Terms of service

1. Definitions

"Software" means the My Portfolio desktop or native-client application together with any updates we make available to you.

"Website" means the My Portfolio website and any related web services we operate.

"Cloud Automation" means running your selected strategies on our servers for a paid 24-hour period for each cloud portfolio.

"Backtest" means a one-off service that computes how a strategy would have behaved on historical market data without placing real trades.

"Credits" means the internal units used to pay for Cloud Automation, Backtests and other paid products. 1 Credit corresponds to 1 Russian ruble. The price is shown before launch.

"Services" means Cloud Automation, Backtests, and the related Website features.

"Subscription" means a previously purchased cloud plan. New subscriptions are not sold or automatically renewed; existing paid cloud access remains covered until its paid-through date.

"Account" means the user record we maintain for you on the Website.

"AI Agent" means third-party software based on a language model that you yourself connect to the Account through the consent page or a personal access token so that it calls Website tools on your behalf.

"User" or "you" means the natural person who holds the Account and uses the Services for personal needs unrelated to business activity.

"Vendor" or "we" means Individual Entrepreneur Bakurov Pavel Andreevich (OGRNIP 321508100472902, INN 503623289407), the publisher of My Portfolio.

My Portfolio is available only to users who are at least 18 years old and have the legal capacity to enter into these terms and to use brokerage services in their jurisdiction. If we learn that an Account is held by a minor or a legally incapable person, we may suspend the Account, stop paid access, and refund the unused paid period where required by mandatory law.

The Vendor is also the seller, service provider, licensor, and website owner for the Website and Software. Privacy, support, and consumer claims may be sent to support@my-portfolio.ru. The Vendor's registered address for legally significant notices is 142105, Podolsk, Podolskikh Kursantov St. 2, apt. 34; the consumer support phone is +7 916 650-96-53; and consumer support business hours are Mon-Fri, 10:00-19:00 MSK.

2. License grant

Subject to your compliance with these terms, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to install and use the Software on machines you control, for your own personal use. Local trading is free and does not require a Subscription or Credits. Paid Services through the Website use Credits under the rules shown before launch.

You may not redistribute, sell, sublicense, lease, rent, or otherwise make the Software available to third parties. You may not reverse engineer, decompile, or disassemble the Software, except to the extent that applicable law expressly permits this activity despite a contractual prohibition. You may not remove or alter any proprietary notices, branding, or labels on the Software.

3. Credits, payment, and cancellation

A cloud portfolio is paid in advance with Credits for 24 hours from launch: 40 Credits for each started block of 10 instruments. A portfolio's instrument count is the distinct instruments of its enabled strategies (repeated instruments count once) plus 10 instruments for each enabled strategy that selects its instruments while running. Each portfolio is billed separately. Composition changes affect the next charge. If you want to end the service early, you may refuse it at any time under article 32 of the Law of the Russian Federation ‘On Protection of Consumer Rights’; in that case we refund the fee for the unused days of the paid period less the actual, documented costs we have incurred.

Before confirming a top-up, you see the amount in Russian rubles and the number of Credits to be added. The payment page shows the available payment methods. Before starting a cloud portfolio, you see its credit price, the paid 24-hour period and the renewal rules. There are no subscription tiers or monthly Credit allowances.

Cloud Automation, Backtests and other paid products use the same Credit balance. Purchased Credits do not expire while the Account exists; you may refuse unused purchased Credits at any time and receive their price back under article 32 of the Law of the Russian Federation ‘On Protection of Consumer Rights’. On Account registration, 1,000 startup Credits are granted once. Startup Credits pay for the same Services but are not purchased: they are not refundable and cannot be exchanged for money. For a refund, startup Credits are treated as spent first: the unspent part of purchased Credits is refunded, up to the paid and not yet refunded top-up amount and up to the Credit balance available at the time of the refund. The cost of a Backtest run is deducted when the run starts and is not refunded once the computation has completed, except where the computation failed through our fault.

The workspace assistant answers 20 messages a day for free; a day runs on Moscow time. Each further message is paid with Credits at the actual cost of the language model's work on the answer: 2 Credits for each ruble of that cost. Before a paid message is sent, the amount shown in the assistant panel is reserved on the balance; the answer never costs more. After the answer, the actual cost is deducted and the rest of the reserve returns to the balance. If no answer arrives, no Credits are deducted and the message does not count toward the free allowance.

Tool calls by connected AI Agents are free of charge. Backtests that an AI Agent launches under the launch permission you granted are paid with Credits under the same rules as launches in the workspace, and only within the daily Credit cap you set for that connection; a day runs on Moscow time.

While a cloud portfolio is running, the next 24 hours are automatically paid from available Credits. Pausing disables the next renewal; resuming within the paid period does not charge again. Topping up requires a separate payment confirmation; there are no automatic card charges for subscription renewals. For payments subject to Federal Law No. 54-FZ, we issue a cash receipt or electronic receipt in the manner required by law through our payment provider YooKassa (OOO NKO YuMoney). If you provided an email address or phone number before payment, the receipt may be sent electronically.

If your available Credits cannot cover the next 24-hour period, the cloud portfolio pauses at the end of its paid period. Top up and resume it to continue. An insufficient balance does not restrict free local trading or access to your Account.

Nothing in these Terms excludes, restricts, or waives any mandatory consumer-protection right. If you use My Portfolio as a consumer, you retain all rights provided by applicable consumer-protection law, including rights relating to inadequate information, defective services, defective digital functionality, statutory deadlines, statutory penalties, damages, and court jurisdiction.

Eligible refunds are returned within 10 days of receiving your request to the original payment method unless another lawful route is required.

A previously purchased Subscription covers cloud access until its paid-through date without daily Credit charges. Subscription sales and automatic subscription charges have ended. After the paid period, running cloud portfolios use daily Credits. If we terminate access without cause during a paid period, we refund the unused portion of the service fees.

Service fees do not include broker commissions, exchange fees, custody fees, taxes, internet or hardware costs, payment-provider charges, or trading losses. Those third-party costs and losses are not refundable by us.

4. Acceptable use

You agree not to use the Software or the Website in any way that violates applicable law, the terms of the brokers you connect to, or the rules of the exchanges you trade on. You agree not to use the Software or the Services to provide investment-management or other regulated financial services to third parties.

You agree not to use the Software for market abuse, including: to attempt to manipulate markets; to generate artificial price or volume signals; to place wash trades; to trade while unlawfully using insider information; to coordinate trades with other persons for the purpose of affecting price, demand, supply, or trading volume; to create artificial liquidity or misleading order-book activity; to evade broker or exchange controls; to conceal the beneficial owner or purpose of a transaction; or to otherwise create misleading market impressions. You agree not to share your Account credentials with other persons, and to remain responsible for all activity that occurs under your Account.

You agree not to abuse the broker connection or the exchange connection through excessive request rates, malformed orders, or any pattern that the broker or the exchange could reasonably treat as misuse.

Support tickets are limited to 5 per user per day on Moscow time, counting every way of sending them, including through a connected AI agent. We may bar a user from submitting tickets who abuses this channel; the bar does not limit access to the Account or the Services, and you can still write to us at support@my-portfolio.ru.

You agree not to bypass technical limits, scrape non-public service data, interfere with the Website or APIs, introduce malicious code, collect other users' personal data without authority, or use My Portfolio in a way that could expose us, a broker, an exchange, or another user to sanctions, AML, market-abuse, cybersecurity, or regulatory risk.

Before enabling the Software, you are responsible for checking whether any restriction applies to you or to a trade - for example, restrictions tied to an instrument, an issuer, a currency, an account type, a trading venue, an order type, a derivative, a short position, a margin transaction, a foreign security, a blocked asset, a non-resident transaction, a qualified-investor restriction, a sanctions measure, or a special economic measure. Many participants can act on those restrictions: a broker, an exchange, a regulator, a depository, a clearing organization, a payment provider, or another infrastructure provider may reject, block, suspend, unwind, delay, or restrict orders or assets. My Portfolio cannot override those restrictions, and it is not responsible for losses, missed trades, blocked assets, or inability to dispose of instruments caused by them.

5. Your responsibilities as the operator

You are the operator of the trades that the Software places. You choose which strategy to run from the strategy library, you configure that strategy's parameters, and you decide when to enable or pause live trading. The Software executes the strategy you have chosen against the broker account you have connected. You are the sole decision-maker for the trades that result.

You are responsible for reviewing every strategy configuration before enabling live trading, for testing strategies in a non-live mode where the Software supports it, and for monitoring the running automation in line with your own risk tolerance. The Software is a tool you operate; it is not an autonomous agent that decides on your behalf.

Broker API credentials, tokens, signing keys, and broker sessions are your responsibility. Broker API tokens may grant access to account information and, depending on the permissions you issue, the ability to place trading orders. Use the minimum broker permissions needed for your purpose, prefer read-only tokens where trading is not required, keep trading tokens on devices you control, revoke them immediately if compromise is suspected, and understand that orders submitted through credentials or tokens you connected may be treated by the broker as your own orders even if they were generated by misconfiguration, malware, device compromise, or another person with access to your device. We are not responsible for losses caused by compromised devices, leaked tokens, incorrect broker permissions, broker API changes, or third-party access to your broker account.

AI Agents you connect act on your behalf. You are responsible for choosing the agent and its provider, for keeping personal access tokens safe, and for the actions and Credit spending that agents you connected perform within the granted permissions and daily cap. A personal token is shown only once: do not share it, and revoke it in the Connected agents section of your profile if you suspect compromise. An agent does not change portfolios, strategies, or broker connections: it only proposes such changes as a link, and they apply after you confirm them in the browser. We are not responsible for the answers, conclusions, or recommendations of a third-party agent or for the processing of data by its provider.

6. No investment advice

The Software does not provide investment advice. My Portfolio is not a broker, dealer, forex dealer, investment adviser, trust manager, asset manager, depositary, exchange, clearing organization, or other professional participant in the Russian securities market. The Vendor is not included in the Bank of Russia register of investment advisers and does not provide regulated investment-advisory, brokerage, dealer, trust-management, portfolio-management, custody, clearing, or order-execution services. Orders are initiated from the Software configured by you and sent to the broker account you connected; we do not accept client assets, open brokerage accounts, route orders as an intermediary, or execute trades on an exchange.

The strategy library is a set of mechanical execution templates that you select from at your own discretion. Strategy names, descriptions, examples, catalog placement, plan labels, and "recommended" badges are marketing or informational material only. They do not state or imply that any instrument, strategy, portfolio structure, tariff, or trading action is suitable for your investment goals, financial position, expected return, risk appetite, or investment profile. They are not individual investment recommendations and must not be treated as a proposal, instruction, or advice to buy, sell, hold, or refrain from trading any financial instrument.

Nothing in the Software, the Website, or our support channels should be treated as financial, investment, tax, or legal advice. Where you need advice of that kind, consult a licensed professional in your jurisdiction.

7. Trading risk

Automated trading can and does produce losses. Past performance of any strategy does not predict future results. The risks of automated trading are described in detail in our Risk Disclosure, which forms part of these terms. By using the Software for live trading, you confirm that you have read and accepted that disclosure.

Any examples, simulations, backtests, screenshots, historical observations, model outputs, or strategy descriptions are illustrative only. They are not promises, guarantees, forecasts, or estimates of future return, loss limitation, liquidity, execution quality, tax result, or uninterrupted operation. If any performance figure is shown, it must be read together with the calculation method, period, assumptions, commissions, fees, taxes, slippage, liquidity limits, and risk disclosure displayed with it.

The Vendor is not liable for trading losses, missed opportunities, or any other adverse trading outcomes, including losses that arise from market events, execution slippage, broker errors, broker insolvency, exchange downtime, internet outages, power failures, configuration mistakes, software defects, or any combination of these.

8. Software provided "AS IS"

The Software and the Website are provided "AS IS" and "AS AVAILABLE", without warranties of any kind, whether express or implied. To the maximum extent permitted by law, we disclaim all implied warranties, including the implied warranties of merchantability, fitness for a particular purpose, accuracy, completeness, non-infringement, and uninterrupted operation. We do not warrant that the Software will be free of defects, that it will operate without interruption, that any defect will be corrected, that the results obtained from using the Software will meet your expectations, or that the Software will be compatible with any specific broker, exchange, or trading instrument at any specific point in time.

The AS-IS disclosure applies only to the extent permitted by law. It does not limit mandatory consumer-protection rights, statutory remedies for defective service or inadequate information, liability for willful misconduct, gross negligence, fraud, or harm that cannot be limited by law.

9. Limitation of liability

Our liability to you is determined by the Law of the Russian Federation ‘On Protection of Consumer Rights’ and the Civil Code of the Russian Federation; contractual liability caps do not apply to consumers.

To the maximum extent permitted by law, we are not liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, loss of revenue, loss of goodwill, loss of data, loss of trading opportunity, or business interruption, even if we have been advised of the possibility of such damages. These limitations apply regardless of the legal theory on which the claim is based.

Nothing in this section limits any liability that cannot be limited under applicable law, including mandatory consumer claims, defective service, inadequate information, statutory penalties, damages, court jurisdiction, fraud, willful misconduct, gross negligence, or, where the law does not permit it to be limited, for personal injury or harm to life and health.

10. Intellectual property

We and our licensors retain all right, title, and interest in and to the Software, the Website, the strategy library, and all related trademarks and copyrights. Your license to use the Software does not transfer any ownership in any of these. You retain ownership of the data you create and the strategy configurations you author, subject to the limited license you grant us to host, copy, process, display, moderate, review, version, back up, and operate that data on the Website and in related My Portfolio services.

You are responsible for the legality and accuracy of any strategy, configuration, note, publication request, support attachment, or other content you upload. You must not upload content that infringes third-party rights, contains unlawful material, contains malware, discloses third-party personal data without authority, or embeds broker credentials, passwords, private keys, or other secrets. We may remove, restrict, or refuse to publish user content that appears to violate these terms, the law, broker or exchange rules, or third-party rights.

11. Termination

You may terminate these terms at any time by stopping your cloud portfolios and ceasing use of the Software and Services. We may terminate these terms, and your access to the Software and Website, on notice if you materially breach these terms or if continued operation would expose us or other users to unacceptable legal or security risk. We may suspend, restrict, or delay access without prior notice where needed to respond to suspected fraud, credential compromise, malware, broker or exchange abuse, sanctions or AML risk, market-abuse reports, lawful requests from authorities, emergency maintenance, infrastructure failure, or other operational safety events. Where we terminate without cause during a paid period, we will refund the unused portion of the service fees.

My Portfolio is not your broker, bank, payment institution, or AML compliance provider. AML/CFT identification, transaction monitoring, blocking, refusal, and reporting duties may be performed by your broker, bank, payment processor, or another regulated provider under rules applicable to them. Platform checks on our side do not confirm that your trading is lawful or compliant.

Sections of these terms that by their nature should survive termination - including the no-advice statement, the AS-IS disclaimer, the limitation of liability, intellectual property, and dispute resolution - will continue in force after termination.

12. Governing law and dispute resolution

These terms are governed by the laws of the Russian Federation, without regard to its conflict-of-laws principles. Either party may send a written pre-trial notice and allow 30 calendar days for response, but this voluntary process does not block any mandatory consumer right to contact a regulator or file a claim in court where the law allows immediate action. Disputes arising out of or relating to these terms will be brought in the competent courts of the Russian Federation, except where applicable consumer-protection law gives you the right to bring the dispute in another court, including the court of your residence or another venue protected by mandatory law. Nothing in this section limits any mandatory consumer right under the law of your country of residence.

13. Changes to these terms

We may update these terms from time to time. We will announce material changes on this page and, where the change affects users with paid Services, by email. Changes apply prospectively. We will not change the price, paid period, or material service limits for an already paid period without your consent, unless the change is required by law or is necessary for security and does not materially reduce the paid service. If a material adverse change affects your paid Services, you may cancel and receive a pro-rata refund for the unused paid period. If you do not accept the new terms, you may stop using the Services before the effective date.

14. Severability and entire agreement

If any provision of these terms is held to be unenforceable, the remaining provisions will continue in full force. These terms, together with the Privacy Policy and the Risk Disclosure, are the entire agreement between you and us with respect to the Software and the Website, and supersede any prior representations or agreements on the same subject.

15. Contact

Questions about these terms, support requests, privacy requests, and consumer claims can be sent to support@my-portfolio.ru. The registered address for legally significant notices is 142105, Podolsk, Podolskikh Kursantov St. 2, apt. 34; the support phone for consumer requests is +7 916 650-96-53; and consumer support business hours are Mon-Fri, 10:00-19:00 MSK.