Terms of Service

1. Acceptance of terms

By accessing or using Tulir Portfolio Analysis (the "Service"), available at xraymyportfolio.com and operated by Tulir Systems LLC ("Tulir Systems", "we", "us"), you agree to be bound by these Terms of Service. If you do not agree to these terms, do not use the Service.

2. Description of the Service

Portfolio Analysis is a browser-based tool that allows you to add a portfolio file — a CSV export from Fidelity Investments or Charles Schwab, or a downloaded PDF account statement from your brokerage — and view analyses including, but not limited to, company-level fund look-through, sector and thematic exposure, fund overlap, correlation analysis, stress testing, concentration thresholds, security-level historical return figures and estimated dividend income, expense-ratio drag, fundamental ratings, target-allocation and tax-loss-harvesting analysis, Roth conversion and retirement withdrawal modelling, charitable-giving comparison, option delta exposure, and growth and Monte Carlo projections. Calculations on your portfolio are performed locally within your web browser; some figures about the securities themselves, such as their past returns, are calculated on our server from public data and sent to your browser. The Service also makes network requests: to classify the securities you hold, to fetch market data, and — if you are signed in — to save the portfolio an import produced, so that it is there the next time you return. The portfolio file you choose is not itself uploaded. Our Privacy Policy sets out each case, what is stored, and how to remove it. Which analyses are available to you depends on your plan; section 3 and the Pricing page set out the plans.

Signing in does three things. It opens the parts of the Service that need an account, including reading your own portfolio file. Market figures shown in the analyses come from our own server, which refreshes them on a schedule from public data sources, or from reference tables built into the Service; the Service can also fetch live data from Finnhub.io, a third-party financial data provider, using our own server-side API key rather than one you provide. And it means a portfolio you import is saved to your account — automatically, without a further prompt — along with anything you enter in the retirement planner. Third, it records which features you open, with the time, against your email address. Section 7 covers what that means for your data, and our Privacy Policy sets out exactly what is sent, what is kept and how to delete it.

3. Plans, billing and cancellation

The Service is offered on four plans — Free, Personal, Professional and Firm — set out with their prices on the Pricing page. The Free plan takes no payment. Personal and Professional are annual plans, Professional priced per seat; Firm is priced by agreement. There is no monthly plan.

Renewal. Personal and Professional renew automatically each year at the price then shown on the Pricing page, and we charge the card you used, unless you cancel first. We will email you at the address on your account 14 days before each renewal, with the amount and the date.

Cancelling. You can cancel at any time from Manage billing in your account, or by writing to hello@tulir.systems. Cancelling stops the next renewal. You keep the plan until the end of the year you have already paid for, and then your account moves to the Free plan. Your saved portfolio and planner entries stay yours (section 7).

Refunds. If you are not satisfied with a new subscription, write to hello@tulir.systems within 14 days of your first payment and we will refund it in full. After that we do not refund part of a year, or a renewal, except where the law requires it, or where we charged you in error. A refund goes together with ending the plan: your account moves to the Free plan from the day we issue it. Refunds go back to the card used, and your bank decides how long that takes.

Discount codes. A code reduces the first payment by the percentage shown at checkout. It cannot be combined with another code or applied to a renewal. If a payment that used a code is refunded, the code is not given back.

If we change the price. We will email you at least 30 days before a renewal at a new price, so that you can cancel first.

Firms paying by invoice. A firm that pays by invoice rather than by card is set up by agreement. Its plan starts when we receive payment and runs for the term on the invoice. It does not renew unless the firm agrees to a further invoice. Refunds follow the same rule as above, measured from the day we receive payment.

If you had an account before billing began. We will email you before billing begins to say what applies to your account, and the plan and end date shown under Account are the ones that apply. A saved portfolio and your planner entries remain yours and remain subject to section 7.

4. No financial advice

The Service is provided strictly for informational and educational purposes. Specifically:

• Fund holdings data is sourced from publicly available disclosures and approximations and may not reflect a fund's current, exact composition at any given moment
• Sector classifications, market-cap/style-box assignments, and "Fundamental Score" ratings are calculated using simplified, disclosed methodologies and approximate benchmarks — they are not the product of professional securities research or registered investment advice
• Stress test results, correlation estimates, and growth projections are mathematical models based on historical data and stated assumptions; actual market behavior may differ substantially from any projection or estimate shown
• Tax estimates anywhere in the Service — including the reallocation planner, the tax-loss harvesting scanner, the Roth conversion planner, the retirement withdrawal model and the charitable-giving comparison — rest on simplified assumptions, such as a flat long-term capital gains rate, or tax brackets that are held at this year’s levels or raised by an assumed inflation rate; your actual tax liability depends on your individual circumstances and should be confirmed with a tax professional before acting
• Nothing in the Service should be interpreted as a recommendation to buy, sell, hold, or otherwise transact in any security

5. No warranty

The Service is provided "as is" and "as available," without warranties of any kind, whether express or implied, including but not limited to warranties of accuracy, completeness, merchantability, fitness for a particular purpose, or non-infringement. We do not warrant that the Service will be uninterrupted, error-free, or that any data displayed (including third-party data from Finnhub) is accurate, current, or complete.

6. Limitation of liability

To the fullest extent permitted by law, Tulir Systems LLC shall not be liable for any direct, indirect, incidental, consequential, or special damages arising out of or in connection with your use of, or inability to use, the Service — including but not limited to investment losses, lost profits, or damages resulting from reliance on any information, analysis, or projection displayed by the Service.

You acknowledge that any investment decisions you make are made independently and at your own risk, and that you should conduct your own due diligence and consult appropriate professionals before acting on any information from this Service.

7. Your data and conduct

You are solely responsible for the data you choose to put into the Service, and for having the right to put it there. The portfolio file you select is read in your own browser and is not uploaded. If you are signed in, the result of reading it is saved to your account: the securities, their quantities and values, the account labels with what looks like an account number removed, and whatever you enter in the planners. Our Privacy Policy sets out the full list.

Keeping it, and getting rid of it. A saved portfolio is kept until you delete it, until a later import replaces it (our Privacy Policy says when), or until your account is deleted; the Service does not delete it for inactivity. Delete my data, on the upload screen, removes every portfolio and every planner entry from the live database immediately, with no undo in the product (copies can remain in our hosting provider’s automatic restore history for up to 30 days; our Privacy Policy explains), and having your account deleted, which you can ask us to do (section 14), removes them from the live database too. Some records are not removed by either; our Privacy Policy lists them. That describes how the Service works today and is not a promise to keep it: we do not undertake to keep any of it for any particular length of time, and it is not a backup: if the figures matter to you, keep your own statements. You retain all rights in what you put in; we claim none. We use it to produce the analyses you asked for, and otherwise only as our Privacy Policy describes — for example, to answer a support question, and to add the ticker symbols in it to a shared list of securities whose prices we refresh.

You agree not to use the Service for any unlawful purpose or in a manner that could damage, disable, or impair the Service or interfere with any other party's use of it.

8. Third-party services

The Service may link to or integrate with third-party services, including Finnhub.io, Google Fonts, the U.S. Securities and Exchange Commission's EDGAR system, and OpenFIGI. Cloudflare is listed separately and deliberately: it is not a service the Service links out to, it is the infrastructure the Service runs on, and a saved portfolio physically lives in a Cloudflare database. It holds that data as our provider rather than for any purpose of its own. We do not control and are not responsible for the content, accuracy, availability, or practices of any third-party service. Your use of any third-party service is governed by that service's own terms.

9. Intellectual property

The design, code and content of Portfolio Analysis are the property of Tulir Systems LLC.

Using the Service. The Free and Personal plans are licensed for the portfolios of your own household. The Professional and Firm plans are licensed for use in your practice, including analysing the portfolios of clients you advise — that is what those plans are sold for, and nothing in these terms restricts it. A seat is for one named person.

The software itself. Whatever your plan, you may not copy, reproduce, redistribute, resell or create derivative works from the Service's underlying code or design, and you may not make the Service available to anyone your plan does not cover, without prior written permission.

10. No fiduciary relationship

Use of the Service does not create a fiduciary, advisory, or any other special relationship between you and Tulir Systems LLC. We owe you no duty of care beyond what is expressly stated in these terms.

11. Changes to the Service and these terms

We may modify, suspend, or discontinue the Service, in whole or in part, at any time without notice. If the Service is discontinued altogether we will make a reasonable effort to tell account holders by email first, because a saved portfolio history cannot be reconstructed from anywhere else — though for that reason it should not be relied on as your only record. We may also update these Terms of Service from time to time; continued use of the Service after changes are posted constitutes acceptance of the revised terms. The "Last updated" date above reflects the most recent revision.

12. Governing law

These terms are governed by the laws of the State of New Jersey, United States, where Tulir Systems LLC is formed, without regard to conflict-of-law principles, to the extent permitted by applicable law.

13. No affiliation

Portfolio Analysis is operated by Tulir Systems LLC and is not affiliated with, endorsed by, or sponsored by Fidelity Investments, Charles Schwab, Finnhub, Cloudflare, or any brokerage, fund company, financial institution, or investor named within the Service. All trademarks and fund names referenced are the property of their respective owners and are used solely for descriptive and identification purposes.

14. Contact

Tulir Systems LLC is a New Jersey limited liability company, reachable at:

Portfolio Analysis is operated by Tulir Systems LLC. Questions about these terms can be sent to hello@tulir.systems, which is a monitored mailbox.

By continuing to use Portfolio Analysis, you confirm that you have read, understood, and agree to these Terms of Service and our Privacy Policy.