Who produces the analysis, and what interest is declared
The signals InbestPlanners publishes, which are non-personalised investment recommendations, are generated by a proprietary model. The natural person responsible for producing them is identified in the Terms and Conditions and in the Legal Notice.
That person may hold or open positions in the financial instruments covered by the analysis. There is therefore a conflict of interest, and it is declared together with what neutralises it.
In addition, InbestPlanners uses services from three issuers the analysis covers, on the standard terms they offer any customer (free, or paid at list price):
- Alphabet Inc. (GOOGL, GOOG), through Google: Sign in with Google, Google Analytics (only with the reader's consent), paid advertising campaigns on Google Ads, and Google Search Console.
- Meta Platforms, Inc. (META), through Meta Platforms Ireland: posting on our Instagram accounts, paid advertising campaigns on Instagram and Facebook, and the Meta pixel (only with the reader's consent).
- Cloudflare, Inc. (NET): DNS for the domains, the Turnstile anti-bot check on the forms, and R2 storage for the encrypted backups.
None of these relationships depends on what is published about those companies, and their signals are computed with the same rules as those of any other security.
How the conflict is neutralised: design, disclosure and commitments
Three pieces work together: the design of the process reduces the window for front-running to an interval in which each security's regular market is closed; this declaration discloses the conflict publicly and verifiably; and the conduct commitments cover what the design does not reach.
The natural concern is front-running — that whoever publishes a recommendation trades ahead of its readers. On the market where each signal is calculated that is not possible, and not because of an undertaking about conduct but because of how the system is built:
- Signals are computed on the session CLOSE, from closing prices. They do not exist during the session.
- Each market is processed on a schedule after its official close: the European ones when the European session ends and the US ones when the New York session ends. No signal is computed while its market is open.
- Publication follows when that processing ends, with the market of each security already closed.
- The entry the recommendation proposes is a limit order calculated on that same close (the close plus 0.5%) and valid only during the NEXT session.
So when a signal is published, the regular market on which it was computed has closed, and the entry it proposes refers to the next session, which neither the person responsible nor any subscriber can anticipate.
The design has a limit. Some securities also trade on another market with different hours (e.g. European shares with depositary receipts in the United States), and there are extended sessions and derivatives traded outside regular hours. In those cases the design is not enough on its own, so a commitment is added: not to trade any instrument between the generation of a signal and its publication, whether or not a market is open in that interval.
| Markets | Official close (exchange local time) | Processed |
|---|---|---|
| Covered European markets | 17:00–17:30 CET/CEST (London, 16:30 GMT/BST) | After the close, once the closing price is final at the data provider |
| Covered US markets | 16:00, New York time | After the close, once the closing price is final at the data provider |
Every recommendation stores its time of production and its time of first dissemination, so the gap between them and their position relative to the market close can be checked against the data itself. An automated check refuses to generate a market's signals while that market is trading, so this does not depend on nobody mistaking the hour. For the US markets, in addition, the process accepts no close before 16:20 New York time and waits, up to a limit of 23:00 Madrid time, until the closing price stops changing at the data provider; if it has not settled by then, it goes on with the latest one available.
What the responsible person undertakes not to do
- Not to trade any instrument between a signal being generated and being published, even if the market is shut.
- Not to trade against a live recommendation on the same instrument.
- Not to alter, delay or withhold a publication by reference to their own position.
What InbestPlanners does not do
- It does not execute orders or intermediate: it is not a broker, a dealer, a management company, an investment advisory firm or a tied agent. The user decides freely whether to trade, and does so through their own intermediary.
- It takes no payment from third parties to cover, highlight or omit any instrument, and it advises no covered issuer. Its only relationships with covered issuers are those of a user or customer declared in the first section.
- The analysis is funded solely by user subscriptions. Any personal positions of the person responsible are declared in the first section and in the next point.
- The person responsible does not hold, in any issuer analysed, a net long or short position exceeding the 0.5% threshold of its issued share capital (Article 6.1.a) of Delegated Regulation (EU) 2016/958).
Remuneration
The responsible person's remuneration comes from subscriptions to the service and is not linked to the outcome of any particular recommendation, nor to trading in any instrument.
This declaration is revised whenever any of the facts it describes changes. Its change history is kept in the project's version control.