Terms of Service

Last updated: 22nd January 2026

These Terms of Service (”Terms”) govern your access to and use of the ACCE Investments Substack publication (the “Publication”), including all content, paid and free subscriptions, newsletters, reports, and related services (collectively, the “Services”).

By accessing, reading, or subscribing to the Publication, you acknowledge that you have read, understood, and agree to be bound by these Terms. If you do not agree with these Terms, you must not access or use the Services.

1. Nature of the Services

ACCE Investments provides independent, educational, and informational financial analysis intended for a general, non-retail audience. The Services consist of written research, commentary, analysis, and opinion based on publicly available information.

The Services do not constitute:

• Investment advice

• Investment research as defined under applicable EU regulations

• A recommendation, solicitation, or offer to buy or sell any financial instrument

• Personalised financial, legal, or tax advice

All content is provided solely for educational and informational purposes.

2. No Investment Advice

The content published by ACCE Investments does not take into account the individual investment objectives, financial situation, or risk tolerance of any reader.

You are solely responsible for your own investment decisions. Before making any investment decision, you should conduct your own independent analysis and, where appropriate, seek advice from a licensed and regulated investment professional.

Past performance is not a reliable indicator of future results. All investments involve risk, including the potential loss of capital.

3. Regulatory Status

ACCE Investments is not authorised or regulated as an investment firm, investment adviser, broker-dealer, or financial intermediary by any European or non-European regulatory authority.

The Publication is not produced in accordance with legal requirements designed to promote the independence of investment research and is therefore considered a non-independent research communication.

Nothing in the Services should be interpreted as triggering regulatory protections applicable to regulated investment services.

4. Accuracy of Information

The content is based on sources believed to be reliable at the time of publication, including company disclosures, regulatory filings, and reputable third-party sources. However:

• No representation or warranty is made regarding accuracy, completeness, or timeliness

• Information may become outdated without notice

• Errors or omissions may occur

ACCE Investments has no obligation to update, revise, or correct previously published content.

5. Opinions and Forward-Looking Statements

Any opinions, estimates, forecasts, scenarios, or forward-looking statements reflect the author’s judgment at the time of writing and are subject to change without notice.

Actual outcomes may differ materially from any forward-looking statements expressed or implied. No assurance is given that any scenario, expectation, or outcome will be achieved.

6. Conflicts of Interest

The author and/or ACCE Investments may hold positions in the securities or financial instruments discussed in the Publication.

Such positions may be entered into, modified, or exited at any time without notice. The existence of a position does not constitute a recommendation or endorsement.

ACCE Investments is under no obligation to disclose the size, timing, or direction of any such positions.

7. Subscriptions, Payments, and Refunds

7.1 Subscriptions

Paid subscriptions grant access to premium content for the duration of the subscription period. Subscription terms, pricing, and billing frequency are determined by Substack and displayed at the time of purchase.

7.2 Payments

All payments are processed by Substack and its payment providers. ACCE Investments does not store or process payment information directly.

7.3 Refunds

Unless otherwise required by applicable law, all subscription fees are non-refundable, including for partially used subscription periods.

8. Intellectual Property

All content published as part of the Services, including text, analysis, reports, charts, and branding, is the intellectual property of ACCE Investments, unless otherwise stated.

You may:

• Read and download content for personal, non-commercial use only

You may not:

• Reproduce, distribute, republish, or transmit content

• Use content for commercial purposes

• Create derivative works based on the content

Without the prior written consent of ACCE Investments, except where permitted by law.

9. Prohibited Use

You agree not to:

• Use the Services for unlawful or fraudulent purposes

• Misrepresent the content as investment advice or recommendations

• Scrape, copy, or systematically extract content

• Interfere with the operation or security of the Services

10. Limitation of Liability

To the fullest extent permitted by law, ACCE Investments shall not be liable for any direct, indirect, incidental, consequential, or special damages, including but not limited to:

• Investment losses

• Loss of profits or opportunity

• Reliance on published content

Arising out of or in connection with the use of the Services.

Your sole remedy for dissatisfaction with the Services is to discontinue use.

11. Indemnification

You agree to indemnify and hold harmless ACCE Investments from any claims, losses, damages, liabilities, and expenses arising from:

• Your use of the Services

• Your violation of these Terms

• Your misuse or misrepresentation of the content

12. Third-Party Links and Content

The Services may contain links to third-party websites or references to third-party content. ACCE Investments does not control, endorse, or assume responsibility for such content.

Access to third-party resources is at your own risk.

13. Termination

ACCE Investments reserves the right to suspend or terminate access to the Services at any time, without notice, for conduct that violates these Terms or is otherwise harmful to the Publication or its readers.

14. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of Spain, without regard to conflict of law principles.

Any disputes arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of Madrid, Spain, unless otherwise required by mandatory law.

15. Changes to These Terms

ACCE Investments may update these Terms from time to time. Any changes will be effective upon publication. Continued use of the Services after changes constitutes acceptance of the revised Terms.

16. Contact Information

For questions regarding these Terms, please contact us.

By accessing or subscribing to the Publication, you confirm that you have read, understood, and agreed to these Terms of Service.