These Terms of Service ("Terms") govern your access to and use of Lead-Lag Atlas, the advisor intelligence platform located at atlas.leadlagmedia.com (the "Service" or "Atlas"). The Service is provided by Lead Lag Publishing, LLC, doing business as Lead-Lag Media® ("we," "our," or "us"). By accessing the Service, creating an account, logging in, or otherwise using any portion of Atlas, you ("you" or "User") agree to be bound by these Terms. If you do not agree, you may not access or use the Service.
1. Description of the Service
Atlas is a private, login-gated advisor intelligence platform that aggregates and analyzes publicly available data from the United States Securities and Exchange Commission ("SEC") Investment Adviser Public Disclosure ("IAPD") system, including Form ADV Parts 1 and 2, Form 13F holdings filings, and supplemental enrichment from third-party providers (including, without limitation, Apollo.io, Hunter.io, and publicly available LinkedIn profile URLs). Atlas presents this data through search, filtering, dashboards, and a suite of artificial intelligence-driven analytical modules.
1A. AI-Driven Modules and Outputs
Atlas includes generative and probabilistic artificial intelligence ("AI") components that produce analytical outputs including but not limited to predictive rotation scores, "doppelgänger" advisor matching, portfolio X-rays, anti-pitch lists, lost-deal autopsies, wholesaler GPT briefs, territory plans, conference heat maps, "have we met" relationship surfacing, cadence optimization, and listening post signal aggregation (collectively, the "AI Outputs"). By accessing the Service you acknowledge and agree to the following:
- Heuristic and Probabilistic Nature. AI Outputs are probabilistic estimates generated by statistical models and large language models. They are not deterministic, are not guaranteed accurate, and may contain errors, hallucinations, omissions, stale data, or incorrect inferences. They are intended as research aids only.
- Not Investment Advice. No AI Output constitutes investment advice, a recommendation to buy, sell, or hold any security, a solicitation, an offer, a fiduciary recommendation under the Investment Advisers Act of 1940, or any form of regulated advice under federal or state securities laws. Atlas is not a registered investment adviser. AI Outputs are informational research tools intended for use by financial professionals operating under their own fiduciary and compliance frameworks.
- Human Review Required. You agree that you will not rely on any AI Output as the sole basis for any business, regulatory, compliance, marketing, sales, investment, or trading decision. You will independently verify all AI Outputs against primary sources (including SEC EDGAR filings, the underlying IAPD records, and your own internal data) before taking any action.
- Source Attribution. Where Atlas surfaces underlying SEC filings, public 13F holdings, Form ADV disclosures, or other primary sources, you are responsible for reviewing those primary sources directly. Atlas's aggregation, summarization, scoring, ranking, or interpretation of those sources may differ from the sources themselves.
- Model Updates and Drift. Underlying AI models, training data, prompts, scoring weights, and ranking algorithms may change without notice. Outputs generated on one date may differ from outputs generated on a later date using the same inputs.
- Tenant-Scoped Access. Where Atlas provides issuer-specific or firm-specific views (for example, holdings filtered to a particular ticker family, dashboards scoped to a single issuer client), that scoping is configured by us and is not a security boundary or compliance attestation. You agree to use the Service only within the scope of access we authorize for you.
- No Customer Lists, No PII Inputs. You will not upload, paste, transmit, or otherwise input into Atlas any client lists, customer personally identifiable information, account numbers, holdings data of your underlying clients, non-public material information, or any data that you do not have the legal right to process.
- Logging. We log AI prompts, responses, and metadata for safety, abuse prevention, debugging, model improvement, and dispute resolution. See the Privacy Policy for details.
1B. Roles of Issuers, Advisors, and Partners
- Issuer Clients. If you access Atlas as an authorized representative of an ETF issuer, fund sponsor, or asset manager under contract with us, your firm is responsible for ensuring that your use of Atlas complies with your firm's compliance program, your firm's policies on the use of third-party data and AI tools, FINRA rules (where applicable), SEC marketing rule restrictions, and any internal review requirements.
- FA Services Network Advisors. If you access Atlas as an enrolled FA Services Network advisor, you represent that you are an SEC- or state-registered investment adviser representative, broker-dealer registered representative, insurance producer, or other duly licensed financial professional, and that your use of Atlas is consistent with your firm's compliance policies and applicable regulations.
- Vendor and Referral Partners. If you access Atlas as a vendor or referral partner, your use is limited to the activities contemplated by your written partnership agreement with us.
- No Reliance on Atlas for Fiduciary Outputs. Regardless of your role, you remain solely responsible for any output, communication, marketing piece, sales pitch, suitability analysis, or regulatory filing that you produce using or informed by Atlas data.
2. Use of the Service
2.1 License
Subject to your continuing compliance with these Terms and your status as an Authorized Client, we grant you a limited, personal, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Service for your own internal business research purposes. All rights not expressly granted are reserved.
2.2 Service Rules
- You will not access the Service except through the user-facing interfaces we provide (web browser at atlas.leadlagmedia.com). You will not access the Service via automated means (scrapers, bots, headless browsers, scripted clients, AI agents acting as you) except where we have expressly authorized such access in writing.
- You will not (a) reverse engineer, decompile, or disassemble the Service or any part of it; (b) attempt to extract source code; (c) circumvent or attempt to circumvent any authentication, access control, rate limit, or tenant-scoping mechanism; (d) interfere with or disrupt the Service; (e) probe, scan, or test the vulnerability of the Service; (f) impersonate any other person; (g) share your login credentials with any other person; (h) use the Service to send unsolicited bulk communications; (i) use the Service in a manner that violates any applicable law, including securities, privacy, anti-spam, or data protection laws.
2.3 AI-Specific Prohibited Conduct
In addition to the rules above, you agree that you will NOT:
- Use the Service to generate content intended to deceive, defraud, or mislead any person, including the creation of fabricated advisor profiles, fabricated holdings data, fabricated regulatory filings, or fabricated quotations.
- Use the Service to generate marketing, sales, or solicitation materials that present AI Outputs as primary research, audited data, or official SEC filings without clear and conspicuous disclosure of the AI-generated nature of the content.
- Use the Service to generate investment recommendations, suitability analyses, or fiduciary advice for delivery to retail investors without independent human review by a qualified, licensed professional.
- Use the Service to train, fine-tune, or otherwise develop any competing AI model, advisor database, or commercial product.
- Use the Service to reconstruct, copy, or rebuild any portion of the underlying advisor database for distribution outside your firm.
- Use the Service to circumvent any third-party data provider's terms of service (including SEC.gov, Apollo.io, Hunter.io, or LinkedIn).
- Use the Service to send unsolicited commercial email, SMS, or other communications in violation of the CAN-SPAM Act, the Telephone Consumer Protection Act, state anti-spam laws, or any applicable law.
- Use the Service to generate, store, or transmit content that is unlawful, defamatory, harassing, threatening, or discriminatory.
- Use any AI Output as the sole basis for any regulatory filing, compliance attestation, suitability determination, or fiduciary decision.
3. Proprietary Rights
The Service, its software, user interface, design, AI prompts, AI scoring models, aggregation logic, dashboards, and all related materials (other than User-submitted data and underlying public-domain SEC data) are owned by us or our licensors and are protected by United States and international copyright, trademark, trade secret, and other intellectual property laws. "Lead-Lag Media," "Lead-Lag Atlas," "Lead-Lag Report," and associated logos are trademarks of Lead Lag Publishing, LLC. SEC IAPD data and Form ADV/13F filings are public records and remain in the public domain; our aggregation, normalization, and presentation of those records is our proprietary work product.
4. Fees
The Service is provided to Authorized Clients at no separate charge as part of, and contingent upon, your active engagement with Lead-Lag Media. There is no separate Atlas subscription fee. We reserve the right to introduce paid tiers in the future on prospective notice. California Civil Code §1789.3 Notice: Under California Civil Code §1789.3, California users are entitled to the following consumer rights notice: complaints regarding the Service or to receive further information regarding use of the Service may be sent to us at the contact address above, or to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (800) 952-5210.
5. Privacy
Your use of the Service is subject to our Privacy Policy, which is incorporated by reference into these Terms. By using the Service you consent to the data collection, use, and disclosure practices described in the Privacy Policy.
6. Security
We implement commercially reasonable administrative, technical, and physical safeguards designed to protect the Service and the data it processes. However, no system is perfectly secure. You are responsible for keeping your login credentials confidential, for any activity that occurs under your account, and for notifying us promptly at the contact address above if you suspect any unauthorized access. We may suspend or revoke access at any time to protect the Service or its users.
7. Third-Party Links and Data Sources
The Service surfaces data from and may contain links to third-party sources including SEC EDGAR, SEC IAPD, Apollo.io, Hunter.io, LinkedIn, and others. We do not control and are not responsible for the content, accuracy, completeness, timeliness, privacy practices, or terms of service of any third-party source. Your interactions with third-party sources are at your own risk.
8. Representations and Warranties
You represent and warrant that: (a) you are at least 18 years old; (b) you have the legal capacity and authority to enter into these Terms and to bind any entity on whose behalf you access the Service; (c) you are an Authorized Client at the time of access; (d) you will use the Service in compliance with all applicable laws and regulations and with your firm's compliance policies; (e) you have all rights and consents necessary to provide any data you submit to the Service; (f) you will not use the Service in violation of any third-party right; (g) all information you provide to us is accurate, complete, and current.
9. Indemnification and Records Preservation
You agree to indemnify, defend, and hold harmless Lead Lag Publishing, LLC, its affiliates, officers, directors, employees, agents, contractors, licensors, and partners from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising from or related to: (a) your use of or access to the Service; (b) your violation of these Terms; (c) your violation of any third-party right, including any intellectual property, privacy, publicity, or contractual right; (d) your violation of any applicable law or regulation, including securities, privacy, data protection, anti-spam, and AI-specific regulations; (e) any content, communication, marketing piece, sales pitch, regulatory filing, or other output that you generate, distribute, or rely upon using AI Outputs from the Service; (f) any unauthorized data input by you into the Service, including client lists, customer PII, account information, or non-public material information.
Records Preservation. In the event of any actual or threatened claim, investigation, or litigation involving your use of the Service or any AI Output, you agree to preserve all relevant records (including prompts, responses, screenshots, exports, and communications) and to provide reasonable cooperation in our defense or investigation.
10. Disclaimer of Warranties — Service AS-IS
THE SERVICE, INCLUDING ALL DATA, AI OUTPUTS, DASHBOARDS, SCORES, AND ANALYTICAL CONTENT, IS PROVIDED "AS IS" AND "AS AVAILABLE," WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, ACCURACY, COMPLETENESS, RELIABILITY, TIMELINESS, AVAILABILITY, FREEDOM FROM ERROR, FREEDOM FROM VIRUSES, AND ANY WARRANTY ARISING FROM COURSE OF DEALING OR USAGE OF TRADE.
NO UPTIME OR SLA. WE MAKE NO COMMITMENT REGARDING SERVICE AVAILABILITY, UPTIME, RESPONSE TIME, OR CONTINUITY. THE SERVICE MAY BE INTERRUPTED, SUSPENDED, MODIFIED, OR DISCONTINUED AT ANY TIME WITHOUT NOTICE.
NO DATA-ACCURACY GUARANTEE. SEC IAPD AND 13F DATA IS PROVIDED BY THIRD-PARTY GOVERNMENT SOURCES AND IS REFRESHED ON A LAG. EMAIL ENRICHMENT FROM APOLLO.IO AND HUNTER.IO IS PROBABILISTIC AND CAN INCLUDE INVALID, STALE, OR INCORRECT ADDRESSES. ADVISOR PROFILES MAY BE OUT OF DATE. WE DO NOT WARRANT THE ACCURACY OF ANY SUCH DATA.
NO AI ACCURACY WARRANTY. AI OUTPUTS ARE PROBABILISTIC AND MAY CONTAIN ERRORS, HALLUCINATIONS, OR OMISSIONS. WE DO NOT WARRANT THAT AI OUTPUTS WILL BE ACCURATE, COMPLETE, CURRENT, OR FIT FOR ANY PARTICULAR PURPOSE.
NO INVESTMENT ADVICE. THE SERVICE IS NOT INVESTMENT ADVICE, IS NOT A RECOMMENDATION OR SOLICITATION, AND IS NOT A SUBSTITUTE FOR YOUR OWN INDEPENDENT JUDGMENT, COMPLIANCE REVIEW, OR PROFESSIONAL ADVICE. NOTHING IN THE SERVICE CREATES A FIDUCIARY, ADVISORY, BROKER-DEALER, OR OTHER REGULATED RELATIONSHIP BETWEEN US AND YOU.
California Civil Code §1542 Waiver. If you are a California resident, you expressly waive and relinquish all rights and benefits which you have or may have under §1542 of the California Civil Code or any analogous law of any other state or jurisdiction, which provides: "A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release, and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party."
11. Limitation of Liability
TO THE MAXIMUM EXTENT PERMITTED BY LAW, IN NO EVENT WILL WE OR OUR AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, CONTRACTORS, LICENSORS, OR PARTNERS BE LIABLE TO YOU FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING WITHOUT LIMITATION LOST PROFITS, LOST REVENUE, LOST DATA, LOST GOODWILL, BUSINESS INTERRUPTION, REGULATORY FINES, OR COMPLIANCE COSTS, ARISING FROM OR RELATED TO THE SERVICE, ANY AI OUTPUT, ANY DATA SURFACED BY THE SERVICE, OR THESE TERMS, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE), AND EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
OUR TOTAL CUMULATIVE LIABILITY TO YOU FOR ANY AND ALL CLAIMS ARISING FROM OR RELATED TO THE SERVICE OR THESE TERMS WILL NOT EXCEED ONE HUNDRED U.S. DOLLARS ($100.00). YOU ACKNOWLEDGE THAT BECAUSE THE SERVICE IS PROVIDED TO YOU AT NO CHARGE, THIS LIMITATION IS A FUNDAMENTAL BASIS OF THE BARGAIN AND THAT WE WOULD NOT PROVIDE THE SERVICE WITHOUT IT.
12. Term and Termination
These Terms remain in effect for as long as you access the Service. Access automatically terminates, with or without notice, when your underlying engagement with Lead-Lag Media ends, lapses, is suspended, or is no longer in good standing. We may also suspend or terminate your access at any time, for any reason or no reason, with or without notice, including for any actual or suspected violation of these Terms. Upon termination, your license to access the Service ends immediately. Sections 1A, 1B, 3, 8, 9, 10, 11, 13, and 16 survive termination.
13. Governing Law; Arbitration; Class Action Waiver
These Terms are governed by the laws of the State of New York, without regard to its conflict of laws principles. Any dispute, claim, or controversy arising out of or relating to these Terms or the Service will be resolved exclusively by binding individual arbitration administered by JAMS under its Streamlined Arbitration Rules and Procedures, seated in New York County, New York, conducted in English, before a single arbitrator. The arbitrator's decision will be final and binding. YOU AND WE EACH WAIVE ANY RIGHT TO A JURY TRIAL AND ANY RIGHT TO PARTICIPATE IN A CLASS, COLLECTIVE, OR REPRESENTATIVE ACTION. Notwithstanding the foregoing, either party may seek injunctive or other equitable relief in any court of competent jurisdiction to protect its intellectual property rights.
14. Confidential Information
You may receive information about the Service, its features, AI prompts, scoring methodology, roadmap, pricing for paid tiers, or other commercial details that is non-public ("Confidential Information"). You agree to hold Confidential Information in confidence, to use it only in connection with your authorized use of the Service, and not to disclose it to any third party except as required by law. This obligation survives termination.
15. DMCA
If you believe that content available on the Service infringes your copyright, please send a notice that complies with 17 U.S.C. §512(c)(3) to michaelgayed@leadlagmedia.com with the subject line "DMCA Notice." We may remove or disable allegedly infringing content and terminate the access of repeat infringers.
16. General
Entire Agreement. These Terms and the Privacy Policy constitute the entire agreement between you and us regarding the Service and supersede all prior agreements. Severability. If any provision is held unenforceable, the remaining provisions remain in full force. No Waiver. Our failure to enforce any provision is not a waiver of that provision. Assignment. You may not assign these Terms; we may assign without notice. Notices. We may give notice by posting on the Service, by email to the address associated with your account, or by any other reasonable means. Modifications. We may modify these Terms at any time by posting a revised version on the Service with an updated "Last Updated" date. Material changes will be highlighted where reasonably practical. Your continued use of the Service after the effective date of a modification constitutes acceptance. Force Majeure. We are not liable for any delay or failure caused by circumstances beyond our reasonable control. Relationship of the Parties. Nothing in these Terms creates a partnership, joint venture, employment, agency, or fiduciary relationship between you and us.
17. Contact
Questions about these Terms should be directed to:
Lead Lag Publishing, LLC
DBA Lead-Lag Media®
Email: michaelgayed@leadlagmedia.com
By using Lead-Lag Atlas, you acknowledge that you have read, understood, and agree to be bound by these Terms of Service and the linked Privacy Policy.