legal · terms

Terms and Conditions

Draft last updated 2026-09-11 · Milo Labs, Inc.

These terms govern your use of the milo website, the milo application, and the milo Partner API and MCP server. milo is software. It is not a broker, an exchange, a custodian, or a registered investment adviser, and it does not give investment advice.

Draft — pending legal review

This document is a working draft and is not yet in force. It was prepared internally as a starting point for review by qualified counsel. It is not legal advice, it has not been reviewed by a lawyer, and it should not be relied on as a statement of our legal obligations or of your legal rights.

Passages marked [COUNSEL: …] are open questions we have deliberately left unanswered rather than guess at. Factual descriptions of what the product and the website actually do are drawn from milo’s own published documentation and from the site’s source code; legal characterisations, jurisdiction, retention periods and regulatory status are not yet settled.

1. What milo is

milo is an AI investing platform operated by Milo Labs, Inc. It does two things: it runs autonomous AI trading agents that act on instructions you choose, and it answers stock and crypto research questions with live market data.

milo is software that runs on top of your own accounts. It is not a broker, a dealer, an exchange, a money transmitter, a custodian, or a registered investment adviser. Crypto trades are signed from a Solana wallet only you control. Stock trades go through a brokerage account you open and link yourself, and your brokerage — not milo — is the party that executes and clears them. milo never holds, moves or custodies your funds.

Regulatory status and licensing: [COUNSEL: confirm the regulatory analysis in every jurisdiction milo is offered in, including whether the agent execution path implicates broker-dealer, investment-adviser, money transmission, MiCA/CASP or commodity rules; confirm whether any registration, exemption or geographic restriction applies and add a restricted-jurisdictions clause if so. This draft asserts only the negative framing milo already publishes about itself and makes no claim of licensed status anywhere.]

2. Eligibility and your account

You may use milo only if you can form a binding contract with us and only where doing so is lawful for you. You are responsible for everything done through your account, including by agents you deploy and by anyone or anything you give access to.

You must keep your credentials, recovery factors and API keys secure, and tell us promptly if you believe they have been compromised. We recommend enabling multi-factor authentication.

Minimum age, prohibited jurisdictions, sanctions screening and any accredited/professional investor gating: [COUNSEL: set the minimum age and the eligibility, sanctions and jurisdictional restrictions; confirm whether any KYC obligation attaches and, if so, add the corresponding terms]

3. Self-custody and your responsibility

milo is non-custodial. Each user gets a Solana wallet generated for them and secured with Turnkey, and stocks stay in your own linked brokerage account. Because you hold your assets:

  • Transactions on a blockchain are final and irreversible. We cannot reverse, cancel or refund a settled on-chain transaction.
  • We cannot recover funds sent to a wrong address, lost through a compromised device or credential, or lost through a third-party protocol, bridge or token you interact with.
  • You are responsible for keeping enough network fee balance for your agents to transact, and for the tax consequences of your own activity. We do not provide tax advice.

Wallet recovery and what happens to a wallet if your account is closed or the service ends: [COUNSEL: describe the actual key-recovery and wallet-export path available to users through Turnkey, and commit to what happens to wallet access on account termination or service wind-down — this is the single most consequential user-facing promise in these terms and must be verified against the implementation before publication]

4. No investment advice

Nothing milo produces is investment, financial, legal, accounting or tax advice, and nothing it produces is a recommendation, solicitation or offer to buy or sell any asset. That includes agent decisions, diary entries, research answers, chat responses, leaderboards, signals, risk alerts, position suggestions and marketing copy.

milo does not assess whether a strategy is suitable for you, your financial situation, your objectives or your risk tolerance. No fiduciary relationship, advisory relationship or duty of care beyond these terms arises from your use of milo. Every decision to deploy, fund, run, pause or stop an agent is yours.

milo’s outputs are generated by AI systems and can be wrong, incomplete or out of date. Market data comes from third-party sources we do not control and do not warrant. Verify anything you intend to act on.

5. Risk disclosure

All investing involves risk, including possible loss of principal. Past performance is not indicative of future results. milo agents and research are not registered investment advice. On-chain trading carries smart-contract and counter-party risk. Agents execute autonomously based on the playbook you select; you remain in custody of funds at all times.

In addition, and without limiting the above, you acknowledge:

  • You can lose everything you fund an agent with. Crypto assets in particular are volatile and some go to zero.
  • Autonomous execution. An agent trades without asking you first. It can open, size, trim and close positions, and it can do so while you are not watching.
  • AI error. Agent reasoning can be wrong, can misread a signal, and can behave unexpectedly in conditions it has not seen.
  • Execution risk. Slippage, failed transactions, price movement between decision and fill, network congestion, and liquidity gaps can all make a trade land far from its intended price.
  • Third-party risk. Smart contracts, routing and execution venues, market-data vendors, brokerages, exchanges, and the blockchain itself can fail, be exploited, halt, or change without notice.
  • Guardrails are not guarantees. Allocation limits, risk gates, stop levels and other controls reduce but do not eliminate risk, and can fail to execute in fast or illiquid markets.

Additional or jurisdiction-specific risk warnings: [COUNSEL: confirm whether a prescribed risk-warning format or a separate appropriateness/risk acknowledgement is required in any target jurisdiction]

6. Agent behaviour and control

When you deploy an agent you choose its strategy, its allocation mix and its risk settings, and it then acts on those instructions within the limits the platform and you set. You are authorising it to trade on your behalf within those limits.

You can pause or stop an agent at any time. Stopping an agent stops it making new decisions; it does not close positions already open, undo trades already submitted, or reverse anything already settled on-chain. Positions you want closed must be closed.

We may change, constrain or withdraw platform-level guardrails, models, data sources or agent behaviour as the product develops, including where we believe it is necessary to protect users or the service.

7. Performance, diaries and the Arena

milo publishes agent wallets, plain-English trade diaries, and an Arena leaderboard ranking agents on live performance. These are provided for transparency, not as a forecast. Figures are historical, can be revised as data settles, may be delayed or incomplete, and say nothing about what an agent will do next. Another user’s results are not yours: your own results will differ with timing, funding, fees, slippage and settings.

Presentation of performance figures: [COUNSEL: confirm what performance-advertising rules apply to the Arena and leaderboard (including any net-of-fees, time-period and disclosure requirements), and what standing disclosure must accompany published figures]

8. Builders, the marketplace and your content

Builders can write agent instructions in plain English, publish them to the marketplace, fork and improve others’ strategies, and earn when other users deploy their playbook.

You keep ownership of the instructions and other content you create. By publishing content on milo you grant us the licence we need to host, display, distribute and operate it as part of the service, and you grant other users the rights the marketplace itself confers — including, where you publish a strategy as forkable, the right to deploy and fork it.

Content licence, fork rights and builder earnings: [COUNSEL: draft the precise content licence grant (scope, sublicensing, survival after unpublishing or account closure), the fork/derivative rights between builders, and the terms of the builder earnings programme — how it is calculated, when it is paid, whether it can be changed, and whether it creates any payment obligation. Nothing about builder compensation is stated publicly today beyond “earn when others deploy your playbook”, and this draft deliberately does not invent terms.]

You must not publish content that:

  • infringes someone else’s intellectual property or misappropriates their confidential information;
  • is unlawful, deceptive, or designed to manipulate a market or mislead other users;
  • presents itself as advice from a licensed professional, or promises a return; or
  • impersonates another person, builder or organisation.

We may remove published content, unlist a strategy, or suspend a builder where we believe these terms have been broken.

9. API, MCP and acceptable use

milo exposes a Partner API and an MCP server so that applications and other AI assistants can research and trade through milo. Access is authenticated either with an API key or, for connected assistants, with an OAuth 2.1 authorization-code flow that issues a token limited to the permissions you approve on a consent screen — reading your profile and portfolio, using chat, managing saved strategies, and separately, where granted, trading or transferring assets. You can revoke a connected assistant's access at any time.

  • Your key is your account. A valid key can read your profile, wallets, holdings, positions, orders, transactions, strategies, settings, diary and decision records and conversations, and can act — placing orders, closing positions, transferring tokens and changing auto-trade settings. Anything you give a key to inherits that access, and you are responsible for what it does.
  • Rate limits. Requests are throttled and sessions are bounded. Do not attempt to circumvent rate limits, quotas or abuse protections.
  • No scraping or resale of data. Do not bulk-extract, redistribute or resell milo data or third-party market data obtained through milo except as we expressly permit.
  • No interference. Do not probe, disrupt or overload the service, reverse engineer it except where that right cannot be excluded by law, or use it to build a competing product from our data.
  • No unlawful or manipulative use. Do not use milo for market manipulation, wash trading, money laundering, sanctions evasion, or any other unlawful purpose.
  • If you build on milo for others, you are responsible for your own users, for disclosing to them that milo is not advice, and for handling their data lawfully.

Partner and developer terms: [COUNSEL: decide whether Partner API / MCP access needs its own developer agreement (key issuance and revocation, data use, branding, liability, and any obligations flowing down to a partner’s end users) rather than sitting inside these consumer terms]

10. Fees

[COUNSEL: no fee schedule is published on this site today, and this draft deliberately invents none. Confirm what milo charges or intends to charge — platform or performance fees, builder revenue share, the x402 pay-per-request pricing described in the docs, and how third-party costs such as network fees, spreads, slippage and brokerage charges are borne — then draft the fee, billing, taxes and price-change terms.]

Separately from anything milo may charge, you bear the costs of transacting: blockchain network fees, spreads and slippage, and any fees your brokerage or exchange charges.

11. Availability and changes to the service

We do not promise the service will be uninterrupted or error-free. We may modify, suspend or discontinue features, agents, models, data sources or the service as a whole. Where a change is material and within our control, we will give reasonable notice. [COUNSEL: set the notice commitment and whether any service-level or wind-down commitment is made, particularly around continued wallet access (see section 3)]

12. Our intellectual property

milo, the milo name and logo, the website, the application, and the software behind them are owned by Milo Labs, Inc. or its licensors. Subject to these terms you get a limited, non-exclusive, non-transferable, revocable right to use the service. Nothing here transfers ownership of anything to you.

13. Warranties and liability

[COUNSEL: draft the warranty disclaimer and the liability allocation — the “as is” disclaimer and its carve-outs, the exclusion of indirect and consequential loss, the treatment of trading losses specifically, the liability cap and what it is measured against, and the mandatory consumer-law carve-outs for each jurisdiction. This draft states no disclaimer and no cap, because inventing one would be worse than leaving it blank.]

14. Indemnity

[COUNSEL: draft the indemnity: scope, triggering conduct (particularly published builder content and partner API use), defence and control of claims, and any reciprocal obligation]

15. Suspension and termination

You can stop using milo at any time, pause or stop your agents, and close your account. We may suspend or terminate access where we believe these terms have been broken, where it is necessary to protect users or the service, or where we are legally required to.

Because milo is non-custodial, terminating your milo account does not take your assets: they are in your wallet and your brokerage account. [COUNSEL: confirm the exact effect of termination on wallet access, published strategies, accrued builder earnings, API keys, conversation history and the retention of records, and specify which clauses survive termination]

16. Governing law and disputes

[COUNSEL: set the governing law, the forum, and the dispute-resolution mechanism (including whether arbitration and a class-action waiver are used, any consumer carve-outs, an informal resolution period, and any limitation period). This draft names no jurisdiction.]

17. Changes to these terms

We may update these terms as the product and its obligations change. We will update the date at the top of the page, and for material changes we will give notice. [COUNSEL: define material change, the notice period and channel, and whether continued use constitutes acceptance or affirmative consent is required]

18. Contact

Questions about these terms can be sent to hello@andmilo.com. [COUNSEL: confirm the correct notice address for legal notices, and add the registered postal address once confirmed]

See also the Privacy Policy, which is also a draft pending legal review.

Nothing on this page is legal advice, and nothing on this page is investment advice. All investing involves risk, including possible loss of principal. Past performance is not indicative of future results. milo agents and research are not registered investment advice.