Terms and privacy

WhoBought operates whobought.app, a website that helps people explore who bought, sold, and owns stocks using public filings from the United States Securities and Exchange Commission and related market data. The website, its pages, tools, and content are referred to here as the Services.

By accessing or using the Services, you agree to these Terms and Privacy Policy, referred to together as the Terms. If you do not agree, do not use the Services.

The Services are not directed to any particular jurisdiction. Availability in a location does not represent that the Services comply with every law of that location.

WhoBought is not a broker, dealer, investment adviser, fiduciary, or financial planner. The Services provide general information only and do not consider your investment objectives, financial situation, risk tolerance, or needs.

Nothing on the Services is an offer, solicitation, recommendation, endorsement, rating, or instruction to buy, sell, or hold a security or to follow any investment strategy. A display that a person or institution bought, sold, or held a security reports or estimates past activity; it does not mean that WhoBought or the filer recommends the security.

Past activity and past performance do not guarantee future results. Markets can move before, during, or after a filing period. You are solely responsible for verifying information and for every investment or trading decision you make.

WhoBought organizes public SEC filings, including Form 13F institutional holdings, Form 4 insider transactions, and Schedule 13D and 13G beneficial ownership filings. Filing data may be delayed, amended, incomplete, restated, coded inconsistently, or reported only as of a past date. Form 13F reports can arrive after the end of a calendar quarter and do not disclose every asset, short position, hedge, or transaction.

WhoBought also calculates derived values to make filings easier to understand. Examples include changes in reported shares, estimated dollar changes, portfolio weights, priced snapshots, performance estimates, and estimated average purchase prices based on covered quarterly market prices. These are computational estimates, not reported execution prices, audited cost basis, current positions, or complete investment returns.

Derived values depend on source coverage, security mapping, corporate actions, price availability, filing dates, and stated assumptions. They may be unavailable or change when filings are amended, mappings are corrected, prices are refreshed, or methods improve. Labels such as bought, sold, added, reduced, new, or exited describe changes detected between covered disclosures and may not capture activity between reporting dates.

Age and capacity. You must be at least 18 years old and able to form a binding contract to use the Services.

Account security. If you sign in, you are responsible for safeguarding access to your Google account and for activity associated with your WhoBought session. Notify us through the feedback form if you believe your access has been compromised.

Local law. You are responsible for determining whether your use of the Services is lawful where you live or operate. You must not use the Services if applicable law prohibits that use.

Restrictions. You must not use the Services if you are subject to applicable sanctions, located in an embargoed region, or otherwise prohibited from receiving the Services.

The Services are intended for individual, lawful research. You must not scrape, crawl, spider, bulk download, mirror, cache, or extract data or content through automated means without written permission.

You must not bypass access controls, authentication, rate limits, or technical restrictions; probe or disrupt the Services; introduce malicious code; impersonate another person; misuse account access; or attempt to gain unauthorized access to any system or data.

You must not republish, resell, sublicense, or redistribute the Services or a substantial part of their content; use the Services to build or train a competing product; infringe intellectual property or privacy rights; or use the Services in violation of law.

We may apply reasonable rate limits or restrict access to preserve availability, security, source-license compliance, and a fair experience for other users. We may suspend or terminate access for violations of this Section.

Our rights. WhoBought and its licensors retain all rights in the Services, including software, methods, design, organization, original text, graphics, and branding. Public SEC filings remain subject to the rights and rules that apply to those source materials.

Limited license. Subject to these Terms, you receive a personal, nonexclusive, nontransferable, revocable license to use the Services for your own lawful research. This license does not transfer ownership of any part of the Services or third-party data.

Your submissions. If you submit feedback or other content, you confirm that you have the right to provide it and grant us a nonexclusive, worldwide, royalty-free license to host, reproduce, process, and use it to operate, secure, and improve the Services. Suggestions and feedback may be used without restriction or compensation.

Marks. The WhoBought name, wordmark, and logos may not be used in a way that suggests sponsorship or endorsement without written permission.

The Services rely on public SEC sources and may use market, company, identity, authentication, hosting, and infrastructure services supplied by third parties. Those sources and services may be delayed, unavailable, corrected, or governed by their own terms.

We do not control and do not guarantee the availability, accuracy, completeness, or timeliness of third-party data or websites. Links to original filings or other websites are provided for convenience and do not imply endorsement. Third-party restrictions may limit display, retention, sharing, or continued availability of particular data or features.

We do not sell personal data. WhoBought does not currently use advertising cookies or cross-site advertising trackers.

Information you provide. When you sign in with Google, WhoBought receives and keeps the verified account identifier, name, and email address needed to identify your session. Google handles the sign-in flow under its own terms and privacy practices. If you use the feedback form, we receive the email address and message you submit.

Essential session cookie. WhoBought uses a signed, host-only session cookie for sign-in and security. It can hold the small Google identity record and temporary authorization state used during sign-in. The cookie is inaccessible to browser scripts, uses SameSite Lax, is sent only over secure connections in production, and normally expires after 12 hours. Signing out clears the session.

Last-visit cookie. The Latest moves page uses a SameSite Lax cookie named wb_last_visit to remember when that browser last visited the page and to identify newly added filings. It does not identify a named person and may remain for up to one year.

Session storage. WhoBought uses browser session storage to remember scroll coordinates and a timestamp briefly when you change filters on the same page. The entry is removed after restoration and ignored after 30 seconds. Browser session storage remains on your device and is not sent to WhoBought by that feature.

Operational data. Our hosting and security systems may process ordinary request and diagnostic information, such as time, requested page, network address, browser information, response status, and error details. The feedback service stores the submitted message and email address with a one-way network-address hash used for abuse controls.

How we use information. We use information to provide sign-in and requested features, display new-since-visit information, receive and respond to feedback, secure and maintain the Services, prevent abuse, diagnose failures, comply with legal obligations, and improve WhoBought.

Sharing. We may share information with service providers that process it for hosting, authentication, delivery, security, storage, and operations; when required by law; to protect rights and safety; or as part of a merger, financing, acquisition, reorganization, or sale of assets. We do not authorize service providers to use personal data for their own advertising.

Retention and choices. We retain personal data only as long as reasonably needed for the purposes described here and for legal, security, and operational requirements, then delete or anonymize it. You can sign out to clear your active WhoBought session, delete cookies or session storage through your browser, and use the feedback form to request access, correction, or deletion of personal data connected with the Services.

Security and children. We use reasonable technical and organizational safeguards, but no storage or transmission method is completely secure. The Services are not intended for anyone under 18, and we do not knowingly collect personal data from children.

To the fullest extent permitted by law, the Services and all content are provided as is and as available. We disclaim all express, implied, and statutory warranties, including warranties of merchantability, fitness for a particular purpose, title, noninfringement, accuracy, completeness, and quiet enjoyment.

We do not warrant that the Services, filings, estimates, links, or data will be uninterrupted, current, secure, complete, accurate, or error free, or that defects will be corrected. You assume the risk of using or relying on the Services.

To the fullest extent permitted by law, WhoBought and its affiliates, licensors, service providers, officers, and employees will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for lost profits, investment losses, lost opportunities, revenues, data, goodwill, or business interruption, arising from or related to the Services or these Terms, even if advised that such damages were possible.

To the fullest extent permitted by law, our aggregate liability for all claims arising from or related to the Services or these Terms will not exceed 100 United States dollars. Some jurisdictions do not allow particular exclusions or limits, so some of the limits above may not apply to you.

You agree to indemnify and hold harmless WhoBought and its affiliates, licensors, service providers, officers, and employees from claims, damages, losses, liabilities, costs, and expenses, including reasonable legal fees, arising from your use of the Services, content you submit, or violation of these Terms or applicable law.

Good-faith process. Before starting a formal proceeding, you will contact us through the feedback form, describe the specific issue, explain why you believe it is not resolved by these Terms, and provide supporting facts and documents. The parties will seek an amicable resolution for at least six months after receipt of that notice.

Mediation. If the dispute remains unresolved, it will first be submitted to mediation under the ICC Mediation Rules administered by the ICC International Centre for ADR. If the parties do not agree on a mediator, the ICC will appoint one. The place of mediation will be Paris, France, and the language will be English.

Arbitration. If mediation does not resolve the dispute, it will be finally resolved by arbitration administered by the International Chamber of Commerce under the ICC Rules of Arbitration. The seat will be Paris, France, the tribunal will consist of one arbitrator, and the language will be English.

Law and forum. These Terms and disputes connected with them are governed by French law. Interim or conservatory measures may be requested from the competent courts of Paris, France.

Individual proceedings. Disputes will proceed only on an individual basis. Class, collective, and representative actions are waived to the extent permitted by law.

We may suspend, restrict, or terminate access to protect the Services or other users, comply with law or third-party requirements, address security or operational risk, or respond to a violation of these Terms. You may stop using the Services and sign out at any time.

When access ends, your license to use the Services ends. Provisions that by their nature should survive will survive, including provisions about source data and estimates, acceptable use, intellectual property, privacy, disclaimers, liability, indemnity, disputes, and miscellaneous terms.

We may update these Terms to reflect changes in the Services, data sources, operations, law, security, or regulation. Material changes will take effect no earlier than 30 days after notice through the Services or another reasonable channel. Nonmaterial changes may take effect when posted.

The Last updated date identifies the current version. Continuing to use the Services after updated Terms take effect means that you accept them.

You represent that you are not located in a country or region subject to applicable embargoes, are not on an applicable restricted-party list, and will comply with export-control and sanctions laws that apply to your use of the Services.

You may share a small excerpt or screenshot for noncommercial commentary or research if you clearly attribute WhoBought, link to https://whobought.app, preserve notices, and comply with source-data restrictions. You may not share content in bulk, imply our endorsement, or redistribute third-party data where the provider prohibits it.

We respect intellectual property rights. We may remove or disable access to material in response to a bona fide infringement notice and may restrict repeat infringers. Use the feedback form to submit a notice with enough information for us to identify the work, the material, your authority, and the requested action.

We are not liable for delay, interruption, data unavailability, or failure caused by events beyond our reasonable control, including natural disasters, market or exchange disruptions, government actions, internet or power outages, cyberattacks, and failures of the SEC or other third-party providers.

You consent to receive notices electronically. We may provide notices through the Services, by posting at whobought.app, or by contacting an address you voluntarily provided. A notice is treated as received when sent or posted, subject to applicable law.

No waiver. Failure to enforce a provision is not a waiver of that provision or any other right.

Severability. If a provision is unenforceable, it will be limited to the minimum extent necessary and the remaining provisions will stay in effect.

Assignment. You may not assign these Terms without our prior written consent. We may assign these Terms in connection with our operations or a corporate transaction.

Entire agreement. These Terms are the entire agreement between you and us about the Services and supersede prior understandings about that subject.

Headings. Headings are for convenience and do not affect interpretation.

To contact us about these Terms, a privacy request, a copyright notice, or any other question, use the feedback form available on every page.

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