TERMS AND CONDITIONS

INFORMATION ABOUT FINFOLLOW

FinFollow AB, Reg. No. 559331-2142, Odenvägen 17, 133 38 Saltsjöbaden, Sweden

www.finfollow.com

[email protected]

GENERAL AND DEFINITIONS

1. These Terms of Use (the “Terms“) govern FinFollow’s relationship with users of FinFollow’s application (the “Platform“) available on AppStore, Google Play and web. The person (natural or legal) who uses or logs on to the Platform (“Member“) is deemed to agree to these Terms in any applicable form. A Member (who in case of a legal person could be a natural person representing the legal person) can be any one or several of the following three options:
   1. User; a person who is a Member;
   2. Contributor; a person who is a Member and offers a paid or non-paid subscription, through FinFollow to Followers to get access to investment account details, as per the Contributor’s configuration, and get notifications regarding buy and sell activity related to the investment account; and/or
   3. Follower; a person who is a Member and subscribes (paid or non-paid subscription) to the Contributor to get access to the Contributor’s investment account details, as per the Contributor’s configuration, and get notifications regarding buy and sell activity related to the contributor’s investment account; for this purpose the Follower and the Contributor enter into a separate agreement (the “Follower Agreement”) which FinFollow is not a party to (FinFollow is only a mediation service through the Platform) unless FinFollow is acting as a Contributor.
2. A User can connect one or more investment accounts from their banks. This requires the User to authenticate towards their bank and sign in via FinFollow’s application. When connecting an account, the User permits FinFollow to collect the relevant investment account data from the bank. The User also permits FinFollow to keep the session alive and collect data ongoing, in order to provide a relevant service. The User acknowledges that the connection will from time to time be lost for various reasons, and that FinFollow may then prompt the User to re-establish the connection to the bank in order for the data to be updated.
3. The account(s) that a User chooses to share on the Platform (making the User a Contributor) are hereinafter referred to as “Shared Accounts“. The Shared Accounts will be displayed with the following data:
1. percentage holdings in the specified financial instrument in relation to the total value of the Shared Account;
2. the historical development (%) of the Shared Account since the investment account was opened;
3. transactions indicating the date, time, financial instrument, transaction price and transaction type since the investment account was opened; and
4. account type.

In addition to above, the Contributor may also choose to display the following data related to the Shared Account;

1. funds invested per financial instrument and in total;
2. account balance; and
3. Transactions indicating transaction amount and fees.

above is hereinafter referred to as “Shared Data”. FinFollow has the right, at any time and at its sole discretion and without notice to its Members, to omit, add or remove financial instruments from being included in Shared Data for example, but not exclusively, due to the risk of market abuse. For this reason, the Shared Data may not completely or correctly reflect the Shared Account.

1. The content of the Platform is created by the Users and / or Contributors and each User / Contributor is responsible for the accuracy of the information it contributes on the Platform and that it acts in accordance with applicable laws and regulations. No content is to be considered financial advice.
2. Content and data on the Platform or from FinFollow are not always provided in real time, but some time delay may occur, for example, regarding Shared Data, market data and notifications, due to technical and / or Contributor limitations.

MEMBERSHIP AND ACCOUNT SECURITY

1. Natural persons who are at least 18 years of age and otherwise authorized to enter into contracts may become Members of FinFollow (“Membership”). In order for the Contributor to share its Shared Data on the Platform, the Contributor must have its Shared Account with a bank which FinFollow has access to.
2. A Membership is created through the Platform. The Member creates an account by completing the registration form on the Platform and confirming that the Member has read and agreed to these Terms and the Privacy Policy available on http://www.finfollow.com/privacy. Following clicking “Create Account”, the Membership is confirmed and activated.
3. Members are allowed to act under alias on the Platform in order to minimize the risks of someone improperly exploiting the Shared Data and other data posted on the Platform. It is however not allowed to impersonate someone else when registering a profile. It is essential not to disclose personal information or other information that may be used for improper purposes and/or to the detriment or harm of the Members or others, such as for online fraud or identity theft.
4. The Member is responsible for not disclosing login details to anyone else and may not give anyone else access to the FinFollow Account or do anything else that could threaten the security of the account. The Member is also obliged to keep FinFollow updated with its contact details at all times. The Member may not create an account for someone else (with the exception that a natural person may create an account as representative for a legal person).
5. All information provided by a Member is published on the Platform without preview by FinFollow. In order to create an inviting and friendly tone on the Platform, Members are encouraged to draw Finfollow’s attention to other Member’s violation and abuse taking place on the Platform. Members contact [email protected] to inform FinFollow about any adverse behaviour.

USER DATA

1. When a Contributor posts content or information (including Shared Data) on the Platform, the Contributor allows Followers to access and use the data and associate it with the Contributor’s FinFollow profile.
2. The Contributor further grants FinFollow a non-exclusive, transferable, licensable, royalty-free, global license to use all content and information that the Member publishes on the Platform and which is subject to copyright (“Protected Material“).

MEMBER’s RESPONSIBILITY

1. Each Member undertakes to comply with these Terms in their entirety. This means, among other things, that each Member undertake to:
   1. comply with all applicable laws and regulations when using the Platformand not to use FinFollow or the Platform to carry out any illegal, misleading, harmful or discriminatory act;
   2. ensure that the conduct on the Platform cannot be considered to constitute the dissemination of false or misleading information that may constitute market manipulation under the Market Abuse on Penalties for Market Abuse in Trading Financial Instruments Act (Sw. lag om straff för marknadsmissbruk vid handel med finansiella instrument) or similar regulation applicable to the Member and not to provide inside information or otherwise act with the aim of unduly influencing the valuation of a financial instrument;
   3. contribute to a positive mood on the Platform by refraining from personal attacks, aggressive statements, insults, racist or sexist views, posts that are irrelevant to the purpose of the Platform, commercial messages and statements that may seem offensive;
   4. not publish content that is hateful, threatening or pornographic or that incites acts of violence or violates the provisions of applicable regulations such as the General Data Protection Regulation (GDPR) or the Swedish Electronic Message Board Liability Act;
   5. not contribute material, or link to material, that may infringe someone else’s rights or are otherwise contrary to law or the right of another;
   6. not obtain or attempt to access other Members’ login details or prepare or attempt to gain improper access to connected networks or data resources, or unauthorized access, use, destroy, distort or forward information from such source;
   7. not collect other Members’ content or data, or otherwise access the Platform through automated methods (e.g. robots, spiders or scrapers);
   8. not upload viruses or other malicious software code or take any action that may disable, overload or impair the functionality of the Platform; and
   9. not, without the approval of FinFollow, market or advertise for its own or others’ services.
2. It is not permitted to publish investment recommendations or to provide investment advice on the Platform .

PERSONAL DATA

1. FinFollow, as data controller, processes the personal data submitted and collected in connection with the application and agreement, or which is otherwise registered in connection with the administration of FinFollow AB Reg. No. 559331-2142, Odenvägen 17, 133 38 Saltsjöbaden, Sweden, E-mail: @finfollow.com
2. The purpose of the processing is to collect, control and register the personal data before the conclusion of a contract and to document, administer and fulfill the agreements entered into. In addition, the data may be processed to comply with legal obligations, conduct market, business and customer analyses (including profiling), conduct marketing and improve, develop and customise the services and products offered.
3. The personal data may also be processed for purposes other than for which it was collected, in accordance with applicable law. If direct mail blocking has been requested, the data will not be processed for direct marketing purposes. Full information on the processing of personal data and the rights of data subjects can be found on www.finfollow.com. By accepting these Terms, the Member as a data subject confirms that he/she has received this information.
4. FinFollow will not, beyond what follows from these Terms, disclose the identity of any Member (in the event that it is not apparent from information provided by the Member itself on the Platform) to third parties unless FinFollow is required by the competent authority to disclose such information, which could occur, for example, in the event of criminal suspicion directed against Members.
5. Emails to Members may contain news and information from FinFollow as well as information and offers from FinFollow’s partners. At the request of the Member, FinFollow ceases mailings that are not required for the maintenance or performance of the Platform.

INTELLECTUAL PROPERTY RIGHTS

1. All rights (such as copyright or trademark law) to all materials (including text, data, graphics, logo, structure and layout) that appear on the Platform, and which Members have not contributed with, belong to FinFollow and/or its right holders. Members are therefore not entitled to copy, download or disseminate such material.

COOKIES

1. The Member must, in order for the Platform to function properly, accept the FinFollow Cookie Policy available on http://www. finfollow.com/cookies. On the Platform, cookies are used to enable FinFollow to measure traffic on the Platform and to improve the experience for the Members. If Members do not accept the use of cookies, the browser may be configured to not accept cookies or users may choose not to use the Platform. If Members choose to set their browser not to accept cookies, FinFollow cannot guarantee that the Platform will function properly.

FEES

1. The Membership is free of charge until further notice. Please note that a fee may apply for the Follower if a Follower chooses to follow a Contributor.

CONTRIBUTOR AND FOLLOWER FEES

1. Each Contributor may enter into a Contributor Agreement with one or several Followers pursuant to which the Follower(s) get(s) access to the Contributor’s investment account details, as per the Contributor’s configuration, and get(s) notifications regarding buy and sell activity related to the Contributor’s investment account. The Contributor Agreement regulates the revenue share between the Contributor and FinFollow i.e. the revenue which FinFollow shall be entitled to, out of the fee paid by the Follower to the Contributor, for the information mediation service. The Contributor Agreement shall be in the form as provided by FinFollow and is non-negotiable. The current revenue share is stated on Finfollow’s webpagewww.finfollow.com For the avoidance of doubt, the Contributor shall pay all transaction fees related to its trades and the Follower shall pay all transaction fees related to its trades.

LIABILITY AND DAMAGES

1. FinFollow is not responsible for any content or information provided to Members by FinFollow or that Members transmit to or share on the Platform. All use of the Platform is at the Member’s own risk. The Platform is provided as is without guarantees of security or availability.
2. FinFollow is not responsible for any direct or indirect damage or loss suffered by Members or third parties due to content or information provided by FinFollow or that Members transmit to or share on the Platform or due to deficiencies in accessibility to the Platform or if FinFollow decides to terminate the provision of the Platform, if such termination has been duly notified in accordance with section 13 below. FinFollow is also not responsible for the actions or data of third parties and Members disclaim FinFollow from any claims and damages arising out of or in any way linked to Members’ use of the Platform.
3. FinFollow does not provide investment advice and does not prepare investment recommendations or analyses under MiFID, the Securities Markets Act (Sw. lag om värdepappersmarknaden) or the Financial Instruments Trading Act (Sw. lag om handel med finansiella instrument) or any other similar applicable regulation. FinFollow completely disclaims responsibility for any advisory comments or recommendations that Members contribute on the Platform. The Follower has neither the right nor the opportunity to turn directly to FinFollow (or the Contributor) for individually designed advice of any kind. The Follower acknowledges through the Membership that it is fully aware that securities trading is associated with the risk of capital loss and that historical returns are no guarantee of future returns. The Follower further confirms in the same way that it is aware that securities may increase and decrease in value, which means that it is never guaranteed to get back the principal amount it deposits or move into its own account. The Follower also confirms that it is aware that the value of certain securities may be affected by changes in exchange rates.
4. FinFollow reserves the right to monitor and remove content on the Platform but does not review posts before they are published.
5. Violation of these Terms or applicable law or regulation may result in FinFollow terminating the Membership and make Members liable to FinFollow for any damage that they may have caused FinFollow through such breach. If anyone makes claims for damages against FinFollow relating to the Member’s actions, the Member’s content or data on the Platform and the Member’s breach of these Terms or applicable law or regulation, it is the responsibility of the Member to indemnify FinFollow for any damage, loss and cost of any kind arising out of such claim.

TERMINATION OF MEMBERSHIP

1. FinFollow has the right to terminate a Membership at any time and without giving reasons and to close an account if FinFollow believes that it is in breach of the Terms or otherwise uses the Platform in a way that, in FinFollow’s opinion, may cause harm to the Platform, FinFollow, Members, FinFollow’s partners or other third parties. A Member may close the FinFollow account at any time, but a Contributor must not do so until the current term of all current Followers has ended in accordance with the Contributor Agreement. FinFollow also has the right to block a person from becoming a Member again following a previous suspension.
2. Any comments contributed by the Member will remain on the Platform if FinFollow does not believe that there are grounds to remove them.
3. If FinFollow has closed the Member’s FinFollow Account due to misbehaviour or breach of these Terms by the Member, a new account may not be opened without Finfollow’s permission.

CHANGES TO/TERMINATION OF THE PLATFORM AND THE TERMS

1. FinFollow shall have the right to make changes to the Platform at any time, change the Terms or to stop providing the Platform. FinFollow shall inform all Members with one month’s notice in the event of a change to the Terms and with three months’ notice if it shall cease to provide the Platform. If a Member continues to use the Platform after changes to the Terms have been made, it means that they agree to the change.

APPLICABLE LAW AND DISPUTE RESOLUTION

1. Interpretation and application of these Terms shall be made in accordance with Swedish law and dispute in connection thereof shall be decided by a Swedish court. Furthermore, the Member has, if he/she is a consumer, the opportunity to turn to the Swedish General Complaints Board (Sw. Allmänna Reklamationsnämnden) to have the dispute heard.

Allmänna Reklamationsnämnden

Box 174

101 23 Stockholm

1. As a European consumer the Member may also turn to the EU Commission’s online platform for alternative disputes http://ec.europa.eu/consumers/odr/