Terms of Use

1. Scope of the Service

Pactolio is a research and data aggregation platform. It normalizes publicly-available SEC filings — Form 13F-HR institutional disclosures and Form 4 insider transactions — and presents them through structured pages, tables, and charts. Pactolio is not a registered investment adviser, broker-dealer, exchange, alternative trading system, or any form of regulated financial-services provider.

2. Not Investment Advice

Nothing on this site constitutes investment advice, a recommendation, a solicitation, or an offer to buy, sell, or hold any security or financial instrument. Furthermore, the content provided does not constitute financial analysis (Finanzanalyse) or investment recommendations under the German Securities Trading Act (WpHG) or the EU Market Abuse Regulation (MAR). Quarter-over quarter changes in 13F positions reflect a combination of active trading and price movement and should not be read as explicit buy or sell signals. Insider transaction signals are descriptive of past-filed activity and are not forward looking. You assume full responsibility for your own investment decisions and should conduct independent due diligence before acting on any information you find here.

3. Acceptable Use

You agree not to:

• Use the site or its data for any unlawful purpose or in a manner that violates any applicable securities, tax, sanctions, or anti-money-laundering law.
• Attempt to gain unauthorized access to the site or to any underlying systems, servers, or databases.
• Scrape, crawl, or otherwise extract data from the site at a rate or in a manner inconsistent with our robots.txt directives, or in any way that imposes a disproportionate load on our infrastructure.
• Re-publish substantial portions of the dataset (entire fund holdings tables, full Form 4 transaction logs, etc.) without attribution and a backlink to the source page.
• Misrepresent the source of the data, present derived figures as Pactolio's own opinions when they are not, or strip the page's data-source attribution.

We reserve the right to temporarily or permanently block IP addresses or users who violate this Acceptable Use policy, without prior notice.

4. Attribution & Citation

The underlying SEC filings are public records and not subject to copyright. Pactolio's normalization, presentation, aggregation, schema markup, and editorial copy (the “Platform Material”) are protected as databases and original works, including protection under § 87b of the German Copyright Act (UrhG). If you cite or quote the Platform Material in research, journalism, or internally-distributed analysis, please cite the page URL and identify Pactolio as the source.

Machine-readable citation guidance for AI / LLM operators is provided in our llms.txt.

5. No Warranties & Third-Party Data

The site and its data are provided “as is” and “as available” without warranty of any kind, either express or implied. Our data is derived from public SEC filings submitted by third parties. We explicitly disclaim any liability for errors, omissions, or misstatements made by the original filers. While we re-ingest filings within 24-48 hours of EDGAR publication and apply pipeline validation, we do not warrant that the data is complete, accurate, current, error-free, or uninterrupted. Filing amendments, EDGAR outages, and our own pipeline errors can all cause discrepancies; report any you find via Contact.

6. Limitation of Liability

To the maximum extent permitted by applicable law, Pactolio, its operator, affiliates, and contributors shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits, revenues, investment returns, data, goodwill, or trading opportunities, whether incurred directly or indirectly, arising out of your access to, use of, or inability to use the site. Mandatory statutory liability — including liability for intentional conduct, gross negligence, injury to life, body, or health, and product liability under the Produkthaftungsgesetz — remains unaffected.

7. Changes to These Terms

When material changes are made to these terms, the updated version is published at this URL with a new effective date below. Substantive changes are also reflected on the Changelog. Continued use of the site after a material change constitutes acceptance of the updated terms.

8. Class Action Waiver (US & Non-EU Users)

For users outside the European Union, you agree that any dispute resolution proceedings will be conducted only on an individual basis and not in a class, consolidated, or representative action. You waive any right to bring or participate in a class action against Pactolio or its operator.

9. Governing Law & Severability

These terms are governed by the laws of the Federal Republic of Germany, excluding its conflict-of-laws rules. Place of jurisdiction for all disputes arising out of or in connection with these terms is, to the extent permitted by law, Ulm, Germany. Mandatory consumer-protection provisions in the consumer's country of residence remain unaffected.

If any provision of these Terms is or becomes invalid, the validity of the remaining provisions shall not be affected.

10. Contact

The operator's contact details are listed in the Impressum. For any question about these terms, write to the address listed there.

Last updated: 2026-06-07