Investment Disclosures

Last updated: August 15, 2026

These Investment Disclosures form part of the Terms of Service. US residents should also read the US Terms Supplement.

1. The short version

Luum gives you analytics about your own portfolio. It does not tell you what to do with your money.

Everything on the Platform is educational and informational. Nothing on it is a recommendation to buy, hold, or sell a security, a suitability assessment, financial planning advice, or tax advice. You make your own decisions, and you bear the results of them.

2. What Luum is, and what it is not

Luum operates a portfolio analytics platform. It measures what you already own, compares it against targets you set, and projects that arithmetic forward under assumptions you can see and change.

Luum is not registered as an investment dealer, adviser, portfolio manager, exempt market dealer, or investment fund manager under Canadian securities legislation, and is not a member of CIRO. Nothing in these disclosures should be read as suggesting otherwise.

We do not, and cannot:

Hold, receive, or have custody of your money or securities.
Place, route, or execute orders, or transmit instructions to any brokerage. Brokerage connections are read-only.
Manage a portfolio on your behalf, on a discretionary basis or otherwise.
Assess whether any investment, strategy, or account type is suitable for you.
Recommend a specific security to you.

The Platform does not offer, solicit, or distribute any security, and nothing on it is an offer or solicitation in any jurisdiction where that would be unlawful.

3. No advice, and no reliance

All content is general in nature. It does not take into account your full financial situation, obligations, tax position, time horizon, risk capacity, or needs — even where you have given us some of that information.

Where the Platform asks for your goal, risk tolerance, age range, net worth range, or skill level, we use those answers to choose defaults, to decide what to show you, and to phrase educational content. We do not use them to determine that any investment is appropriate for you. Nothing we show becomes a recommendation because you told us about yourself.

You should consult a registered adviser, portfolio manager, or other qualified professional — and a tax professional for tax matters — before acting.

4. Risk

Investing involves risk, including the loss of your entire principal.
Past performance does not guarantee, indicate, or predict future results.
Projections and simulations are illustrative arithmetic, not forecasts. They will be wrong to some degree, and can be wrong by a large margin.
Diversification and rebalancing manage some risks; they do not eliminate risk and do not ensure a profit or protect against loss.
Market data on the Platform is delayed and may be incomplete or inaccurate.

5. What each part of the Platform does and does not tell you

Surface	What it is	What it is not
Dashboard, net worth	A total of what you have recorded, converted to one currency at delayed FX rates	A statement of account. Your brokerage's and bank's records are authoritative
Holdings and allocation	Your positions grouped by asset class, sector, geography, and currency	An opinion that any allocation is right for you
Returns and performance	Time- and money-weighted returns computed from the transactions and cash flows you provided	A verified or GIPS-compliant performance record. Accuracy depends entirely on your data
Benchmark comparison	Your return alongside a published index	A claim that you should have held the index, or a like-for-like comparison
Allocation drift and rebalancing	The gap between your holdings and targets you set yourself, and the trades that would close it	A recommendation to place those trades. Rebalancing has tax and cost consequences we may not model
Insights, risks, and action items	Observations generated from your data, ranked for relevance	Instructions, or a view on the merits of any security
Strategy projections and Monte Carlo	Arithmetic and simulation under assumptions shown on the page and editable by you	A forecast, a guarantee, or a probability that your goal will be met in reality
What-if simulations	Recalculation of your portfolio under a change you specify	A suggestion that you make that change
Ticker scores and fit scores	Formulaic scores from published fundamentals and price data, plus a mechanical comparison against targets you set. Methodology and thresholds are published	A rating, a recommendation, a price target, or an opinion that a security is good, bad, or suitable for you
Explore, watchlists, news, IPO information	Third-party market data and reference information you asked to see	A recommendation to buy, sell, or watch anything. Watchlists are lists you build
Tax Centre	Capital gains on the average cost base method, contribution room estimates, and report exports	Tax advice or a tax return. See Section 7
AI assistant and Ask AI	Language-model answers grounded in your own portfolio figures	Advice, and not necessarily correct. See Section 8
Help centre content	Educational explanation of concepts and of how the Platform works	Advice about your own situation

6. Limitations you should know about

Your data drives everything. If a cost base, transaction, dividend, or account type is missing or wrong, every figure derived from it is wrong — returns, gains, drift, income, fees, and projections included. We cannot detect most such errors, and our staff cannot inspect or correct your data.

Market data is delayed and is supplied by third-party vendors. Prices, fundamentals, ETF holdings, corporate actions, and news may be stale, incomplete, or wrong. Do not use the Platform for real-time trading decisions.

Foreign exchange. Multi-currency values are converted at rates that are themselves delayed, and historical conversions may use a different rate than your brokerage applied to the actual transaction.

Scores and models are formulas, not judgments. Ticker scores are computed mechanically from available data using published thresholds. Where an input is missing, the score is computed on what remains or withheld. A score is not the product of human analysis of the business.

Projections rest on assumptions. Contribution rates, return assumptions, inflation, and time horizons come from you or from defaults we chose. Monte Carlo output describes the behaviour of the model, not the probability of a real-world outcome. Changing an assumption slightly can change the result substantially.

Private and manually tracked holdings — property, private companies, collectibles, liabilities — are valued at the figures you enter. We do not verify or independently value them.

7. Tax

Tax summaries on the Platform are informational only and are not tax advice. The Platform does not prepare or file tax returns.

Capital gains use the average cost base (ACB) method, pooled per security across your non-registered accounts.
The calculations do not apply the superficial loss rules, and do not allocate cost base on a spin-off.
Foreign-currency dispositions are converted at the published rate for each transaction date, falling back to the most recent prior published rate where a date has none. Where no rate is available for a currency, the affected security is excluded from the report and identified rather than converted at an assumed rate.
Return of capital, phantom distributions and stock splits are reflected only where they appear in the transaction history you provide or import. The Platform has no independent corporate-actions feed. Mergers, spin-offs, attribution rules and foreign property reporting are not reflected.
Gains inside registered accounts are not reported, as they are not reportable dispositions.
Transactions the Platform cannot account for — a disposition with no purchase history, a disposition exceeding the units on record — are identified on the report rather than omitted from it, but they are not computed.
Contribution room figures are estimates. The Canada Revenue Agency's records are authoritative.
Tax slips and reports issued by your financial institution are authoritative for filing.

Verify with the CRA or a qualified tax professional before you file or act.

8. Artificial intelligence

The AI assistant, AI insights, and AI observations use large language models. Outputs are grounded in figures retrieved from your own portfolio rather than invented, and the assistant is instructed not to give advice or make recommendations.

Nonetheless:

AI output can be wrong, including in confident and plausible-sounding ways. Verify any figure against the underlying data before relying on it.
AI output is not investment, tax, or legal advice, and is not a recommendation, regardless of how it is phrased.
If the assistant appears to recommend a course of action, treat that as a limitation of the model, not as advice from us. Please report it to support@luumwealth.com.

9. Conflicts of interest and how we are paid

We are paid by our users, through subscriptions and AI credit purchases.

We receive no compensation from any issuer, fund manager, or ETF provider for including, scoring, ranking, or displaying a security.
We receive no payment for order flow, and no referral, revenue-share, or introduction fee from any brokerage or dealer, including through our brokerage-connection provider.
We do not sell advertising, sponsored placement, or sponsored content.
We do not sell or license user data.
We hold no proprietary positions and take no position in any security displayed on the Platform.

If any of this changes, we will disclose it here and in-product before the change takes effect.

10. Jurisdiction

The Platform is currently offered to residents of Canada. It is not directed at residents of any other jurisdiction, and nothing on it is an offer or solicitation where that would be unlawful.

US availability is planned but not open. When it opens, the US Terms Supplement will set out the equivalent disclosure under US federal securities law.

11. Contact

Questions about these disclosures: legal@luumwealth.com