Terms of Use

The rules of the road.

Effective 27 April 2026 · Last updated 27 April 2026

These Terms of Use ("Terms") govern your access to and use of the SWARM Trading app, website, and associated services (collectively, the "Service"), operated by Tommy Hayes ("we", "us", "our"), an individual based in Ireland. By accessing or using the Service, you agree to be bound by these Terms. If you do not agree, do not use the Service.

Important — read this first. SWARM is an information and market-data service. It is not investment advice, a recommendation to buy or sell any security, or a solicitation of any kind. We are not licensed financial advisors, brokers, or fund managers. Trading carries substantial risk of financial loss. You are solely responsible for your trading decisions and outcomes. Past performance does not guarantee future results.

1. The Service — what SWARM is and is not

1.1 What SWARM is

SWARM is a real-time market-information aggregation tool. It collects publicly available data — including market scanner feeds, news headlines, SEC filings, social-sentiment signals, gappers, top movers, and economic events — and presents that data through a multi-channel app interface for iOS and macOS. When configured patterns appear across multiple data sources simultaneously (a "confluence"), the app surfaces an alert.

1.2 What SWARM is not

2. Eligibility

To use the Service, you must:

3. Subscriptions, billing, and refunds

3.1 Subscription terms

The Service is offered on a recurring subscription basis. Pricing is displayed on Whop (whop.com/swarm-eacd) and, when available, the Apple App Store. Subscriptions auto-renew at the end of each billing period unless cancelled at least 24 hours before renewal.

3.2 Payments

Payments are processed by Whop or by Apple, depending on the path you choose. We do not store, see, or process your payment card details. Refer to your chosen payment provider's terms for refund eligibility.

3.3 Cancellation

You may cancel your subscription at any time:

Cancellation takes effect at the end of your current billing period. You retain access to the Service until that period ends. We do not provide pro-rata refunds for unused portions of a billing period unless required by applicable consumer-protection law.

3.4 EU consumer right of withdrawal

If you are a consumer in the European Union, you have a 14-day right of withdrawal under EU Directive 2011/83/EU. By beginning to use the Service immediately upon subscription, you expressly request immediate performance and acknowledge that you lose the right of withdrawal once the Service has been fully provided within that 14-day period.

3.5 Price changes

We may change subscription prices for new billing periods. Existing subscribers will receive at least 30 days' written notice (by email or in-app) before any price change affects their renewal. You may cancel before the new price takes effect.

4. Your account

5. Acceptable use

You agree NOT to:

We reserve the right to suspend or terminate your account, without refund, for any violation of this Section 5 or these Terms generally.

6. Intellectual property

All content, software, design, branding, trademarks, and proprietary methodology associated with SWARM — including but not limited to the confluence engine logic, the multi-layer scoring model, the visual interface, the SWARM name and logo, and all written documentation — is the exclusive property of Tommy Hayes or his licensors. You receive a limited, non-exclusive, non-transferable, revocable licence to use the Service for personal, non-commercial use only, for the duration of your active subscription.

You retain ownership of any content you post to the chatroom. By posting, you grant us a worldwide, royalty-free licence to display that content within the Service for the purpose of operating the chatroom and for the duration permitted by our retention policy.

7. Third-party data and links

Market data, news headlines, SEC filings, and social-sentiment signals displayed in the Service are provided by third-party data providers (including but not limited to Financial Modeling Prep, the U.S. Securities and Exchange Commission's EDGAR system, Finnhub, and various news publishers). We do not control, endorse, or verify the accuracy of third-party data, and we are not responsible for any errors, omissions, or delays in such data. Links to external websites are provided for convenience only.

8. Disclaimer of warranties

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE", WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, NON-INFRINGEMENT, OR UNINTERRUPTED OPERATION. WE DO NOT WARRANT THAT THE SERVICE WILL BE ERROR-FREE, FREE OF VIRUSES OR HARMFUL COMPONENTS, OR THAT DEFECTS WILL BE CORRECTED. ANY DATA, ALERT, OR SIGNAL DISPLAYED IN THE SERVICE IS INFORMATIONAL ONLY AND MAY BE INACCURATE, INCOMPLETE, OR DELAYED.

9. Limitation of liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

Nothing in these Terms excludes or limits any liability that cannot lawfully be excluded under applicable law, including liability for death, personal injury caused by negligence, or fraud.

10. Indemnification

You agree to indemnify, defend, and hold harmless Tommy Hayes and his agents and contractors from and against any and all claims, liabilities, damages, losses, costs, expenses, and reasonable legal fees arising out of or related to: (a) your use of or misuse of the Service; (b) your violation of these Terms; (c) your violation of any law or regulation; (d) your violation of any third-party right; or (e) any trading decision you make based on information obtained from the Service.

11. Termination

You may terminate your relationship with us at any time by cancelling your subscription. We may suspend or terminate your access immediately, without notice or refund, if (a) you breach these Terms; (b) we are required to do so by law; (c) the Service is discontinued; or (d) we determine in our reasonable judgement that your use of the Service poses a risk to other users or to the operation of the Service.

Sections that by their nature should survive termination — including Sections 6 (IP), 8 (Warranties), 9 (Liability), 10 (Indemnification), 12 (Governing Law), and 13 (Disputes) — shall survive.

12. Governing law

These Terms and any dispute or claim arising out of or in connection with them are governed by the laws of Ireland, without regard to conflict-of-law principles. Where you are a consumer resident in the European Union, you retain the protection of any mandatory consumer-protection laws of your country of residence.

13. Disputes

Before filing any formal claim, you agree to first contact us at contact@hayesholdings.ie with a detailed description of the dispute and to negotiate in good faith for at least 30 days. If unresolved, disputes shall be subject to the exclusive jurisdiction of the courts of Ireland, except where overridden by mandatory consumer-protection law.

EU consumers may also access the European Commission's Online Dispute Resolution platform at ec.europa.eu/consumers/odr.

14. Apple App Store additional terms

If you obtain the Service through the Apple App Store, the following additional terms apply:

15. Changes to these Terms

We may update these Terms from time to time. The "Last updated" date at the top reflects the most recent revision. Material changes affecting your rights will be communicated by email or in-app notice at least 14 days before they take effect. Your continued use of the Service after the effective date constitutes acceptance of the revised Terms.

16. Severability and entire agreement

If any provision of these Terms is held to be unlawful, void, or unenforceable, that provision shall be severed and the remaining provisions shall remain in full force. These Terms, together with our Privacy Policy, constitute the entire agreement between you and Tommy Hayes regarding the Service and supersede all prior agreements.

17. Contact

Questions about these Terms:
Tommy Hayes Hayes Holdings · contact@hayesholdings.iemiddot; contact@hayesholdings.ie

Risk reminder. Trading equities, options, and other financial instruments involves substantial risk of loss and is not suitable for every investor. The valuation of securities may fluctuate, and you may lose more than you originally invested. You should carefully consider your investment objectives, level of experience, and risk appetite, and seek advice from an independent financial advisor licensed in your jurisdiction if any doubt exists. Past performance is not a reliable indicator of future results.