Tenebra
Terms of Service
These terms govern every use of Tenebra: the website at tenebra.penumbreal.com, the Tenebra application for iPhone and iPad (including TestFlight builds), the public pages, the programmatic interface (API), the Excel add-in and any other integration we publish. Please read them; by using Tenebra you agree to them.
1. Who we are
Tenebra is operated by Penumbreal, the sole proprietorship (eenmanszaak) of Tuna Battaloğlu, registered with the Netherlands Chamber of Commerce (KvK) under number 42159345, VAT identification number NL005545981B19, established at De Nieuwe Erven 3, Unit 15248, 5431 NV Cuijk, the Netherlands. Contact: [email protected].
In these terms, "Penumbreal", "we", "us" and "our" refer to that business; "Tenebra" or "the Service" refers to everything listed above; "you" refers to the person or organisation using the Service.
2. Acceptance, eligibility and authority
By creating an account, tapping Agree, using an API key, installing the add-in or otherwise using the Service, you accept these terms, the Privacy Policy and the Research Disclaimer. If you do not agree, do not use the Service.
You must be at least 18 years old and legally able to enter into a contract. If you use the Service on behalf of a company or other organisation, you confirm that you are authorised to bind it, and "you" includes that organisation.
The Service is intended for professional and research use by analysts, risk managers, researchers and similar users. If you use it as a consumer, the mandatory consumer protections of your country of residence apply and nothing in these terms limits them.
3. What Tenebra is, and what it is not
Tenebra is a research instrument. It gathers public information (news, market prices, prediction-market odds, reference statistics), applies statistical models and artificial intelligence, and produces estimates of the probability that clearly defined future events will occur, together with the reasoning and evidence behind each estimate. It also grades its own past estimates in public.
Every number Tenebra shows is a model-generated estimate. It is not a fact, not a prediction of what will happen, not a promise, and not advice. Estimates change as new information arrives and may be wrong at any moment. A probability of 90% means the event is expected to fail to occur one time in ten, and a probability of 10% means it is expected to occur one time in ten; neither is a guarantee.
Tenebra does not provide investment, financial, trading, legal, tax, accounting, insurance, medical, security or political advice, and nothing in the Service is an offer, solicitation, recommendation or invitation to buy, sell, hold or trade any security, commodity, currency, derivative, prediction-market contract, digital asset or other instrument, or to take or refrain from any action. Penumbreal is not a licensed investment firm, investment adviser, broker, portfolio manager or financial institution and is not authorised or supervised by the Netherlands Authority for the Financial Markets (AFM), De Nederlandsche Bank (DNB) or any other financial regulator. Any decision you make is yours alone and at your own risk. Consult a licensed professional before making financial, legal or other consequential decisions.
The Shadow Book is a simulation. It marks a virtual paper bankroll against public prediction-market prices to measure the model's calibration. No real funds are held, transmitted, invested or traded, no brokerage or custody relationship exists, and no position in the Shadow Book is a recommendation to take a real position. References to Polymarket or any other venue are informational and are not endorsements or partnerships.
Your Book, the exposure feature, works on ticker symbols you choose to follow. Tenebra never asks for, receives or stores holdings, quantities, account numbers, brokerage credentials or any link to a real portfolio, and nothing it shows about your book is a valuation of, or advice about, any real position.
4. Accounts
Access requires an account: either a Penumbreal account, which is one account for every Penumbreal product, or an account that we create for you. Penumbreal accounts are provided through Microsoft Entra External ID: Microsoft runs the sign-in page, keeps the password and handles e-mail verification and password resets, under these terms and our Privacy Policy. Creating a Penumbreal account does not by itself give access to Tenebra; access is granted separately, by invitation or with a plan that includes it.
Keep your credentials confidential and do not share your account. You are responsible for everything done under your account, whether or not you authorised it, until you tell us at [email protected] that your credentials may have been compromised. Use accurate information and keep it current.
Each account is for one person. Organisations receive one account per user; seats are not shared. We may refuse, suspend or terminate accounts, and refuse or remove API keys, at our discretion where we reasonably believe these terms are being breached, the Service is being abused, or the law requires it.
5. Plans, fees and payment
Tenebra is offered on a free tier and on paid plans. The features, limits and prices of each plan are shown in the Service and at the point of purchase and form part of these terms. We may change the features, limits or prices of the free tier at any time, and of paid plans on at least 30 days' notice, effective from your next renewal.
Payments are processed by our merchant of record, Lemon Squeezy, LLC, which sells the subscription to you, collects payment and any applicable VAT or sales tax, and issues invoices under its own terms of sale and privacy policy, which you also accept when you buy. Penumbreal does not receive or store card numbers.
Paid plans renew automatically at the end of each billing period at the then-current price until cancelled. You can cancel at any time from your account or through the merchant of record; cancellation takes effect at the end of the current period and no partial refunds are due for the remainder, except where the law requires otherwise. Prices are shown inclusive of VAT for consumers in the EU and exclusive of VAT for business customers who provide a valid VAT number, as applied by the merchant of record.
If you are a consumer in the European Union, you have a statutory right to withdraw from a distance contract within 14 days. Because the Service is digital content and a digital service that starts immediately, by starting a paid plan you request immediate performance and acknowledge that, once performance has begun, the right of withdrawal is lost for the part of the service already delivered, to the extent permitted by law. Refunds beyond that are at our discretion or as required by law.
A "Founding" or other promotional price is personal to the account that bought it, applies as long as that subscription stays continuously active, and ends if the subscription lapses, is cancelled or is transferred. If a payment fails, we may suspend paid features until it is settled, and we may downgrade the account to the free tier after a reasonable period. Usage allowances (tracked hypotheses, analysis runs, questions, API calls) reset per period and do not carry over; unused allowance is not refunded.
6. Acceptable use
You agree not to, and not to allow anyone else to:
- use the Service for any unlawful, fraudulent, deceptive or harmful purpose, or in breach of any applicable law, including market-abuse, securities, sanctions, export-control and data-protection law;
- ask the Desk or the API for estimates about private individuals, about harming any person, about self-harm, for sexual content, or to influence or manipulate an election;
- present Tenebra's outputs as guarantees, as advice, or as endorsed by Penumbreal, or use them in any offering, marketing or communication to third parties in a way that could mislead;
- resell, sublicense, redistribute, syndicate or publicly display the Service's outputs as a data feed, dataset, index, signal service or competing product, except as expressly allowed by a written agreement with us or by the API terms in section 7;
- scrape, crawl, harvest or bulk-download the Service other than through the API within its limits;
- probe, scan, overload, disrupt, bypass rate limits or quotas, circumvent access controls, or test the security of the Service without our prior written consent;
- reverse-engineer, decompile, disassemble or attempt to derive the source code, models, prompts, weights, scoring methods or non-public parts of the Service, except where the law expressly permits despite this clause;
- use the Service to build or train a competing model or product, or to extract our prompts or methodology;
- submit content that is unlawful, defamatory, infringing, malicious, or that contains personal data of others without a lawful basis, or that attempts to manipulate the models (for example by injecting instructions into hypotheses or questions);
- share accounts, API keys or sessions, or use automated means to create accounts;
- remove or alter any notice, attribution, watermark or link in the Service or its outputs;
- use the Service where doing so is prohibited, including from a country or by a person subject to EU, Dutch, UK or US sanctions or embargoes.
We may investigate suspected breaches, and may throttle, suspend or terminate access without notice where we reasonably consider it necessary to protect the Service, other users, third parties or ourselves.
7. API keys, add-ins and integrations
Where we issue you an API key, it is confidential, personal to your account and subject to the scopes, quotas, rate limits and monthly budgets shown when it is issued or in the Service. You are responsible for all use of your key. We may rotate, restrict or revoke keys at any time, and we may change the API on reasonable notice; we aim to keep documented endpoints stable but do not guarantee backwards compatibility.
API responses and add-in outputs (for example numbers placed in a spreadsheet cell) are estimates subject to section 3 and the Research Disclaimer, and carry the same restrictions on redistribution. You may use them internally and in documents you author, provided you attribute them to Tenebra and do not present them as advice. Public report links (/r/...) are unlisted but not confidential; anyone with the link can view the report.
The Excel add-in runs inside Microsoft Excel and is provided under these terms; your use of Excel and of any marketplace through which the add-in is distributed is governed by Microsoft's terms. Third-party spreadsheet, chat or automation platforms that we integrate with are not under our control, and we are not responsible for them.
8. Your content
You keep ownership of the hypotheses, questions, notes, tickers, settings and other material you submit ("Your Content"). You grant Penumbreal a worldwide, non-exclusive, royalty-free licence to host, store, process, analyse, reproduce, adapt and display Your Content as needed to operate, secure, support and improve the Service, including passing the text of hypotheses and questions to the AI and data providers listed in the Privacy Policy. This licence ends when you delete the content or your account, except for copies in backups (deleted as the Privacy Policy describes), for content that has already been incorporated into published forecasts and their grades (kept in de-identified form as part of the public record), and where we must keep it to comply with law or resolve disputes.
You are responsible for Your Content. You confirm that it is lawful, that you have the rights needed to submit it, and that it does not include confidential information of third parties, material non-public information, personal data of others without a lawful basis, or anything that would breach section 6. Do not submit anything you would not want processed by a third-party AI model.
Hypotheses you track can appear, in name, probability, deadline and grade, on the live index and the record, which every signed-in user can see. Your account name, your notes and your conversations are never shown there.
9. Our intellectual property
The Service, including its software, design, user interface, methodology, prompts, models, scoring methods, databases, documentation, text, graphics, marks and logos, is owned by Penumbreal or its licensors and protected by intellectual-property law. These terms give you a limited, personal, non-exclusive, non-transferable, revocable right to use the Service in accordance with them. All other rights are reserved. "Tenebra", "Penumbreal" and the crescent mark are marks of Penumbreal; do not use them without our written permission.
If you send us feedback, suggestions or ideas, you grant us a perpetual, irrevocable, royalty-free licence to use them without obligation to you.
10. Third-party data and services
Market prices, news, prediction-market odds, statistics and other data are obtained from third parties (for example public news feeds and aggregators, Yahoo Finance, Polymarket and similar sources) and may be delayed, incomplete, inaccurate, discontinued or subject to those parties' terms. Their inclusion is not verification or endorsement. We have no control over third-party services and are not responsible for their content, availability, accuracy or practices. Links to third-party sites are provided for convenience only.
11. AI-generated content
Analyses, probability estimates, arguments, digests, scenario descriptions, suggested hypotheses, answers given by the Desk and other content are generated in part by large language models supplied by third-party providers (currently Anthropic) and by statistical models. Such output can be incomplete, outdated, biased, fabricated or simply wrong, may misread sources, and can change between runs. Tenebra publishes its own record precisely because its estimates are fallible. You must apply your own judgment and verify anything you rely on. We do not review AI output before it is shown to you.
Answers in the Desk, analysis texts, briefings and estimate reports are generated by an AI model working from Tenebra's engine. They are research, not investment, legal or tax advice, and they can be wrong. Tenebra makes no decisions with legal or similarly significant effects about you by automated means.
12. Availability, changes and beta features
The Service is provided "as is" and "as available". We do not promise that it will be uninterrupted, timely, secure or error-free, that scheduled refreshes, alerts or notifications will be delivered, or that any particular hypothesis will be analysed or graded by any time. We may change, suspend, limit or discontinue any part of the Service at any time, and we may impose or change usage limits. Features labelled beta, preview, experimental or delivered through TestFlight may be incomplete, may change without notice and may be withdrawn. No service-level agreement applies unless agreed in writing.
13. Suspension and termination
You may stop using the Service at any time and may ask us to delete your account by writing to [email protected]. We may suspend or terminate your access, with notice where reasonably possible, if you breach these terms, if we are required to by law, if your account has been inactive for more than 24 months, or if we discontinue the Service. On termination your right to use the Service ends, and we may delete Your Content after a reasonable period. Sections that by their nature should survive (including 3, 6, 8 to 11 and 14 to 21) survive termination.
14. Disclaimer of warranties
To the maximum extent permitted by law, Penumbreal disclaims all warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, accuracy, completeness, timeliness, non-infringement and quiet enjoyment. We do not warrant that any estimate is accurate or calibrated, that the public record predicts future performance, that the Service meets your requirements, or that defects will be corrected. Past calibration is not a guarantee of future calibration.
15. Limitation of liability
To the maximum extent permitted by Dutch law, Penumbreal, its owner and anyone working for it are not liable for: trading, investment or business losses; loss of profit, revenue, savings, goodwill, opportunity or data; the cost of substitute services; decisions made or actions taken in reliance on the Service or its outputs; or any indirect, incidental, special, punitive or consequential damage, however arising, even if advised of the possibility.
Penumbreal's total aggregate liability arising out of or relating to the Service and these terms, whether in contract, tort (including negligence), breach of statutory duty or otherwise, is limited to the amounts you paid to Penumbreal or its merchant of record for the Service in the twelve months before the event giving rise to the claim, or EUR 50 if you paid nothing.
Nothing in these terms excludes or limits liability for death or personal injury caused by our negligence, for fraud, for intent (opzet) or deliberate recklessness (bewuste roekeloosheid) on our part, or for any liability that cannot be excluded or limited under applicable law, and nothing affects the mandatory rights of consumers. Any claim must be brought within one year of the event giving rise to it, where the law allows such a limit.
16. Indemnity
If you use the Service on behalf of a business, you will indemnify and hold harmless Penumbreal and its owner against all claims, damages, losses, costs and expenses (including reasonable legal fees) arising from Your Content, your breach of these terms or applicable law, or your use of the Service or its outputs, including any use of outputs in your own products, communications or decisions or those of your clients.
17. Force majeure
We are not liable for any failure or delay caused by events beyond our reasonable control, including failures of hosting, network, AI or data providers, internet or power outages, cyber-attacks, strikes, governmental action, sanctions, pandemics, war or natural disasters.
18. Sanctions and export control
You confirm that you are not located in, organised under the laws of, or ordinarily resident in a country or territory subject to comprehensive EU, Dutch, UK or US sanctions, and that you are not a person listed on any EU, Dutch, UK or US sanctions list. You will comply with all applicable export-control and sanctions laws in using the Service.
19. Privacy
Our Privacy Policy explains what personal data we process, why, and your rights. It forms part of these terms.
20. Changes to these terms
We may change these terms. For material changes we will give reasonable notice, for example in the app, on the website or by e-mail, and the apps will ask you to accept the new version. Changes take effect on the date stated; continued use after that date is acceptance. If you do not accept, stop using the Service and, for a paid plan, cancel before the change takes effect.
21. Governing law and disputes
These terms, and any dispute or claim arising out of or in connection with them or the Service, are governed by the law of the Netherlands, excluding its conflict-of-law rules and the United Nations Convention on Contracts for the International Sale of Goods. Disputes are submitted exclusively to the competent court of the district of Oost-Brabant, the Netherlands. If you are a consumer in the EU, you may also rely on the mandatory provisions and courts of your country of residence, and you may use the European Commission's online dispute resolution platform at ec.europa.eu/odr. Before going to court, please write to [email protected]; we will try to resolve any dispute informally within 30 days.
22. General
These terms, the Privacy Policy, the Research Disclaimer and the plan descriptions are the entire agreement between you and Penumbreal about the Service and replace any earlier agreement. If any provision is held invalid, the rest remains in force and the provision is replaced by a valid one that comes closest to its intent. Our failure to enforce a provision is not a waiver. You may not assign or transfer these terms; we may assign them to a successor of the business, including a company into which Penumbreal is converted. Notices to you may be given in the Service, by e-mail to the address on your account or by posting on the website; notices to us go to [email protected]. These terms are written in English; any translation is for convenience and the English text prevails. Headings are for convenience only.
23. Contact
Penumbreal, the sole proprietorship (eenmanszaak) of Tuna Battaloğlu, registered with the Netherlands Chamber of Commerce (KvK) under number 42159345, VAT identification number NL005545981B19, established at De Nieuwe Erven 3, Unit 15248, 5431 NV Cuijk, the Netherlands. Contact: [email protected].
Also available: Terms of Service, Privacy Policy, Research Disclaimer.