Our Legal
Commitments

COPYWINS CONTENT POLICY

This Content Policy describes the rules for content published on the CopyWins platform at copywins.com (the “Platform”). It applies to all creators and to anyone who posts content on the Platform. This Policy is incorporated into the CopyWins Terms of Service and the CopyWins Creator Agreement, and capitalized terms used but not defined in this Policy have the meanings given in those documents. CopyWins enforces this Policy at its discretion and may remove content, suspend accounts, withhold payouts, and take other action consistent with the Terms of Service and the Creator Agreement. Enforcement decisions reflect CopyWins's judgment based on the totality of circumstances. Examples in this Policy are illustrative and not exhaustive.

1. The Spirit of This Policy

CopyWins is a publishing platform for independent creators who share market analysis, sports analysis, and educational content. The Platform is not an investment adviser, broker-dealer, sportsbook, or licensed sports information service. The categories below exist so that the Platform can preserve its character as a publishing platform and so that creators do not unintentionally cross into regulated activity that requires licensure or registration. Most creators will never need to think about these rules; they apply at the edges.

2. Prohibited Content

The following content is prohibited and will be removed. Creators who post such content may be suspended or terminated.

2.1 Personalized Advice

Creators must publish to their subscriber population generally, not to individual users. The following are prohibited:

• Tailoring picks or recommendations to a specific user's portfolio, account size, financial situation, risk tolerance, or sporting preferences.

• Responding to user questions in direct messages, private channels, or comment threads with content that constitutes individualized advice.

• Offering one-on-one consultations, individualized portfolio reviews, or personalized betting strategies, whether for additional compensation or otherwise.

• Promising specific outcomes for a specific user.

Creators may answer general questions in public comment threads where the answer is responsive to the published Content and is directed to the subscriber population generally. Creators may direct users to professional advisors for individualized questions.

2.2 Guarantees of Performance or Outcomes

Creators must not state, imply, or suggest that any pick will succeed, that any specified return is assured, or that any user will profit. The following are prohibited:

• “Guaranteed winner.”

• “Lock of the day,” “absolute lock,” “sure thing.”

• “Can't lose.”

• “100% accuracy,” “never wrong,” “always profitable.”

• Promises of specific dollar returns or percentage gains.

• Promises that following the creator will replace a job, generate passive income, or produce financial independence.

Creators may offer their opinion or analysis, identify what they consider their highest-conviction picks, and discuss probabilities. The line is between sharing opinion and promising outcomes.

2.3 Unsubstantiated or Cherry-Picked Performance Claims

Performance figures must be capable of substantiation from published Content and must reflect the creator's full record over the measurement period. The following are prohibited:

• Self-reported win rates or returns that exclude losses.

• Performance figures based on a curated subset of picks.

• Backtested or simulated results presented as actual results.

• Screenshots of brokerage or sportsbook accounts presented as proof of overall performance without context.

• Performance figures without the universe of picks measured and the measurement period.

• Aggregate performance claims (“I'm up 400% this year”) without the underlying record on the Platform.

Creators consent to CopyWins calculating and displaying performance figures from their published Content using the Platform's methodology, as described in the Creator Agreement.

2.4 Forex and Futures Signals (Interim Restriction)

Until further notice, creators may not publish actionable signals or trade recommendations on retail foreign exchange (forex) or futures contracts. This restriction exists because such content typically requires registration as a Commodity Trading Advisor under the Commodity Exchange Act. The following are specifically prohibited:

• Specific entry, exit, stop, or target levels on currency pairs (e.g., EUR/USD, GBP/JPY).

• Specific entry, exit, stop, or target levels on futures contracts (e.g., E-mini S&P, crude oil futures, gold futures).

• Calls to action to enter or exit forex or futures positions.

Educational commentary about forex or futures markets remains permitted. Examples of permitted educational content include explanations of how a forex pair tends to behave around economic announcements, discussion of futures contract specifications, and general macro analysis. The distinction is between teaching and signaling.

Creators who are registered Commodity Trading Advisors or who qualify for an exemption may apply for an exception by contacting compliance@copywins.com with documentation. Any exception, if granted, will require additional creator-side disclosures.

2.5 Market Manipulation

The following are prohibited under all circumstances:

• Pump-and-dump schemes, including coordinated promotion of thinly traded stocks or tokens with the intent to sell into the resulting price movement.

• Wash trading, spoofing, or any form of trade manipulation.

• Coordinating the timing or content of picks across creators to create artificial market activity.

• Front-running of picks (recommending an asset to subscribers after taking a position with the intent to sell into subscriber buying).

• Material misrepresentations about an asset, an issuer, or a market participant.

• Sharing material non-public information.

Creators must disclose, in any Content recommending action on a security or commodity interest, whether they hold or intend to hold a position in the asset.

2.6 Sports Touting Guarantees and Locks

On the sports side, the following are prohibited in addition to Section 2.2:

• Guaranteeing the outcome of a game, prop, or other event.

• Holding out as a “sports information service” licensed in any jurisdiction unless the creator is in fact licensed and provides documentation upon request.

• Targeting Content at users in jurisdictions where Platform sports Content is geofenced.

• Soliciting users to place bets through any specific sportsbook in exchange for compensation, unless the relationship is disclosed in accordance with Section 4.

2.7 Misrepresentation of Credentials

Creators must not represent, expressly or by implication, that they are any of the following unless they actually are and provide CopyWins with documentation upon request:

• A registered investment adviser under federal or state law.

• A registered broker, dealer, or registered representative.

• A registered Commodity Trading Advisor or Commodity Pool Operator.

• A member of FINRA, the NFA, or any similar self-regulatory organization.

• A licensed sports information service in any jurisdiction.

• A Certified Financial Planner, Chartered Financial Analyst, or other professional certification, unless held.

• Affiliated with, employed by, or endorsed by any registered, licensed, or regulated entity.

2.8 Fraud, Deception, and Identity Misuse

The following are prohibited:

• Impersonating any person or entity.

• Creating fake follower or subscriber accounts.

• Manipulating Platform metrics.

• Soliciting subscribers under false pretenses.

• Using stolen or unauthorized payment methods.

2.9 Illegal Content and Restricted Categories

Content that violates applicable law is prohibited. Without limitation:

• Content that targets users in restricted jurisdictions in violation of geofencing rules.

• Content directed at minors, or content suggesting a minor should engage in trading or wagering.

• Content involving or promoting illegal drugs, weapons, human trafficking, or other illegal activity.

• Content that infringes the intellectual property rights of any third party.

• Content that violates any sanctions program administered by the U.S. Department of the Treasury's Office of Foreign Assets Control or any similar program.

2.10 Harassment, Discrimination, and Threats

Creators and users must treat one another with respect. Harassment, threats, hate speech, doxxing, and discriminatory content based on race, ethnicity, religion, national origin, sex, gender identity, sexual orientation, age, disability, or other protected characteristic are prohibited.

2.11 Sexually Explicit Content

Sexually explicit content, content sexualizing minors, and content promoting violence or self-harm are prohibited.

2.12 Off-Platform Solicitation

Creators may not use the Platform to direct subscribers to off-Platform paid services that compete with the Platform's subscription model, including private signal groups, paid newsletters, or paid Discord channels offering the same content for a fee. Creators may reference their other public projects (such as a free podcast or YouTube channel) where reasonable and consistent with the Creator Agreement.

3. Required Disclosures

3.1 Material Connections

If you receive compensation, free product, discounts, or any other consideration from any third party in exchange for mentioning, promoting, or linking to that third party's product or service, you must disclose that relationship clearly and conspicuously in the relevant Content. This requirement reflects the FTC Endorsement Guides at 16 C.F.R. Part 255. Disclosures should:

• Appear in close proximity to the related content (not buried in a profile bio or footer).

• Use clear language identifying the material connection (e.g., “Sponsored by [name],” “I receive a commission when you sign up through this link,” or “I am paid to promote this product”).

• Be visible without requiring users to click through, hover, or scroll past additional content.

3.2 Position Disclosures

If you are recommending action on a security, commodity interest, or other asset in which you hold or intend to take a position, you must disclose that position in the Content. The disclosure should identify the position direction (long or short), the asset, and whether you intend to add to or reduce the position.

3.3 Affiliate and Sportsbook Disclosures

If you receive compensation for referring users to any sportsbook, brokerage, exchange, or other transactional platform, you must disclose that compensation arrangement. Affiliate links must be identified as affiliate links.

3.4 Performance Disclosures

Any performance figure published by you must be accompanied by:

• The measurement period.

• The universe of picks measured.

• The methodology for calculating wins and losses.

• A typicality disclaimer to the effect that past performance is not a guarantee of future results and that individual results vary.

The Platform may calculate and display these figures from your published Content, in which case the methodology will be disclosed in a Platform-level methodology statement. Where you also publish your own performance figures, they must be consistent with the Platform-calculated figures.

4. Geographic Restrictions

Certain Platform features and Content categories are restricted by geography. The current restrictions are published on the Platform and may be updated at any time. Without limitation, sports-related Content may be restricted in jurisdictions that license sports information services, including Nevada under NRS 463.0193. Creators must not direct Content at users in jurisdictions where their Content category is restricted.

5. Reporting and Enforcement

5.1 Reporting

To report content that may violate this Policy, contact moderation@copywins.com or use the in-Platform reporting tools.

5.2 Enforcement Actions

Depending on the nature and severity of a violation, CopyWins may take one or more of the following actions:

• Remove the content.

• Issue a warning.

• Restrict the creator's ability to publish certain content categories.

• Suspend the creator's account.

• Terminate the creator's account.

• Withhold or reverse payouts in accordance with the Creator Agreement.

• Refer the matter to law enforcement or regulators where appropriate.

Repeated or egregious violations will generally result in termination.

5.3 Appeals

Creators may appeal an enforcement action by contacting compliance@copywins.com within fourteen (14) days of the action. Appeals will be reviewed by a different reviewer than the one who made the initial decision. Decisions on appeal are final.

6. Updates to This Policy

CopyWins may update this Policy from time to time. Material updates will be communicated to creators by email or in-Platform notice. Continued use of the Platform after the effective date of an update constitutes acceptance.

7. Questions

Questions about this Policy may be directed to compliance@copywins.com.