Disclosures.

Drumlin is software you configure. It is published by HJB CodeForge, a sole proprietorship located in Ottawa, Ontario, Canada. Drumlin is not a registered investment adviser, investment dealer, exempt market dealer, portfolio manager, or any other category of registrant under National Instrument 31-103, the Securities Act (Ontario), or any other Canadian provincial or territorial securities legislation.

Drumlin does not engage in trading, advising, or portfolio management on your behalf. Drumlin executes the rules you select, on the parameters you set, against your own brokerage account. The rules are your rules. The trades are your trades. The outcomes are yours.

Nothing on this site, in the Drumlin application, in any Drumlin-issued email, or in any Drumlin strategy template constitutes a recommendation to buy, sell, or hold any security. We do not select, suggest, rank, score, or endorse any specific security, sector, market, asset class, or strategy for you.

The five default strategy templates we ship — gap-fill, opening-range breakout, VWAP mean reversion, moving-average crossover, and end-of-day square-up — are illustrative starting points published as editable parameters. They are not picks. They are not signals. They are not investment advice. If you want personalised investment advice, speak with a registered adviser.

Drumlin does not custody, hold, control, or have beneficial interest in any cash, securities, or other client assets. Your funds and securities remain at your broker — Questrade Inc. or Interactive Brokers Canada Inc. — at all times. Drumlin connects to your broker using your own credentials over the broker’s official public API, places orders on your behalf only when your rules trigger, and never moves cash or securities anywhere else.

Drumlin does not pool client assets. Drumlin does not earn or accept payment for order flow, kickbacks, or rebates from any broker, market maker, or trading venue. Our only revenue is the flat monthly subscription you pay directly to us in CAD.

All orders Drumlin places execute through your broker, in your account, under your name, subject to your broker’s terms, conditions, fees, commissions, margin rules, and risk-management systems. The broker is the broker of record on every trade. Drumlin is not a counterparty to any trade.

The broker’s order-handling, best-execution, and trade-reporting obligations under CIRO and applicable Canadian securities legislation are unaffected by Drumlin’s role as the software that initiates orders on your instruction.

Every strategy you create in Drumlin is locked to internal shadow execution for thirty calendar days, measured per strategy from the time you save it. During that period, Drumlin evaluates your rules against your broker’s live quote feed and writes simulated fills to a shadow ledger. No order is sent to any broker for any paper-mode strategy.

Simulated fills assume idealised conditions. They do not reflect slippage, partial fills, queue position, market impact, halts, or venue-specific quirks that affect real orders. Performance during the paper-trade window is not indicative of future live performance. Past performance, simulated or real, is not indicative of future results.

The daily CAD loss cap, the per-account kill switch, and the paper-trade gate are server-side controls Drumlin enforces to the best of its ability. They are not insurance. They cannot prevent losses caused by gap-down opens, halted markets, broker outages, internet outages, exchange failures, or events that occur between quote updates.

The kill switch cancels working orders and blocks new entries. It does not close existing positions, and it does not protect against market moves that happen after a position is open. Closing a position is your responsibility and your broker’s.

Trading equities and exchange-traded funds carries a real and material risk of loss, including loss of the entire principal you invest. Rule-based and algorithmic trading does not reduce that risk and may amplify it. Markets move in ways that backtests, simulations, and intuition do not anticipate.

Only trade with capital you can afford to lose. Read your broker’s account agreement and risk disclosures in full. If you are not sure whether rule-based trading is suitable for you, speak with a registered adviser before enabling live mode on any strategy.

Drumlin’s trade journal CSV is a reconciliation tool. It computes per-symbol Adjusted Cost Base, realised gain and loss, and flags rows that may fall under the thirty-day superficial-loss rule based on the trade data Drumlin has recorded. It is designed to sit beside the T5008 your broker issues at tax time.

Drumlin does not issue T5008 slips. Drumlin does not file taxes on your behalf. The journal is not tax advice. Use it with your accountant or registered tax professional. If the journal disagrees with your broker’s T5008, the broker’s T5008 is the authoritative document for CRA purposes.

Drumlin is offered to residents of Canada who hold a self-directed retail account at a Canadian broker that Drumlin supports. You must be the legal account holder, of the age of majority in your province or territory, and authorised to operate the account.

Drumlin does not solicit business in any jurisdiction where doing so would require Drumlin or HJB CodeForge to register as an adviser, dealer, or other regulated entity it is not registered as. If you access Drumlin from outside Canada, you do so on your own initiative and at your own risk.

Drumlin charges a flat monthly subscription denominated in Canadian dollars. We do not charge performance fees, success fees, profit shares, or any compensation tied to the outcome of your trades. We do not publish leaderboards, social copy-trading feeds, or shared strategies, and we do not show one user’s performance to another.

Marketing copy on this site that describes future product features, broker integrations, or regulatory positions is forward-looking and subject to change. Wealthsimple Trade integration, Interactive Brokers ISV approval, and any feature listed as “v2” or “deferred” are intentions, not commitments. Do not subscribe to Drumlin in reliance on a feature that has not yet shipped.

To the maximum extent permitted by applicable law, HJB CodeForge and Drumlin are not liable for any loss, damage, cost, or expense arising from your use of the software, including trading losses, broker fees, tax liabilities, missed trades, slippage, or any indirect, incidental, consequential, or punitive damages. Your sole remedy for dissatisfaction with Drumlin is to cancel your subscription.

Nothing in this section limits a liability that cannot be limited under applicable Canadian consumer-protection or securities legislation.

We update these disclosures when the product, the brokers we connect, or the applicable regulatory framework changes in a way that affects what we say here. The date below is the date of the most recent update. Material changes are emailed to active subscribers before they take effect.

Questions about these disclosures, including from registered advisers, accountants, or counsel acting for a Drumlin user, go to hello@drumlin.com. Mail addressed to HJB CodeForge, Ottawa, Ontario, Canada reaches the founder.