Any reference in this Agreement to the terms "we", "our", "our" and "ourselves", as the case may be, means that Eurotrade Investments RGB Ltd (‘Gratis app’ or Company). Similarly, any reference made to "Client", "you", "your", and "yourself" as applicable will refer to you as a client of our services under this Client Agreement.

We are authorized and regulated by the Cyprus Financial Supervisory Commission (“CySEC”). Our CySEC registration number is 279/15.

Our registered office is located at 70, Kyrillou Loukareos Street, Kakos Premier Tower, 1st Floor, 4156, Limassol, Cyprus and we are registered in Cyprus with company number HE317893. We operate under the trade name Gratis app.

Please read the terms of this Agreement carefully before opening an account on our site. You should understand that by opening an account on our site you are agreeing to be legally bound by the Client Agreement.

You can validate this Client Agreement on our Website by checking the declaration stating that you have read, understood and accepted the Client Agreement. Please understand that if you refuse to accept this Customer Agreement, you will not be able to open an account with us. This Customer Agreement will be effective on the date you accept it on our website and / or through our mobile applications.

Subject to have sufficient funds, we will provide you with a mobile application that allows you to buy and sell certain types of securities. We will arrange for those securities to be held for you, by our chosen custodian. We will also arrange for your available funds to be held for you by our chosen custodians. We refer to these as the ‘’services’’ that we will provide to you.

Certain shares available to trade through our Services are offered for fractional investment. Buy and sell orders for these shares will be submitted in terms of the cash value you wish to invest. The number of shares you buy or sell through this order may include a fraction of a share (following any currency conversion, including the deduction of relevant charges).

Other Securities available to trade through our Service are offered for whole share investment only. Any orders for these securities will result in a whole shareholding only.

The services offered are the same for all of our clients. We do not offer tailor-made services to any of our clients and we do not offer any advice as to whether or not our Services are suitable to any of our clients. It will be your responsibility, at all times, to ensure that the Services we offer (including the functionality that we offer and the way(s) in which we deliver the Services), including any changes to the Services, are suitable to your specific needs and circumstances. If our Services do not meet your needs, you should stop using our Services.

We will categorise and treat you as a “retail client” as defined by Cyprus Financial Supervisory Commission , without any exception. As a result, you will benefit from the regulatory protection afforded by the relevant rules.

The Services that we offer are what is known as “execution-only” services. That means, we will (subject to the remainder of this Agreement) execute your Instructions without investigating or advising on the suitability or otherwise of the investment or your Instructions.

We do not provide or offer any investment or other advice, including advice on the suitability of any particular investment or investment strategy.

You agree that, by using our Services, you are responsible for your own investment decisions (i.e. the decision to buy, sell, withdraw monies, etc.) and investment strategy and that you have sufficient knowledge and experience to make those decisions, taking into account the risks associated with investments generally or a particular nature. If you are unsure of any investment or investment decision, you should seek the services of a qualified and registered financial adviser before you make the investment or decision.

You agree that, when you provide an Instruction to us through our Services, we will be entitled to assume that you have considered the risks and merits of the proposed Instruction and taken independent advice where necessary.

We may from time to time publish general or specific information or commentary on our mobile and website application, our website, in the general press, through communications with you or otherwise. You agree that none of that information or commentary will ever constitute investment advice by us, and you should never treat it as such.

You hereby agree that neither Gatis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature and howsoever arising, for any Loss arising from your decision to buy or sell Securities through our Services or otherwise through the use of our Services.

Our services are only available to retail customers, who are over 18 years old and who trade for their own account.

Our services laid out in this agreement are only available to customers who are tax residents in the European Union.

By using our services, you expressly confirm you are doing so in your own capacity, as a retail customer. You will use our services for your own account and not for the benefit of anyone else, you are a resident of the European Union, you are over the age of 18 and you will immediately stop using our services if any of the above cease to apply.

You confirm that you are not a resident of the United States of America, including those who qualify as 'US Citizen', 'permanent resident', 'resident alien' or 'US Person' as per the law of the United States of America (each a “US Person”) and residents of other jurisdictions that do not or only limited tolerate the offering of financial or investment services to their citizens (a “Resident”) must not use the services of Gratis app.

You agree that you will use your Gratis app Account and issue Instructions at all times in accordance with all applicable laws and regulations. You will, in particular, but without limitation, not:

• engage in any practice that is considered to be market abuse,

• use your Gratis app Account or issue any Instructions in connection with any attempt to launder money or avoid applicable sanctions against any person, company or country, or

• provide any false or otherwise misleading information in relation to your identity or personal circumstances that we request in order to provide you with a Gratis app Account.

You agree that you are not, and will not become for the duration this Agreement remains valid, a US person for the purposes of residency or tax.

This Agreement sets out, in various places, events for which we do not assume any liability. You should read the Agreement carefully to understand the circumstances in which we accept no liability.

We will only be liable to you in connection with the Services that we provide or this Agreement, in the following circumstances, namely where:

• this Agreement does not exclude or limit our liability, and

• we have been negligent or in willful default of our obligations under this Agreement.

You agree that we will under no circumstances be liable for any:

• consequential, indirect, incidental or special Losses; or

• economic loss, loss of profit, loss of business, loss of revenue or trading losses of whatever nature, in each case that result from or relate to your use or our provision of the Services or this Agreement, even if you have advised us of the possibility of such Loss.

We are not liable for any delays in the Services, including the execution of Instructions or settlement of orders, or for market movements between the time that an Instruction was placed and the time it was executed.

We are not liable for any Loss or failure to provide the Services, caused by any event outside our reasonable control, including unavailability of our Services caused by disruption to or failure of market infrastructure, communications networks or technology systems.

You are responsible for payment of all appropriate taxes. We are not liable for any Losses that arise from any taxes imposed on you as a result of your use of our Services, or for any changes in tax rates.

Nothing in this Agreement limits or excludes our liability for:

• death or personal injury caused by our negligence;

• our own fraud; or

• Losses that we cannot limit or exclude under applicable laws and regulations.

You agree that, in providing the Services and acting on your Instructions, we do so in accordance with your Instructions. You hereby indemnify us against any Losses arising from any claim against us as a result of or in connection with our execution of your Instructions.

Gratis app provides clients with the ability to buy and sell various Investments on a non-advised (i.e. execution only) basis, and transmits those orders to an Execution Broker via the Gratis app.

Trading financial Investments involves an element of risk. The value of your investment may fall as well as rise and you may get back less than your initial investment, and in some cases, you may lose your entire initial investment. Past performance of an Investment is not an indication of its future performance. Further details on the risk of trading in shares are set out in our Risk Disclosure. Before using the Gratis app to submit Orders in relation to Investments, you should consider whether you have understood the risks detailed in these terms and the Risk Disclosure.

The risks set out in our Risk Disclosure do not represent all the risks involved when using the Services that we provide to you under this Agreement, there may be additional risks to you and your capital both currently and in the future and is not intended to be a comprehensive explanation of the key risks. If you have any questions or concerns about any of the content of this Agreement or any of our other agreements or notices, you should seek independent professional advice before using the Services.

When we may need to make changes to our services from to time. For example, we may add a new piece of functionality to our services, (e.g. adding a new order type like limit orders), removing features or functionality from our services, changing the countries who residents are allowed to onboard, changing the look and feel of our applications and changing the third parties we use or rely on to be able to deliver the services. This is not a definitive list of changes that we may make.

You may not be notified of any services changes before we make them, or before they take effect, so you should make sure that our services remain suitable to your specific circumstances and stop using them if this is no longer the case.

If the changes we make result in not being able to offer our services to you (such as removing a country from the supported list), we will take reasonable steps to try to notify you of this in advance of the changes taking effect.

Your right to use our Services will cease immediately and automatically from the moment that our Services are changed in such a way that we can no longer provide them to you. In such an event, we may either freeze your account (which means that you will no longer be able to issue buy or sell Instructions to us) and/or we may close your account (please refer to the section on Consequences of Termination for a description of what will happen if your Gratis app Account is closed).

Further details of applicable fees and charges which are levied for transactions in Investments are provided in our Costs and Charges policy. Fees and charges will only be applied for Orders which have been transmitted by us and then either executed or transmitted for execution by the Execution Broker.

10.1. You have the right to deposit and withdraw money from your Account using the methods provided within our app. We have the right to restrict the methods available at any time. Please note that, depending on the method, special conditions may apply for the deposit to take place. Please note that for deposits and / or withdrawals you must use a bank account whereby you are the sole beneficiary. If this is not the case, the deposit and/ or withdrawal will be rejected, and a fee be charged.

No third party bank deposit into your Account is permitted at any time. You can transfer money to Your Account only after you have signed a contract with Us and received a username and password to access the Trading Platform.

You can submit a withdrawal request by logging into your account. Please note that it will take up to 3 (three) business days for your request to be processed. You will have the right to withdraw money from your Account up to the amount of available funds to withdraw. No payment to third parties is authorized from your Account.

You acknowledge that, by default, the withdrawal of any part of the available funds will be executed using the same method and to the same source as the funds originally came from. In certain situations, subject to Our approval, we may make an exception for a withdrawal to be executed with a payment method different from that used for the deposit. You must provide Us with all proof that We request that the new payment method is in your name.

You may not be able to withdraw the proceeds from the sale of shares from your account until the sale is settled on the settlement date (normally 2 days after the trade date). Notwithstanding the foregoing, we may, at our absolute discretion in certain circumstances, upon receipt of a request from you, allow the withdrawal of small amounts. The proceeds from the sale of shares held in your account can be used prior to the settlement date to purchase more shares.

You agree that each time you confirm a withdrawal, Gratis app will use a specific payment intermediary or bank to process your withdrawal in accordance with your Payment Instruction. The payment intermediary or the bank may withhold the withdrawal amount while the payment transaction is being processed, which means that the withdrawal amount will no longer be considered as Customer Money.

We may request additional information and / or documents to verify the legitimacy of any Payment Instruction request. We may delay or refuse the processing of a Payment Instruction if there are valid reasons, including:

• the authenticity of the instruction given;
• suspected unauthorized or fraudulent use of your Account;
• the validity of the designated and provided bank account; Where
• legal or regulatory requirements.

You hereby agree that in such circumstances there may be a delay in processing your payment instruction.

All Instructions to trade Securities will be executed in accordance with our Order Handling Policy and the best execution policies of the chosen providers stated above. You agree that you have read and agree with the respective best execution policy and our Order Handling Policy by agreeing to these terms. We do not have control over those execution vendors platforms other than our responsibility to make reasonable efforts to ensure that an execution platform is capable of delivering adequate service to you. Consequently, we do not accept any liability, of whatever nature, if any Instruction fails to execute or for any Loss arising from non-executed Instruction.

Best execution policy of our execution providers may change from time to time. You may not be notified of these changes before they take effect. It is your responsibility to ensure that you reconfirm and accept the respective best execution policy before you place Instructions with us. You acknowledge and agree that we may assume you have read and agree with the respective best execution policy each time that we accept your Instructions, and agree that neither Gratis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature, to you or anyone else for any Loss, of whatever nature, that you may suffer as a result of your failure to review of the certain best execution policy.

We accept Instructions at our sole discretion and reserve the right to refuse to accept your Instructions and/or to execute them after we have received them, at our sole discretion. We will use reasonable endeavours to notify you if we refuse to accept your Instructions and/or if we decide not to execute them, although there may be circumstances where we are unable or not allowed to do so. You agree that neither Gratis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature, to you or anyone else for any Loss of whatever nature that you may suffer as a result of our decision not to accept your Instructions and/or not to execute your Instructions.

If you give us an Instruction to buy Securities or to transfer funds to your Bank Account, you hereby irrevocably authorise us to deduct those amounts (together with our fees and any associated costs, charges, taxes and other deductions shown on our Website or our mobile application) from your Cash Balance. If you do not have sufficient Cash Balance to cover the entire amount set out in the Instruction (including associated costs, charges, taxes and other deductions) you hereby acknowledge and agree that we will not process that Instruction (specifically, we will not process Instructions in part to cover only the amounts that you have in your Cash Balance). You agree that neither Gratis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature, to you or anyone else for any Loss that you may suffer as a result of us not executing Instructions where you did not have sufficient Cash Balance to cover the Instruction (including associated costs, charges, taxes and other deductions).

If you give us an Instruction to sell Securities or where you transfer funds to us from your Bank Account, you hereby irrevocably authorise us to add the proceeds of the sale transaction (less any associated costs, charges, taxes and other deductions shown on our Website or our mobile application) or the amounts that you have transferred to us (as appropriate) to your Cash Balance.

We currently only provide market orders via the Gratis app. When you place an instruction, we will execute your order as soon as reasonably practicable after we have received it. Under normal circumstances, there should be no (or very little) delay between the time you place the instruction and the time we execute, as long as this is placed during the trading hours of the chosen market. We do not allow you to place orders outside of markets hours at this time.

Once an order has been executed, you will not have any ability to cancel, so you must ensure that you are satisfied with your instructions before you commit.

As a result of the way in which we execute Instructions for our Instant order type, the price of the Securities at the time that we execute your Instruction should, under normal circumstances, not be very different from the price of the Securities displayed through our mobile application at the time that you placed the order. However, given the speed at which markets move, and given that the execution price is different from the prices displayed through our Services (see the section on Pricing of Securities below), there may be some difference between the price of the Security displayed through our Services and the execution price. As a result, where you place an Instruction to:

• sell a specific number of Securities, the price of those Securities may be higher or lower than the price shown at the time that you placed the Instruction with us (and we will credit your Available Funds with the proceeds actually received), or
• spend a certain cash amount on buying Securities, you may receive fewer or more of the Securities (or fractions of Securities) than the amount of Securities that was shown at the time that you placed the Instruction with us.

You hereby agree that neither Gratis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature and howsoever arising, for any Loss arising from us executing your Instructions at a price that is different from the price that was shown through our Services at the time that you placed the Instruction.

For us to facilitate your instruction to buy or sell securities, we rely on external market infrastructure and counterparties to settle the trade. Your security investments will settle in accordance with local markets. This is generally on a T+2 basis. We have no control over this and so do not accept liability, of any nature, if those trades fail to settle or for any loss arising from failed trades. If a trade fails to settle, we will credit your account and make available to withdraw the amount, as soon as practicable in the circumstances, less any costs or fees that are not refundable.

You will be shown a summary of your Instruction before you finally place it with us, together with the price of the relevant Security and all associated fees, costs, taxes and other deductibles. It is your responsibility to ensure that your Instructions are accurately reflected, and that you accept the price and all associated fees, costs, taxes and other deductibles, before you finally place the Instruction. Once you have placed an Instruction, you will not be able to cancel it.

We will display market data to you, including the latest market price received for various securities. This data will be displayed by us, exactly as we receive it from third party providers. The data is subject to change and will be updated frequently. This data in some cases will be real time or close to real time market price and in other cases a delayed market price. We will inform you of the source, type of data and if delayed, the last point in which the last data point was received.

The market data displayed as part of our Services is highly confidential and made available to you on condition that you will not use that data for any purpose other than in connection with our Services. In particular, but without limitation, you hereby agree not to:

• use any of the data that we provide as part of our Services for commercial purposes;
• make that data available to any other person (whether for free or otherwise);
• publish that data anywhere; or
• provide access to that data to anyone else through your account.

The price at which we execute your buy or sell instruction will be the price that we obtain from the market at the point of execution of your instruction. That price may be different from the price of the relevant security displayed to you on our mobile application.

The execution price is the price that the market is willing to buy or sell the security in question, at the point of execution and is not something we can control.

We are not responsible for any movements in the market or pricing differences, between the time that your instruction has been placed and the time your instruction is executed.

You accept and understand that there is a difference between market prices displayed as part of our Services and the price at which the market is prepared to execute a transaction at the point of execution of the trade.

We do not validate that the market data that we receive from our market data providers and that we display as part of our Services, is correct or accurate, nor do we verify that the price at which Instructions are executed in the market is the best price available in the market for the relevant Securities (we do, however, comply with our best execution duties as required by our regulators).

We assume no liability if the market data we display as part of our Services is incorrect or if the price at which a trade is executed for you is not the best price in the market.

In the unlikely event that the market data displayed through our Services is incorrect (including, by way of example, if the market data displayed is wrong as a result of a systems error or incorrect market data received by us from our market data providers), we reserve the right to take all steps that we in our sole discretion believe are necessary or appropriate, including to cancel all affected but unexecuted Instructions that were based on that incorrect market data, and to reverse executed Instructions that were executed on the basis of incorrect market data.

We are, however, under no obligation to take such steps and you acknowledge that, even where we take such steps, we may not be successful. We will use reasonable endeavours to notify you if we intend to take, or have taken, this type of action.

You agree that neither Gratis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature and howsoever arising, for any Loss arising if the price at which your Instructions are executed is incorrect, not the same as the market data displayed on our Service or not the best available price in the market, or arising from remediation efforts we may decide to take as set out above.

Funds which we hold on your behalf and which are considered client funds in accordance with the CySEC Client Funds Policy, will be processed in accordance with these regulations and held in a separate bank account from our other funds.

Appropriate skill, care and diligence will be exercised in the selection, appointment and periodic review of any third party bank with which your funds are placed. We will not be responsible for the acts, omissions or failures of the third party bank.

Where applicable, you authorize us to permit another person such as a stock exchange, clearinghouse or intermediary broker to hold or control your client funds for the purpose of executing your Transactions on your behalf through that other person or with them.

In the event of failure on our part (eg due to insolvency), any money held in a clients' fund account by third parties will be segregated from our other assets and will not be available to our creditors. However, in the event of failure (e.g. due to insolvency) of a third party, as your client funds will be held with funds from other clients in a common bank account, in case the third party bank who holds the funds was in default and a deficit was created, you will proportionally share that deficit with other creditors of the bank where your customer funds are deposited.

We may keep your money and the money of other Clients in the same Client Bank Account (omnibus account). Where appropriate, we are able to identify your money through our internal and accounting system.

We will hold the investment on your behalf in accordance with the CySEC Client Assets Regulations.

You instruct us to arrange for any securities which you have bought on our platform to be held on your behalf until we receive further instruction from you to sell that security. This is called "custody", and means that we will be your "custodian". We will hold the securities on your behalf in accordance with the Applicable Law, or may arrange for the custody services to be provided by another company (this is called a "sub-custodian"). We are not liable for any acts, omissions, insolvency or dissolution of the sub-custodian, unless any losses which you incur have been caused by our fraud, willful default or gross negligence.

When holding such securities on your behalf, we take measures to ensure their protection and for safeguarding your ownership rights, including:

• keeping records and accounts enabling us at any time and without delay to distinguish assets held for you from assets held for any other client and from our own assets;
• maintaining our records and accounts in a way that ensures their accuracy and, in particular their correspondence to the securities held for you;
• conducting, on a regular basis, reconciliations between our internal accounts and records and those of sub-custodians; and
• taking steps to ensure that any securities deposited with a sub-custodian are identifiable separately from any of our assets or any of the sub-custodian's assets.

Detailed records of all your securities held by the custodian or sub-custodian will be kept by us at all times to show that your securities are held on your behalf, for your benefit and do not belong to the custodian or any sub-custodian.

Detailed records of all your securities held by the custodian or sub-custodian will be kept by us at all times to show that your securities are held on your behalf, for your benefit and do not belong to the custodian or any sub-custodian.

Where your securities are deposited for safekeeping with a sub-custodian, there may be instances, if this is required by the law of the country where the securities are held, that the sub-custodian may have a security interest, lien or right of set-off over your securities enabling such sub-custodian to dispose of your securities, in order to recover debts that do not relate to you or the provision of services to you.

Your securities will be pooled together with our other clients' securities (we call this an "Omnibus Account") with a third party depositary in the name of Eurotrade Investments RGB on behalf of our clients. In such case, it may not be possible to separate your securities from those of other clients.

In the event of the insolvency or any other analogous proceedings in relation to that third party, we may only have an unsecured claim against the third party on behalf of the client, and the client will be exposed to the risk that the money received by us from the third party is insufficient to satisfy the claims of the client with claims in respect of the relevant account. We do not accept any liability or responsibility for any resulting losses.

This also means that if we or our third-party nominee becomes insolvent, your securities may not be immediately identifiable by separate certificates, physical documents, or equivalent electronic entries on the register. Instead any claim will be against the Omnibus Account, and therefore more time might be needed for us to identify which securities are yours, and which belong to a different client. As additional time might be needed, this might increase your risk of losing money. In addition, if there is an unreconciled shortfall caused by the default of a custodian, you may share proportionately in that shortfall.

A person who holds Securities may from time to time be invited to cast votes in relation to the company whose Securities those are, attend meetings of those companies, subscribe for additional Securities and/or to take other actions, all on account of the fact that that person is a holder of those Securities. These are sometimes referred to as “corporate actions”. The registered holder of those Securities will be informed of these corporate actions (i.e. the Custodian in this case). You hereby:

• acknowledge and agree that we will have no duty to inform you of any corporate actions related to any Securities that are beneficially owned by you through our Services, even if we become aware thereof,
• irrevocably waive your right to exercise any corporate actions that may be exercised by the holder of the Securities that you beneficially own through our Service, and
• agree that the Custodian may in its discretion act on those corporate actions as it sees fit (which may include not to take any action at all).

To the extent that your Securities entitle the holder thereof to any proceeds (for example, dividends or interest in the form of cash) or to other benefits we will, promptly after having been informed of those proceeds or benefits, use reasonable endeavours to collect those from the relevant Custodians and

• credit your Available Funds with the amount of that dividend that pertains to your holding once we have received those proceeds in cleared funds, or
• update our records to show the increased number of Securities held by you.

We are under no obligation to initiate or defend any legal action (including class action), join any shareholder action, or take any action with respect to your Securities (other than as set out above) that will require us to incur any expense – and we are not obliged to require any Custodian to do so – in respect of Securities that you hold through our Services.

During the account opening process or subsequently, you have given your explicit consent to the loan of shares held in your account to the Gratis app.

By providing us with your explicit consent to Securities Lending, you acknowledge that you have granted the Gratis app the right to use your Lendable Securities for securities lending transactions.

When you lend the shares to us, we shall at all times act as your counterparty and are obliged to redeliver shares to you. You will not receive fees or payment for lending your shares to us.

Gratis app will then lend the lendable securities to a reputable third party. The Third party will be the counterparty (the ‘’Borrower’’) to us and as such will have the obligation to redeliver the shares which we lend to the borrower, to us. We will receive fees or payment for lending shares to the Borrower. Such fees are due to us only.

In exchange for the Lendable Securities, an appointed third party lending agent will receive collateral from the Borrower for an amount greater than that of the loaned security value. Such collateral will be held on your behalf and monitored on an ongoing basis during the time period that the securities are lent.

You will still hold a claim towards Gratis app with respect to the lent share and you would retain the legal right of redelivery against Gratis app. However, we will not hold the shares which you purchased in custody for you, as the shares will be on-lent to the borrower. Instead, collateral will be held for you.

The securities lending arrangement will not affect your ability to sell your shares to any time, in the same manner as trading any other shares in your account.

When you lend your shares to us and we lend to the borrower, you will continue to be the beneficial owner of the shares and you continue to have the market exposure inherent to beneficial ownership of the shares (I.e., if the share price decreases while you own the shares but you are lending them out, the value of your position will decrease).

You are entitled to receive the amount of all dividends and distributions made on or in respect of the loaned securities. However you may receive cash payments ‘’in lieu of’’ dividends.

Until such time as the securities lending transaction(s) are complete, the collateral will be designated as safe custody assets under the applicable part of the Cysec regulation and held by a third party manager in a segregated account on your behalf, together with collateral held on behalf of other Gratis customers whose securities are being lent. In the unlikely event that the Borrower defaults on their obligation to return the securities, Freetrade will take all reasonable measures to return to you equivalent securities.

You grant us the right to use your lendable securities to enter into securities lending transactions at our discretion. We will not notify you where we have exercised our right to use. Information setting out which of your Lendable Securities have been lent will be available via your monthly statement.

If your Lendable Securities are already on loan and you decide to sell an amount of the securities in your Freetrade Account that will mean selling the Lendable Securities, a recall process will be initiated. The recall process will involve returning your Lendable Securities to you, at which point your sell instruction will be completed. This recall process may delay the time it takes to settle your sell instruction (however this should not normally be the case).

The following special terms apply in relation to all International Securities, in addition to the other terms of this Agreement. International securities are defined as those that are listed at inernational exchanges, outside of the European Union.

Since International Securities may be denominated in a currency different from that of your base currency, we need to arrange for a foreign exchange conversion at the point in time that the Instruction to buy or sell those International Securities is executed.

We will convert Instructions for International Securities into the base currency of your account, and display the estimated converted price or number of International Securities, at the time that you are requested to confirm the Instruction. This estimated price or number of International Securities will include the estimated foreign exchange conversion rate. Upon execution of your buy or sell Instruction, we will execute a foreign exchange conversion with one of our chosen International Providers. The effective foreign exchange conversion rate will be the rate executed by our third-party provider. There will no additional deduction for a foreign exchange conversion fee.

The estimated foreign exchange conversion rate (and therefore the estimated converted price) is indicative and the actual conversion rate may vary, depending on movements in the foreign exchange markets between the time that you placed the Instruction and the time that the Instruction has been executed.

Where any additional information is required in relation to any Instruction related to International Securities, such as tax information, you agree to provide that information to us promptly when we request it, and undertake to provide accurate, complete and not misleading information. Where this information is required to be provided before an Instruction can be placed or executed, you agree to provide that information to us as a condition to us accepting the Instruction for execution.

You should be aware that transactions in relation to International Securities will be executed at such times as the relevant market dictates. These times may be different from the usual times at which transactions in relation to Securities will be processed, and may be at times that differ from the usual Cut-Off Time. As a result, there may be a difference in the price for the International Securities at the time that your Instruction has been executed and the time that you have placed your Instruction.

You agree to complete any relevant tax documentation, including but not limited to a W-8BEN form for investment in United States-listed securities, when it is made available to you through our mobile application or our website and before giving any Instruction to trade in International Securities.

You agree that neither Gratis app nor any of our group companies, directors, officers, staff, agents, suppliers or contractors will have any liability, of whatever nature and howsoever arising, for any Loss arising if the price at which an Instruction for International Securities is different at the time of execution compared to at the time that the Instruction was placed.

While we target to have our Services available without interruption, we cannot guarantee that our Services will always be accessible by you, always available, always functioning properly or error-free.

We may, from time to time, suspend our Services to perform routine or emergency maintenance or to upgrade or replace our systems. Where this is the case, we will use reasonable endeavours to notify you of any planned downtime, however we may not always be able to provide you with advance notice.

Because we do not offer a phone dealing service, if our Services are unavailable for whatever reason, or if you are unable to communicate with our Systems, this may affect your ability to trade through our Services, withdraw funds, cancel Instructions before they are executed and/or otherwise send us Instructions.

You agree that neither the Gratis app app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature and howsoever arising, for any Loss arising as a result of your inability to access our Services, whatever the reason or cause for that inability.

You are responsible for ensuring that your account cannot be accessed by third parties. We are entitled to assume that any Instruction received by us from your Account is a valid Instruction, issued by you – even if the Instruction was issued by someone who gained unauthorised access to your Account.

You must keep your login details and passwords that you use to access your Account, safe and secure and not allow any other person to know or obtain those details. If you have lost your login or password details, or you suspect your login or password details have been compromised, you should immediately inform us and change your details via the Service.

We recommend that you use appropriate, up-to-date security software and definitions to reduce the risk that your system will be susceptible to unauthorised access and intrusion.

You must install the latest version of any mobile applications that we publish from time to time. These updates often include improved security or fixes for recently discovered vulnerabilities.

You agree that neither the Gratis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature and howsoever arising, for any Loss arising as a result of your failure to keep your Account (including login and password details) secure, or from any unauthorised access to your Account as a result of malicious code (such as viruses or Trojans) or your failure to update to the latest version.

We will take reasonable steps consistent with our legal duties to protect your Account and secure it, however we are not liable for security breaches that may occur where we have complied with those obligations.

Through our Service, you will be able to instruct us to buy or sell Securities for you that are available to trade through our Service. This is only through our mobile application.

When providing us with Instructions, you will either be required to submit the cash value which you wish to buy or sell, or the number of Securities that you wish to buy or sell (which, for certain shares you may trade through our Service, may result in you buying or selling fractions of such shares).

It is your responsibility to ensure that the contents of your Instructions are accurate and complete in all respects. We do not examine or investigate the accuracy of your Instructions and you hereby agree that we may assume, at all times, that your Instructions – as received by us – are correct and reflect your requirements.

You will bear all risk of sending Instructions to us, even if they are incorrect or do not reflect your requirements. You acknowledge and agree that we may execute your Instructions exactly as we have received them, and agree that neither Gratis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature, to you or anyone else for any Loss that you may suffer as a result of us executing your Instructions as we have received them.

You should ensure that you are aware of additional fees and charges imposed by the issuer of Securities that you wish to buy, before dealing in those Securities. Examples include exchange traded funds and similar securities. Information regarding this will be made available in the relevant prospectus documents and on the websites of issuers. While Gratis app may facilitate access to this information (for example, by linking to the relevant documents from our mobile application or website), we will not be held liable for our failure to do so or the contents of the information linked to.

Key Investor Information Documents (KIID), where available for certain Securities, will be linked to from our mobile application or website and will be available for you to review prior to placing an Instruction. By providing an Instruction, you confirm that you have read the relevant KIID and agree with its contents.

An at least quarterly statement will be made available to you through our mobile application or our website, reflecting the Securities that you hold via our Services, your Available Funds and other details as we may decide from time to time.

We may collect, store and process information obtained from you or otherwise related to this Agreement and transactions for the purposes of compliance with FATCA or other applicable laws, rules and or regulations, including disclosures between yourself and to government authorities. You acknowledge that this may include transfers of information to jurisdictions that do not have strict data protection, data privacy or banking secrecy laws, inside or outside the Client. 'European Economic Area.

By accepting this Agreement, you authorize us to provide, directly or indirectly, to the competent tax authorities or any other party authorized to perform an audit, or similar control, for tax purposes, information concerning the client or in relating to this agreement and transactions, and to disclose to such tax authorities any additional information relating to your Account that we may have.

The CRS provides for an annual automatic exchange of financial account information between participating jurisdictions. Such financial institutions, including us, must submit the appropriate information to their local tax authorities who will then forward it to the relevant foreign tax authorities.

For the purposes specified above, and similarly to FATCA, we may collect, store and process information obtained from you or otherwise related to this Agreement and transactions for purposes of compliance with NCD or other applicable laws, rules and / or regulations, including disclosures between themselves and to government authorities. You acknowledge that this may include transfers of information to jurisdictions that do not have strict data protection, data privacy or banking secrecy laws, inside or outside of the 'European Economic Area.

By accepting this Agreement, you authorize us to provide, directly or indirectly, to the competent tax authorities or any other party authorized to perform an audit, or similar control, for tax purposes, information concerning you or in relating to this agreement and transactions, and to disclose to such tax authorities any additional information relating to your account that we may have.

Where we are required under applicable law to report your transactions to CySEC or any other competent authority, you must provide us with your Legal Entity Identifier (LEI) (only for businesses) or your card number, national identity or any other information we may need to determine your national Client ID, before we can place orders through our platform or our trading floor.

If you need to get in touch with us about anything, you can email us at [email protected] We will do our best to respond to enquiries as soon as we are able to, and aim is to reply within one business day, however, there may be times when it takes us longer. Our chat function is usually available at the times set out in our mobile application or our website and queries will be addressed on a “first come, first served” basis.

We do not currently offer a dedicated phone helpline.

You can make a complaint by any reasonable means – for example, letter, email, telephone or in person. It is free of charge to complain.

Complaints may be submitted in writing or by email only at the contact details provided below:

• Postal Address: 70, Kyrillou Loukareos Street, Kakos Premier Tower, 1st Floor, 4156, Limassol, Cyprus
• By email: [email protected]

Your complaint will be handled according to our internal policy. In the event that you are dissatisfied with our response you will have recourse to the Financial Ombudsman Service of Cyprus.

We may suspend or restrict your Gratis app Account and/or the execution of any Instructions before they have been executed, at any time and without notice to you, on any reasonable grounds, including:

• if we have reason to believe that you have not complied with this Agreement,
• if we are required or requested to do so by any regulator, law or other authority,
• if we have reason to believe our continued association with you would bring us into disrepute or cause us to breach any applicable law, regulation or guidance
• if we have reason to believe that your Gratis app Account has been compromised;
• if we have reason to we believe the Instruction did not originate from you or, if implemented, would contravene any applicable law, regulation or guidance; or
• if, in our reasonable opinion, we deem your use of our service to be unreasonable; for example, if you are undertaking very high frequency trading or algorithmic trading activity.

You agree that neither The Gratis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature and howsoever arising, for any Loss arising as a result of any suspension of your Gratis app Account.

We may, in our sole and absolute discretion, suspend the Services (or any part thereof) or any particular way of delivering the Services (e.g. via any mobile application or website), for so long as we decide may be appropriate and for any reason whatsoever.

You agree that neither The Gratis app nor any of our group companies, directors, staff, agents, suppliers or contractors will have any liability, of whatever nature and howsoever arising, for any Loss arising as a result of any suspension of the Services.

You agree that you will use your Gratis app Account and issue Instructions at all times in accordance with all applicable laws and regulations. You will, in particular, but without limitation, not:

• engage in any practice that is considered to be market abuse,
• use your Gratis app Account or issue any Instructions in connection with any attempt to launder money or avoid applicable sanctions against any person, company or country, or
• provide any false or otherwise misleading information in relation to your identity or personal circumstances that we request in order to provide you with a Gratis app Account.

You agree that you are not, and will not become for the duration this Agreement remains valid, a US person for the purposes of residency or tax.

We may terminate your Gratis app Account at any time and for any reason by giving you notice. Notice of termination will not affect any Instructions that have yet to be executed – we will continue to execute those Instructions in accordance with its terms and this Agreement (which may include refusal to execute any such Instructions). If your Gratis app Account has been terminated for whatever reason, then (unless we are prohibited from doing so by any applicable law or regulation), we will do the following:

• we will arrange for any Securities that you have acquired through our Services and that you still hold with us, to be liquidated (i.e. sold on the market), and you hereby irrevocably authorise us to do so,
• we will deduct all applicable fees, costs, expenses, taxes and other deductibles related to the liquidation of your Securities from your Available Funds,
• once any outstanding trades have settled, including those relating to the liquidation of your Securities, we will arrange for your Available Funds that remain to be transferred to your Nominated Bank Account.

Once your Gratis app Account has been terminated, we will not accept any further Instructions from you.

We may retain a copy of all records related to your Gratis app Account and Instructions you have sent to us, in accordance with our data retention policies and otherwise as required by any applicable law or regulation.

If you need to get in touch with us about anything, you can email us at [email protected]

We will do our best to respond to enquiries as soon as we are able to, and aim to reply within one business day, however, there may be times when it takes us longer. You can also access our chat function through our mobile application. Our chat function is usually available at the times set out in our mobile application or our website and queries will be addressed on a “first come, first served”-basis.

We do not currently offer a dedicated phone helpline.

All rights, including all intellectual property rights of whatever nature, in connection with our Services, our website, our mobile applications, information in your Gratis app Account and otherwise howsoever (including our marks, designs and logo) will be owned by us, absolutely, or by third parties who we have licensed those from. You agree to transfer and assign to us, at our request and for no payment or consideration, any rights (including intellectual property rights of whatever nature) in connection with our Services, our website, our mobile or website applications, information in your Gratis app Account and otherwise howsoever (including our marks, designs and logo) that may vest in you at any time.

We hereby grant to you a personal, non-transferable, revocable licence to use our Service, mobile application and website, for so long as you remain a client until your Gratis app Account is terminated for whatever reason. You may use these only for the purpose of using the Services and for no other purpose whatsoever.

We may, from time to time, update or make other changes to the terms and conditions of this Agreement. We will use reasonable endeavours to inform you of those changes, which may include notifying you by email. If you do not agree with those changes, you should stop using our Services and terminate your Gratis app account. We will assume you agree with changes to this Agreement if you continue to use our Services after those changes have been made.

The language of communication between you and us for the duration of this Agreement will be English, unless otherwise agreed. This Agreement may be translated into several languages. In the event of inconsistencies between the different translated versions, the English version will prevail.

By signing this Agreement, you will be required to notify us as soon as possible of any changes to the information you have provided to us.

This Agreement supersedes all prior written agreements signed between you and us regarding the provision of the Services. This does not concern the rights and obligations of both parties in accordance with the commercial conditions in connection with these services.

In the event that a court or competent authority rules that any provision of this Agreement (or any part thereof) null, illegal or unenforceable, the latter shall be deemed to be erased without this affecting the validity and enforceability of the other provisions of this Agreement.

If any provision of this Agreement is void, unenforceable or illegal but could become valid, enforceable and legal to the extent that part of this provision is deleted, the parties will reach an agreement between them to modify these provisions in a spirit of good will, so that the latter are legal, valid and enforceable and in such a way that, and to the extent possible, they continue to serve the original business intention of the parties.

Neither party will assign, transfer, bet, assign to third parties or in any way interchange any or all of their rights and obligations under this Agreement.

No delay, non-performance or omission (in whole or in part) to perform or apply its right, power, privilege, remedy or compensation created by or arising from this Agreement or the law, shall not be considered or interpreted as a denial of this or any other right, power, privilege, remedy or compensation relating to given circumstances, or could not suspend the application of this or any other right, power, privilege, remedy or compensation in any case whatsoever and to any time.

Nothing in this Agreement (or any arrangement contemplated in this document) will be deemed to constitute a partnership between you and us.

A person who is not a party to this Agreement will have no rights under or in connection with this Agreement.

The law of Cyprus governs this Agreement and both parties hereby submit the non-exclusive jurisdiction of the courts of Cyprus with respect to any dispute arising out of or relating to this Agreement.

The Client declares that he / she has read, understood and accepted this Agreement in its entirety.

The Client declares that he / she has read, understood and accepted the document entitled Risk Disclosure and that he / she has understood the warnings contained in this document.

Customer declares that the terms of this Agreement, as amended from time to time and as posted on the Company's website, take precedence over any previous, current or future statements, express or implied, made or to be made. by us and / or any of our representatives, and will be the only legally enforceable means that defines the relationship between the Client and the Company.

The Client declares that he / she consents to and accepts direct advertising using various door-to-door sales operations including, but not limited to, telephone calls, sending emails and faxes.

The Client declares that he / she is over 18 years of age and / or of full capacity (in the case of legal persons) to enter into and be bound by this Agreement and that it is not prohibited by the laws / regulations of his country of residence to enter into this Agreement.

The Client declares that all the information indicated in the "Account opening request form" are authentic, precise and not misleading and that he / she undertakes to inform the Company of any changes that may be made to the data. / information indicated in the "Account opening request form".

The Client declares that he accepts and understands that it is his sole responsibility to monitor the updates of the applicable Agreement in force as posted on the Company's website from time to time. Any visitor or user of the Company's website, whether Client or not, accepts and understands that use of the Company's website, or any form of access through this website to information displayed or to a service offered by the Company, constitutes knowledge and acceptance of the Agreement and all of its contents.

The Client declares to accept and understand that the official language of the Company is the English language.