Compliance

Updated 10/06/26, 16:26

1. Legal Identity and Accountability

Heatmup Oy is a Finnish limited liability company registered in Helsinki under business identity code (Y-tunnus) 3620396-9. The company operates heatmup.com and is responsible for every forecast, page, and disclosure published on the Service. The person legally accountable for the company is the Chief Executive Officer, Veikko Ahonen. Questions, regulatory inquiries, complaints about content accuracy, and requests to access, correct, or delete personal data go to [email protected]. Heatmup responds in writing and keeps a record of every exchange.

2. System Transparency: Three Types of Content

The Service publishes three distinct types of content, each generated by a different mechanism. Understanding the distinction between them is material to interpreting what appears on heatmup.com. (a) Forecast heatmaps and probability distributions: generated entirely by the HMX quantitative aggregation engine, a proprietary system that aggregates independent quantitative predictions from a heterogeneous pool of models into a probability distribution, described in section 3. This content is not AI-generated. It is the output of a deterministic aggregation of quantitative model predictions, produced automatically and published without human review of any individual output. (b) Forecast description text: a statistical summary of the heatmap, for example describing the historical window, the projected median, and the percentile range. This is generated automatically from the structured numerical output of HMX and is not produced by a large language model or any generative AI system. It is not reviewed by a human analyst before publication. (c) Narrative market analysis text: a contextual commentary accompanying each forecast, for example describing current macroeconomic conditions, recent flows, or catalysts relevant to the asset. This component is generated by a large language model ("LLM") operating on current market information. It is not a forecast. It does not form part of the quantitative probability distribution. It is not reviewed or approved by a human analyst before publication, given the speed at which market conditions develop.

Sections 2 and 3 of this page, together with the Cookie Policy at heatmup.com/legal/cookies and the Privacy Policy at heatmup.com/legal/privacy, constitute the formal transparency disclosure Heatmup provides under Regulation (EU) 2024/1689 (the EU AI Act) in respect of the LLM-generated narrative text described in category (c) above. The forecast heatmaps described in category (a) and the automated descriptions described in category (b) are not outputs of an AI system within the meaning of that regulation; they are the outputs of a deterministic quantitative aggregation engine.

3. System Transparency: How the Forecasting Pipeline Works

The forecasting pipeline produces the probability distributions and heatmaps described in section 2(a). It operates as follows. Data Ingestion: scrapers and ingestion processes collect financial articles, regulatory filings, options flow data, prediction-market pricing, and market data from multiple sources. Each source is summarised and scored for significance and reliability before being made available to the predictor pool. Quantitative Prediction Pool: the engine runs a diverse suite of proprietary quantitative models. Each model independently processes the ingested data and outputs a strict prediction: a date, a target price, and a probability. To prevent groupthink or consensus bias, these models are completely walled off from one another—no model can see what another is predicting prior to submission.

Aggregation Engine: the independent predictions are combined into a single probability distribution using time-decay weighting, so that more recent predictions carry greater influence than older ones. A light Gaussian smoothing is applied to the visual rendering of the distribution so that the chart is readable. Every published chart is archived with an immutable identifier and a timestamp. The current release publishes equally weighted aggregated output: every model in the pool contributes the same weight regardless of its historical accuracy. Accuracy-weighting, under which models with stronger historical track records carry proportionally greater influence, is on the roadmap for September 2026. Until that milestone ships, the output is descriptive in character: it represents what the equally weighted pool of models produces, not what a calibrated accuracy-weighted system would produce. The distinction is material and is stated here openly.

4. How to Read a Heatmap

Heatmaps are percentile bands computed from the aggregated distribution described in section 3. The 50th percentile is the median path: half of the aggregated model predictions sit above it and half below. The 25th and 75th percentile bands cover the middle half of the distribution. The 5th and 95th percentile bands cover ninety percent of the distribution. Wider bands indicate that the models in the pool disagree. Narrower bands indicate that they cluster. A percentile is a probability statement about the distribution of model output. It is not a guarantee about price, and it is not a prediction of what will happen. The 5th and 95th bands compress more than the true distributional tails of financial markets, which are wider and fatter than any model pool captures cleanly, and must not be read as worst-case or best-case scenarios for any asset.

5. Regulatory Status: MiFID II and Investment Services

Nothing on heatmup.com is investment advice, investment research, or a personal recommendation within the meaning of Directive 2014/65/EU on markets in financial instruments ("MiFID II") or the Finnish Act on Investment Services (Sijoituspalvelulaki 747/2012). Heatmup is not authorised, registered, or regulated as an investment firm, investment adviser, portfolio manager, broker, dealer, or provider of any investment service in Finland, the European Union, the United States, or any other jurisdiction. Heatmup is not supervised by the Finnish Financial Supervisory Authority (Finanssivalvonta) in respect of the Service.

The Output does not constitute investment research or a marketing communication within the meaning of MiFID II or Commission Delegated Regulation (EU) 2016/958, nor a personal recommendation as defined in those instruments. Output is generic, automated information disseminated to the public at large. It is not directed at, or tailored to, the circumstances of any particular recipient. Heatmup does not provide portfolio management, order execution, reception and transmission of orders, or any other regulated investment service. Heatmup does not hold client funds and does not execute transactions on behalf of any person. Readers in jurisdictions where this content is restricted should not rely on it. Separately, and under the distinct regime of the Market Abuse Regulation, the broad statutory definition of "investment recommendation" in Article 3(1)(35) MAR may capture the Output; Heatmup addresses that status and the disclosure obligations it carries in section 7. Falling within the MAR definition does not make the Output investment advice or investment research under MiFID II, which it is not.

6. Regulatory Status: MiCA and Cryptoassets

Heatmup does not provide any cryptoasset service within the meaning of Regulation (EU) 2023/1114 on markets in cryptoassets ("MiCA"). Output relating to cryptoassets is generic statistical information only. It does not constitute advice on cryptoassets, reception or transmission of orders, operation of a trading platform for cryptoassets, exchange of cryptoassets, custody or administration of cryptoassets, or any other service requiring authorisation under MiCA. Heatmup is not authorised as a cryptoasset service provider and is not supervised under MiCA. Cryptoassets are high-risk instruments that can lose all of their value. Readers bear full responsibility for any dealing in them.

7. Market Abuse Regulation

Heatmup operates under Regulation (EU) No 596/2014 on market abuse ("MAR") and Commission Delegated Regulation (EU) 2016/958. "Investment recommendation" is defined in Article 3(1)(35) MAR more broadly than its ordinary meaning, extending to information that suggests an investment strategy concerning financial instruments and is intended for distribution channels or the public. To the extent the Output falls within that statutory definition, Heatmup treats itself as a producer and disseminator of non-personalised investment recommendations for the purposes of MAR and 2016/958 and complies with the obligations that apply to such persons. This MAR characterisation is distinct from, and does not contradict, the position in section 5 that the Output is not investment advice or investment research under MiFID II: MAR and MiFID II are separate regimes with separate definitions, and content can fall within the broad MAR recommendation definition while remaining outside the narrower MiFID II categories. Forecasts are automated outputs of the quantitative aggregation engine described in section 3. They are not insider information as defined in Article 7 MAR and are not intended to influence any market, any price, or any financial instrument. Heatmup does not hold inside information, does not take positions in covered assets, and publishes its output to the public at large without selective disclosure.

Every published forecast is archived with an immutable identifier and a public timestamp, consistent with the record-keeping obligations applicable to disseminators under Article 20 MAR and Article 3 of Commission Delegated Regulation 2016/958. Conflicts-of-interest disclosures required under those instruments are set out in section 9 of this page. The standing disclaimer printed at the foot of every page, stating that content is for informational purposes only and does not constitute investment advice, is the summary-form disclosure required under Article 20(1) MAR.

8. US Regulatory Status

This section applies to access from within the United States. Heatmup is not registered with the US Securities and Exchange Commission ("SEC"), the Commodity Futures Trading Commission ("CFTC"), the Financial Industry Regulatory Authority ("FINRA"), or any state securities regulator. Heatmup is not a registered investment adviser, broker-dealer, commodity trading advisor, commodity pool operator, or futures commission merchant. The Output is not investment advice within the meaning of the Investment Advisers Act of 1940 and is not a research report within the meaning of Regulation AC or FINRA rules. No fiduciary duty under the Advisers Act, ERISA, or any other US law arises from use of the Service. US residents should consult a registered investment professional before acting on any market information.

9. Conflicts of Interest

Heatmup Oy's CEO, directors, and staff hold no personal positions in the financial instruments, securities, cryptoassets, or commodities covered on this site and do not trade in covered instruments. A written personal-trading policy applies to every person with influence over the model, the pipeline, or the published commentary. A full positions ledger is available on request at [email protected].

If any person covered by the personal-trading policy acquires a position in a covered asset, this page is updated before the change takes effect and the affected assets carry a visible disclosure label on every forecast in which they appear. Heatmup currently has no affiliate relationships and no sponsorships. No third party pays for placement, ranking, or favourable treatment of any asset on the site. If either of those things changes, this page is updated before the relationship becomes active.

10. Limits of Forecasts

Forecasts have real limits. They can be inaccurate. They change daily, sometimes sharply, as new data arrives and older predictions age out of the aggregation window under time-decay weighting. They are probability surfaces over quantitative model output, not statements of what will happen. The 5th and 95th percentile bands do not represent worst-case or best-case scenarios for price; the true distributional tails of financial markets are wider and fatter than any model pool captures cleanly. No forecast on heatmup.com should be read as a recommendation to buy, sell, hold, or otherwise transact in any financial instrument, security, cryptoasset, commodity, index, or derivative.

Until the accuracy-weighting milestone described in section 3 ships, the aggregation is equally weighted. A model with a poor historical track record contributes as much to the output as one with a strong one. Users who treat the current output as calibrated probability are reading more into it than the architecture currently supports. That is stated plainly here and is the basis on which every heatmap is published. The LLM-generated narrative text described in section 2(c) reflects the information available to the language model at the time of generation and may be incomplete, incorrect, or outdated. It is contextual commentary, not a forecast, and must not be treated as one.

11. Personal Data and Privacy

Personal data is processed under Regulation (EU) 2016/679 (GDPR) and the Finnish Data Protection Act (Tietosuojalaki 1050/2018). Heatmup Oy is the data controller within the meaning of Article 4(7) GDPR. The Privacy Policy at heatmup.com/legal/privacy describes what data is collected, on what legal basis, for how long it is retained, who receives it, and how to exercise rights of access, rectification, erasure, restriction, portability, and objection. Cookies and similar technologies are described in the Cookie Policy at heatmup.com/legal/cookies. All privacy and data requests go to [email protected].

12. Updates to This Page

This page is updated whenever a material fact it records changes: a new conflict of interest arises, a regulatory status changes, the pipeline architecture changes in a way that affects the transparency disclosure in section 2 or 3, or a new affiliate or sponsorship relationship is entered into. The date shown at the top of the page is the date of the most recent revision. For everything on this site, the standing rule is the one printed at the bottom of every page: for informational purposes only, not investment advice.