unless the provider expressly agrees to their application in text form.

§ 2 Subject Matter

1. The provider issues subscription-based publications on listed equities. The following are offered:
   Accelith Value Select. A monthly fundamental analysis of individual listed equities, including investment thesis, valuation and a view on value.
   Accelith Kinetic. A monthly report on a rules-based, systematic model portfolio. The composition of the model portfolio is derived mechanically from earnings-estimate revision momentum combined with an industry filter. The model portfolio holds approximately twenty equally weighted positions and is rebalanced once per month. The report sets out the current composition and the changes versus the prior month. There is no discretionary selection and no individual assessment of any single holding.
   Accelith Suite. A separate subscription comprising the services of Accelith Value Select and Accelith Kinetic. Partial termination is excluded.
2. The publications constitute investment recommendations within the meaning of Art. 3 (1) (35) of Regulation (EU) No 596/2014 (Market Abuse Regulation). The requirements of that Regulation and of Delegated Regulation (EU) 2016/958 are complied with, in particular as regards the identity of the producer, the presentation of the methodology and the disclosure of conflicts of interest.
3. The provider reserves the right to develop the scope and presentation of the publications, provided that the character of the service under paragraph 1 is preserved.

§ 3 Nature of the Service, No Investment Advice

1. All content is made available to all subscribers of the respective subscription uniformly, identically and at the same time. Content is not individualized for individual subscribers.
2. The provider does not collect, assess or take into account any personal circumstances of the subscriber. This includes in particular the financial situation, investment objectives, risk tolerance, assets, and knowledge and experience of the subscriber. No suitability or appropriateness assessment is carried out.
3. Content is not presented as suitable for the individual subscriber. The provider does not provide investment advice within the meaning of § 1 (1a) sentence 2 no. 1a KWG and § 2 (2) no. 4 WpIG.
4. The provider maintains no connection to brokers, banks or custodians. No portfolio reconciliation takes place. Orders are neither accepted nor forwarded nor triggered. The provider executes no transactions, holds no client funds and no client financial instruments, and neither holds nor administers any assets.
5. The subscriber makes investment decisions independently and on their own responsibility.
6. The provider holds no license under § 32 (1) KWG or § 15 (1) WpIG and is not supervised by the Federal Financial Supervisory Authority or any other financial supervisory authority.

§ 4 Remuneration

1. The provider is remunerated exclusively through the subscription fees paid by subscribers.
2. The provider receives no remuneration, benefit or other consideration from issuers, brokers, trading venues or other third parties in connection with the content published. No commissioned analyses are produced. No advertising space is marketed.
3. The price displayed during the order process in the currency stated there is decisive. Costs of currency conversion and fees charged by the subscriber's account-holding institution are borne by the subscriber.
4. Billing takes place in advance for the selected term. Payment is processed by the payment service provider Stripe, whose terms for payment processing apply in addition.
5. The provider is a small business within the meaning of § 19 UStG. Value added tax is not shown.

§ 5 Term and Termination

1. The subscription is concluded for the term selected during the order process, either monthly or annual.
2. A monthly subscription continues after the initial month on a monthly basis. An annual subscription continues after the initial twelve-month term on an annual basis.
3. During the initial term, the subscriber is bound for that term; ordinary termination takes effect at the end of the initial term, and fees already paid for the initial term are not refunded on a pro-rata basis.
4. After the initial term, the subscriber may terminate at any time with a notice period of no more than one month, effective at the end of that notice period (§ 309 no. 9 BGB). For a monthly subscription, the fee for the current month is not refunded. For an annual subscription in a renewal period, fees already paid for the part of the renewal period falling after the termination takes effect are refunded on a pro-rata basis.
5. Termination is effected via the management function in the customer account (including the cancellation button provided pursuant to § 312k BGB) or in text form to support@accelith.com.
6. The right to extraordinary termination for good cause remains unaffected for both parties.

§ 6 Right of Withdrawal (consumers)

1. Consumers have a statutory right to withdraw from the subscription contract within fourteen days. The details are set out in the Right of Withdrawal instruction (Widerrufsbelehrung) available on the website, which forms part of these terms and includes the model withdrawal form.
2. The right of withdrawal does not expire early. The provider obtains no waiver under § 356 (4) or (5) BGB and claims no compensation for value under § 357 (8) BGB. Access is activated immediately, and a consumer who withdraws within the withdrawal period receives a full refund of the amount paid.
3. For consumers resident in Germany, the German version of the Right of Withdrawal instruction is legally operative.

§ 7 Provision of Content

1. The publications are sent by email to the address provided by the subscriber and are additionally made available in the password-protected area of the website.
2. The publications are issued monthly. The provider does not owe publication on any particular calendar day.
3. The provider does not owe uninterrupted availability of the website. Temporary interruptions due to maintenance, technical faults or circumstances outside the provider's control do not give rise to any claim for reduction, provided that provision by email remains unaffected.

§ 8 Distribution Territory

1. The subscription is not offered to persons whose residence or habitual abode is in the United States of America or the United Kingdom.
2. On concluding the subscription, the subscriber warrants that they have neither residence nor habitual abode in one of the states named in paragraph 1 and that they are not concluding the subscription for the account of such a person.
3. The content is not directed at persons in jurisdictions in which its publication or availability would be contrary to applicable law. It is each recipient's responsibility to ensure that receipt and use are lawful in their jurisdiction.
4. In the event of an incorrect warranty under paragraph 2, the provider is entitled to terminate the subscription without notice and to block access. No claim to a refund exists in this case.

§ 9 Rights of Use

1. The subscriber receives a simple, non-transferable right to use the publications for their own, non-commercial purposes.
2. Passing on, reproducing, making publicly available or otherwise distributing the publications to third parties is prohibited without the prior consent of the provider in text form. This also applies to extracts.
3. Access credentials are non-transferable and are to be used exclusively by the subscriber.
4. In the event of a breach of paragraph 2 or 3, the provider is entitled to terminate the subscription without notice and to block access.

§ 10 Conflicts of Interest

1. Accelith Kinetic: the producer may hold positions corresponding to the Kinetic strategy through own capital, in which case the producer has a direct financial interest in the price development of those positions. The producer may alternatively hold no such positions and instead track the strategy on a model (paper) basis. The position status applicable to each report, and the basis on which the track record is maintained, are disclosed in that report. A publicly listed Wikifolio mirroring this strategy is planned but not yet live; this disclosure will be updated once it launches.
2. Accelith Value Select: the producer does not systematically invest in accordance with Value Select recommendations. In individual cases the producer may hold, establish or change positions in covered securities. The position status applicable to each report is disclosed in that report.
3. References in this section to positions held by the producer include positions held by any company controlled by the producer.
4. The producer receives no remuneration, benefit or other consideration from issuers, brokers, trading venues or other third parties in connection with the content published.
5. The current disclosure forms part of each publication and is additionally available via the Legal Notice on the website.

§ 11 Liability and Risk Notice

1. The publications are prepared with due care. The provider gives no guarantee as to the accuracy, completeness or timeliness of the content, in particular not for third-party data and estimates relied upon.
2. Securities investments involve risks up to total loss. Past performance, including any track record published on the website, is not an indicator of future results. No particular performance is promised or guaranteed.
3. The provider is liable without limitation for intent and gross negligence and for injury to life, body or health. For breach of material contractual obligations the provider is also liable for simple negligence, but limited to the foreseeable damage typical for the contract. Liability is otherwise excluded.
4. The provider is not liable for the subscriber's investment decisions and their economic consequences.

§ 12 Amendments to these Terms

1. The provider may amend these general terms to the extent necessary to adapt to changed legal conditions or to a development of the range of services, and provided that the subscriber is not unreasonably disadvantaged thereby.
2. Amendments are notified to the subscriber in text form at least six weeks before they take effect. If the subscriber does not object within six weeks of receipt, the amendments are deemed accepted. This consequence is pointed out separately in the notification. In the event of objection, the subscription ends when the amendment takes effect.

§ 13 Final Provisions

1. The law of the Federal Republic of Germany applies, excluding the UN Convention on Contracts for the International Sale of Goods. Mandatory consumer protection provisions of the state in which the subscriber has their habitual abode remain unaffected.
2. Should any provision of these general terms be or become invalid, the validity of the remaining provisions remains unaffected.
3. The contract and communication language is English, and the English version of these terms is authoritative. The sole exception is the statutory Right of Withdrawal instruction (Widerrufsbelehrung) for consumers resident in Germany, for whom the German version of that instruction is legally operative.