Terms of Use

Updated 14 May 2026

These Terms of Use govern your access to and use of Thesis Tracker, an information service about publicly available fund manager statements relating to ASX-listed entities. By creating an account or otherwise accessing the service, you agree to be bound by these Terms. If you do not agree, you must not use the service.

1. Definitions and interpretation

1.1 Definitions

In these Terms, unless the context requires otherwise:

"Account" means the user account created by you to access the Service.

"Action Statement" means the single sentence published with each Entry that factually describes the portfolio action the relevant Fund Manager has reported in connection with the source statement (such as initiating, increasing, reducing, exiting, or making no change to a position).

"Content" means all material made available through the Service, including Entries, Verbatim Extracts, Action Statements, Topical Sentences, factual metadata, descriptive classifications, source links, entity information drawn from public records, and methodology pages.

"Corporations Act" means the Corporations Act 2001 (Cth).

"Disclaimer" means the Disclaimer document published on the Service, as amended from time to time.

"Entry" means a single record on the Service comprising an Action Statement, one or more Verbatim Extracts, optionally a Topical Sentence, and associated metadata and tags.

"Fund Manager" means any third-party entity whose publicly available statements are recorded or referenced on the Service.

"Intellectual Property Rights" means all rights of any kind in or to copyright, trade marks, designs, patents, confidential information, know-how, and any other rights of a similar nature, whether registered or unregistered, anywhere in the world.

"Privacy Policy" means the Privacy Policy published on the Service, as amended from time to time.

"Service" means the Thesis Tracker website, accessible at [domain], including all associated pages, features, content, communications and any successor service.

"Source Material" means a published document or recording in which a Fund Manager has made a statement that is recorded on the Service, such as a monthly report, quarterly update, investor letter, annual review, interview transcript, or regulatory filing.

"Subscription" means a paid subscription to the Service of the type set out in clause 6.

"Topical Sentence" means an optional single sentence published with an Entry that, in neutral and non-evaluative language, identifies the subjects the underlying Source Material discusses (such as the industries, products, regulatory matters, or corporate events the Fund Manager addressed).

"Verbatim Extract" means a passage copied exactly from a Source Material, reproduced in quotation marks with attribution to the Fund Manager. An Entry may contain one or more Verbatim Extracts.

"You", "user" means the natural person or entity accessing the Service.

1.2 Interpretation

Headings are for convenience only and do not affect interpretation. References to legislation include amendments and re-enactments. Words in the singular include the plural and vice versa. A reference to a person includes a body corporate. Where the word "including" is used, it means "including without limitation".

2. Access

2.1 Eligibility

You may use the Service only if you are at least 18 years old, are legally capable of entering into binding contracts, and are not prohibited from using the Service under applicable law.

2.2 Open access

Access to the Service is open to any eligible user. The Operator does not assess whether the Service is suitable for any particular user. The Service is the same factual record regardless of who accesses it.

2.3 Geographic scope

The Service is operated from Australia and is principally intended for Australian users. It may not be appropriate for users in other jurisdictions, and the Operator does not represent that the Service complies with the laws of any jurisdiction outside Australia. If you access the Service from outside Australia, you do so on your own initiative and at your own risk.

3. Account creation and security

3.1 Account information

To access the Service, you must create an Account by providing accurate, current and complete information. You must keep your Account information up to date.

3.2 Account security

You are responsible for maintaining the confidentiality of your Account credentials and for all activities that occur under your Account. You must notify the Operator immediately of any unauthorised use of your Account or any other breach of security. The Operator is not liable for any loss arising from your failure to comply with this clause.

3.3 One Account per person

Accounts are personal to you and may not be shared, transferred, or assigned. You may not create more than one Account for yourself.

4. Nature of the Service

4.1 The Service is a factual information service

Thesis Tracker is an information service. Its purpose is to make publicly available statements by Australian Fund Managers easier to find, easier to attribute, and easier to read in context. It does this by recording, classifying, and indexing such statements. The Service is the kind of service that catalogues primary-source material — like a public records database, a regulatory filing index, or a news archive — rather than the kind of service that analyses, interprets, or recommends.

4.2 What each Entry contains

For each statement recorded on the Service, the Operator publishes an Entry consisting of:

Identifying metadata — the identity of the Fund Manager who made the statement, the Source Material in which the statement appeared, a direct link to the Source Material where it is publicly available, the date on which the statement was published, and the entity to which the statement relates;
An Action Statement — a single factual sentence describing the portfolio action the Fund Manager has reported (such as "initiated a position", "increased their holding", "reduced their holding", "exited their position", "made no change to their position", or "commented on" — where the Fund Manager mentions an entity without reporting a portfolio action);
One or more Verbatim Extracts — passages copied exactly from the Source Material, reproduced in quotation marks with attribution. The total length of Verbatim Extracts in an Entry is typically between 40 and 250 words. Where the Source Material contains multiple material considerations (for example, both reasons for the position and counterbalancing concerns), multiple Verbatim Extracts are included so that the Entry reflects the substance of what the Fund Manager said;
An optional Topical Sentence — a single sentence in neutral, non-evaluative language identifying the subjects the Source Material discusses (such as "The manager's comments addressed above-rail volume performance, the proposed regulatory extension, and grain volume trends"). The Topical Sentence describes subjects, not the Fund Manager's view of those subjects, and is omitted where it cannot be written without evaluative drift;
Descriptive tags — factual topic tags identifying subjects discussed in the Source Material, drawn from categories such as industry, products, geographic operations, corporate events that have occurred, and regulatory matters. Tags are descriptive, not evaluative.

4.3 What the Service does not do

The Service does not:

author its own investment commentary, opinions, recommendations, or analysis of any security;
paraphrase, condense, summarise, or synthesise a Fund Manager's investment thesis in the Operator's own words;
characterise, rate, rank, score, or otherwise evaluate any Fund Manager, fund, security, or statement;
publish sentiment scores, "bullish" or "bearish" indicators, or aggregate signals derived from Fund Manager statements;
publish price targets, forecasts, or forward-looking statements about specific securities authored by the Operator (forward-looking statements within a Verbatim Extract remain the Fund Manager's own words, not the Operator's);
generate or curate "investment ideas", "tips", "picks", "theses", or "recommendations";
compare or contrast Fund Managers in a way that suggests one is better than another;
provide model portfolios, suggested allocations, or any other portfolio-construction outputs;
provide personalised content of any kind tailored to a user's situation; or
add causal language ("driven by", "supported by", "as a result of") in operator-authored portions of an Entry, except where those exact words appear in a Verbatim Extract.

4.4 Faithfulness commitment

The Operator commits to representing Source Material faithfully. In particular:

Verbatim Extracts must be copied exactly from the Source Material, preserving the Fund Manager's wording, and may not be paraphrased, smoothed, or stitched together from non-adjacent passages within a single Extract;
Where a Source Material raises a material counterbalancing consideration (a concern, a risk, a hedging factor, or any other point that would materially qualify the impression conveyed by other Verbatim Extracts in the Entry), the Operator either includes additional Verbatim Extracts that capture that consideration, or applies NEEDS_REVIEW status to the candidate Entry;
Entries flagged NEEDS_REVIEW are not published until they have been reviewed by a person. Following review, either a faithful Entry is composed (typically by including additional or replacement Verbatim Extracts) or the candidate Entry is declined for publication;
The Topical Sentence (where included) must accurately reflect the range of subjects the Source Material discusses, and must not selectively name only subjects that support a particular impression of the Fund Manager's view.

4.5 The Service is not financial advice

Nothing published on the Service constitutes financial product advice — personal or general — within the meaning of s766B of the Corporations Act. The Operator does not provide recommendations, opinions, ratings, or endorsements in relation to any financial product, security, fund, or service. The Operator does not hold an Australian Financial Services Licence and is not an authorised representative of an AFSL holder.

4.6 The Service is not research

The Service is not a financial research service, an investment newsletter, a tipsheet, or a substitute for licensed investment research. The Operator does not produce investment ideas, model portfolios, or buy/sell recommendations.

4.7 Independent decisions

If you are considering any investment decision, you must make that decision independently — on the basis of the Source Materials linked from the Service, the relevant Product Disclosure Statement and Target Market Determination, your own assessment of those documents against your own circumstances, and (where appropriate) advice from an appropriately licensed financial adviser. Content on the Service is not, and must not be treated as, a basis for any investment decision.

4.8 Disclaimer incorporated

The Disclaimer published on the Service forms part of these Terms by incorporation. In the event of any inconsistency, the Disclaimer prevails to the extent of the inconsistency.

5. Permitted and prohibited use

5.1 Permitted use

You may access and use the Service only for your own internal, personal, non-commercial purposes — including using the Service as a starting point to identify and read original Source Materials. You may not use the Service for any other purpose without the Operator's prior written consent.

5.2 Prohibited use

You must not, and must not permit any other person to:

scrape, harvest, extract, index, mirror, or systematically download Content, whether manually or by automated means;
access the Service by means of any robot, spider, crawler, scraper, or other automated tool or process;
circumvent, disable, or otherwise interfere with any access controls, rate limits, or security features of the Service;
redistribute, republish, broadcast, transmit, sell, sublicense, or otherwise make available any Content to any third party, in any form, by any means;
use the Service, or any Content, to provide financial product advice, recommendations, or investment guidance to any other person;
treat any Content as financial product advice or as a basis for any investment decision;
use the Service to develop, train, or evaluate any artificial intelligence, machine learning model, or similar system;
use the Service to identify, target, contact, or otherwise approach any listed entity, its directors, officers, or employees, in connection with any actual or proposed trading, takeover, activist campaign, short-selling activity, or other corporate action;
use the Service in any way that could constitute, facilitate, or contribute to market manipulation (within the meaning of Part 7.10 Division 2 of the Corporations Act), insider trading (within the meaning of Part 7.10 Division 3 of the Corporations Act), or any other contravention of Australian financial services or markets law;
misrepresent your identity or affiliation;
use the Service in any manner that is unlawful, fraudulent, defamatory, harassing, or otherwise harmful;
introduce any virus, malware, or other harmful code to the Service;
reverse engineer, decompile, or disassemble any part of the Service; or
remove, alter, or obscure any attribution, copyright notice, trade mark, or other proprietary marking on any Content.

5.3 Consequences of breach

The Operator may, at its discretion and without notice, suspend or terminate access to the Service in the event of any breach or suspected breach of clause 5.2. The Operator reserves all rights to recover damages, seek injunctive relief, and report unlawful conduct to relevant authorities.

6. Subscription, fees and billing

6.1 Subscription plans

The Service is offered on the following Subscription plans:

Monthly Subscription — billed monthly in advance at the price advertised on the Service at the time of subscription;
Annual Subscription — billed annually in advance at the price advertised on the Service at the time of subscription.

The current price for each plan is set out on the Service's pricing page and is incorporated into these Terms.

6.2 Payment

All Subscriptions are paid in advance. Payment is processed by [Stripe Payments Australia Pty Ltd] as the Operator's payment processor. By providing payment information, you authorise the Operator (through its payment processor) to charge the applicable Subscription fees to your payment method.

6.3 Automatic renewal

Subscriptions automatically renew at the end of each billing period at the then-current Subscription rate, unless you cancel renewal in accordance with clause 6.4.

6.4 Cancellation of renewal

You may cancel renewal of your Subscription at any time by emailing team+cancel@thesis-tracker.com. If you cancel renewal before the end of your current billing period, your Subscription will continue until the end of that period, after which no further charges will be made. Cancelling renewal does not entitle you to a refund of fees already paid, except as set out in clause 6.5.

6.5 Money-back guarantee

The Operator offers a money-back guarantee on Subscription fees. You may request a refund of fees paid by contacting team+cancel@thesis-tracker.com. Refund requests will be considered on a case-by-case basis. The Operator reserves the right to refuse refunds where, in its reasonable opinion, the refund request is being made in bad faith or in circumstances suggesting an attempt to exploit the guarantee.

6.6 Price changes

The Operator may change Subscription prices at any time. Price changes will not affect the current paid-up Subscription period but will apply on renewal. The Operator will provide at least 30 days' notice of any price increase that will apply on renewal.

6.7 Taxes

All prices are stated in Australian dollars and are inclusive of GST unless otherwise stated.

6.8 Failed payment

If a Subscription payment fails, the Operator may suspend access to the Service until payment is received. After 14 days of non-payment, the Operator may terminate the Account.

7. Intellectual property

7.1 Operator IP

All Intellectual Property Rights in the Service (including the platform, the user interface, the indexing system, the classification schema, and the compilation of Content) are owned by or licensed to the Operator. Nothing in these Terms transfers any Intellectual Property Rights to you.

7.2 Third-party content

Verbatim Extracts and other quotations from Source Materials reproduced on the Service remain the Intellectual Property of the relevant Fund Manager. Such material is reproduced in reliance on the fair dealing provisions of the Copyright Act 1968 (Cth) for the purpose of reporting news, with attribution and a direct link to the original Source Material.

7.3 Limited licence to you

Subject to your compliance with these Terms, the Operator grants you a non-exclusive, non-transferable, revocable licence to access and view Content through the Service for your own internal, personal, non-commercial use during the period of your active Subscription. This licence does not include any right to redistribute, republish, or otherwise exploit Content.

7.4 Feedback

If you provide the Operator with any feedback, suggestions, or ideas regarding the Service, you grant the Operator a perpetual, worldwide, royalty-free, irrevocable licence to use such feedback for any purpose without obligation to you.

8. Third-party content and links

8.1 Third-party materials

The Service contains links to, and extracts from, third-party materials including Fund Manager reports, regulatory filings, and other publications. The Operator does not control, endorse, or take responsibility for any third-party material.

8.2 Fund Manager disclaimers prevail

Each Fund Manager's own disclaimers, terms, and risk warnings apply to their published materials. In the event of any inconsistency between a Fund Manager's disclaimer and any Content on the Service derived from that Fund Manager's materials, the Fund Manager's own disclaimer prevails in respect of the underlying statement. Where a Verbatim Extract contains a forward-looking statement, projection, target, or opinion, that material reflects the Fund Manager's view at the time the Source Material was published and is subject to the Fund Manager's own qualifications and risk warnings.

9. Privacy and data

The Operator's collection, use, and disclosure of your personal information is governed by the Privacy Policy, which forms part of these Terms by incorporation. By using the Service, you consent to the handling of your personal information in accordance with the Privacy Policy.

10. Warranties and disclaimers

10.1 As-is service

To the maximum extent permitted by law, the Service and all Content are provided "as is" and "as available", without warranty of any kind, express or implied.

10.2 No warranty of accuracy

The Operator does not warrant that Content is accurate, complete, current, or reliable. Content is compiled from third-party Source Materials and may contain errors, omissions, or out-of-date information. While the Operator commits to faithfulness in representing Source Materials (see clause 4.4), no representation system is perfect, and you remain responsible for verifying any Content you wish to rely on by reference to the original Source Material.

10.3 No warranty of availability

The Operator does not warrant that the Service will be uninterrupted, error-free, or secure. The Operator may suspend the Service for maintenance, upgrades, or other operational reasons.

10.4 Consumer guarantees

Nothing in these Terms excludes, restricts, or modifies any consumer guarantee, right, or remedy conferred by the Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010 (Cth)) or any other law that cannot lawfully be excluded, restricted, or modified. Where a consumer guarantee applies and the Operator is entitled by law to limit its liability for breach of that guarantee, its liability is limited (at the Operator's election) to: (a) supplying the services again; or (b) the payment of the cost of having the services supplied again.

11. Limitation of liability

11.1 Exclusion of liability

Subject to clause 10.4, and to the maximum extent permitted by law, the Operator excludes all liability (whether in contract, tort, statute, or otherwise) for any loss or damage arising out of or in connection with your access to or use of the Service or any Content, including:

any investment loss, opportunity cost, or trading loss;
any loss arising from reliance on Content or from inability to access the Service;
any indirect, consequential, special, or punitive loss;
any loss of profit, revenue, goodwill, data, or business opportunity; and
any loss caused by the act or omission of any third party, including any Fund Manager or payment processor.

11.2 Cap on liability

Where liability cannot be excluded by law, the Operator's total aggregate liability to you for all claims arising in connection with these Terms or the Service is limited to the greater of (a) the total Subscription fees paid by you to the Operator in the 12 months immediately preceding the event giving rise to the claim.

11.3 Your indemnity

You indemnify the Operator against all loss, damage, cost, expense, and liability (including legal costs on a full indemnity basis) suffered or incurred by the Operator arising out of or in connection with:

any breach by you of these Terms;
any use by you of Content in breach of these Terms; and
any third-party claim arising from your conduct in connection with the Service.

12. Suspension and termination

12.1 Termination by you

You may terminate your Account at any time by cancelling renewal under clause 6.4 and ceasing to use the Service.

12.2 Termination by the Operator

The Operator may suspend or terminate your Account, with or without notice, if:

you breach these Terms;
the Operator is required to do so by law or by a regulator;
your Subscription payment fails and is not remedied;
your conduct poses a risk to the Service, other users, or any third party; or
the Operator decides, in its reasonable discretion, to discontinue the Service or any part of it.

12.3 Effect of termination

On termination, your right to access the Service ends immediately. Clauses 5.2, 7, 10, 11, 13, and 14 survive termination.

13. Changes to these Terms

The Operator may amend these Terms from time to time. The Operator will give you reasonable notice of material changes by email and through the Service. Continued use of the Service after the effective date of any amendment constitutes acceptance of the amended Terms. If you do not accept the amended Terms, you must cease using the Service and may cancel your Subscription under clause 6.4.