Our Terms

This document (together with our Privacy Policy) ("Terms") details the general terms and conditions governing this relationship and sets out the rights and responsibilities we each have in this context. These Terms include important information about who we are and prescribe the way in which we will provide products or services (“Products and Services”) to you.

Our Products and Services are made available to you on a non-advised basis. This means that Plum will not provide you with any advice or make any recommendations about whether and how you should use our Products and Services. You are solely responsible for any decisions you take in this context. You must note that certain of our Products and Services involve capital at risk and the value of your investments may go down, as well as up, and you may lose all of the capital that you have invested.

You will not be able to use any of our Products and Services unless you accept these Terms. Please read them carefully and make sure that you understand them before deciding to sign up with us. We may amend these Terms from time to time. Please refer to clause 13.7. for more information. You can find the latest version of these Terms on our website https://withplum.com or you may ask for a copy at any time.

Note that these Terms are general terms and not specific to any of our Products and Services. Each of our Products and Services may be subject to additional specific terms, which you will need to agree to and which may take precedence over these Terms. Please refer to clause 1.1. of these Terms for more information.

These Terms, along with our Terms of Website Use, any applicable Premium Service Terms and any other specific terms and conditions that apply to our Products and Services, constitute a legal agreement between you and Plum Fintech CY Limited and Plum Money CY Limited, as the case may be depending on the Products and Services you receive (the latter two referred to in these Terms together or separately as "Plum", "we", "us", etc.).

A glossary of defined terms used in these Terms is set out in Annex 1.

1. Information about us

1. Depending on the products and/or services you may choose to use, your provider will be one of Plum Fintech CY Limited or Plum Money CY Limited. Plum Fintech CY Limited or Plum Money CY Limited may provide the product and/or service using Third Party Providers. This will be clearly stated in each of the specific product terms and conditions, but also reflected in the following table.

   Product / Service	Provider	Relevant terms
   Aggregation Partner(s)	TrueLayer (Ireland) Limited	Truelayer Terms
   	Tink AB	Tink AB Terms
   E-Money Provider	Modulr Finance B.V.	Modulr Finance B.V. Terms
   Stock Investing	Alpaca Securities LLC	Stock Investing Terms
   Money Market Fund ("Plum Interest")	Plum Money CY Limited	Money Market Fund ("Plum Interest") Terms

2. Plum Fintech CY Limited, is a company registered in the Republic of Cyprus under registration number HE 414801, with registered office at 21 Panteli Katelari street, Libra House, Floor 6, 1097 Nicosia, Cyprus. Plum Fintech CY Limited is registered with the Central Bank of Cyprus (“CBC”) in Cyprus and the European Banking Authority ("EBA") with national identification number 115.1.2.40 to provide account information services.Plum Fintech CY Limited is also a partner of Modulr Finance B.V., a company registered in the Netherlands with company number 81852401, which is authorised and regulated by the Dutch Central Bank (DNB) as an Electronic Money Institution (Firm Reference Number: R182870) for the issuance of electronic money and payment services. Your account and related payment services are provided by Modulr Finance B.V. Your funds will be held in one or more segregated accounts and safeguarded in line with the Financial Supervision Act.

   Plum Money CY Limited, is a company incorporated in the Republic of Cyprus, under registration number HE 414587, with registered office at 21 Panteli Katelari street, Libra House, Floor 6, 1097 Nicosia, Cyprus. Plum Money CY is an investment firm authorised and regulated by the Cyprus Securities and Exchange Commission with license number 407/21 to provide regulated activities.

3. We are not a financial adviser, and we do not provide financial, legal, tax or any other advice. We are not responsible for ensuring your Plum Wallet or your Plum Account has sufficient funds for your needs, purposes, or transactions. We do not make any representations, warranties, or guarantees of any kind that any or all of the Products and Services are suitable or appropriate for you. If you are not sure whether any of the Products or Services are suitable or appropriate for you, you should seek advice from a qualified financial, legal, tax or other adviser.

2. Plum Website and App

1. You can find a lot of information about us and our Products and Services on our website https://withplum.com (“Plum Website”).
2. We also operate a mobile application (“Plum App”) which you can download on your mobile phone. All Products and Services are delivered via the Plum App, and as such, you will not be able to access the Products and Services without having first installed the Plum App.
3. The use of the Plum Website and Plum App is governed by our Terms of Website Use which can be found on the Plum Website. Please take the time to read these carefully.

3. Our Products and Services

1. Plum will act with all due skill, diligence, and care when making the Products and Services available to you.
2. Access to the Products and Services is provided at Plum’s sole discretion. Plum may reasonably, and as permitted under applicable law, add, modify or discontinue any feature, functionality or any other tool within the Products and Services at its own discretion and without further notice to you. Where a material adverse change is made to the core functionality of the Products and Services, Plum will provide you with reasonable prior notice of such change in accordance with the relevant provisions.
3. You may use our Products and Services only for lawful purposes. You may not use our Products and Services:
   • in any way that breaches or is intended to breach any applicable local or international law, regulation or policy or causes Plum to breach any applicable law, regulation or policy;
   • in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;
   • for the purpose of harming or attempting to harm others, including minors and vulnerable persons (as such term is defined by the local legislation) in any way;
   • for anything that is abusive or incites hate, violence or does not comply with Plum’s policies;
   • in connection with any unsolicited or unauthorised advertising or promotional material or any other form of spam;
   • in connection with harmful programs like viruses or spyware or similar computer code designed to adversely affect the operation of any computer software or hardware;
   • in any way that would evade any applicable taxes, levies or duties illegally or facilitate any form of tax evasion;
   • in any way that facilitates money laundering and/or terrorist financing.
4. Account Information Management Services
   • This service will enable you to access, manage, and act on information regarding your individual personal account(s) held with your bank (“Personal Account(s)”). The service does not address any accounts held for business purposes.
   • We track and analyse information from your Personal Account(s) in order to help you better understand your income, expenses, and spending patterns. Making use of our analytics, Plum will be able to identify funds in your Personal Account(s) that may be put aside and transferred automatically to your Plum Wallet.
   • Note that Plum is not endorsed or sponsored by the providers of your Personal Account(s).
5. Plum Wallet
   • The Plum Wallet is an e-money wallet.
   • Benefiting from the data made available to you through the Account Information Management Services, and based on specific parameters (amount of funds, frequency of transfers, etc.) as set by you via the Plum App, we can assist you effect transfers of funds from your Personal Account(s) to your Plum Wallet.
   • For these purposes, and as applicable, we will set up a direct debit mandate for you with an appropriately authorised Third Party Provider. The direct debit will continue until you notify us that you wish to cancel it by contacting us. We may not be able to stop payments which are already in progress or scheduled to take place when you give notice to cancel because, for example, the notice to cancel is too close to the payment date and the relevant instructions to make those payments have already been acted on. You can also cancel a direct debit by contacting the provider of your Personal Account(s) directly.
   • We are not liable for any overdraft charges you may incur as a result of any direct debits related to your use of our Products and Services, including the Plum Wallet, unless we are negligent in cancelling your direct debit when asked to do so.
   • Note that only funds from your Personal Account(s) may be transferred to your Plum Wallet.
   • Your funds will remain in your Plum Wallet until you instruct us to transfer any or all of your funds from your Plum Wallet to your Personal Account(s) by using the "withdraw" functionality in-app. We will generally transfer the requested funds from your Plum Wallet to your Personal Account(s) within one Business Day of when we receive your request. If you do not have sufficient funds in your Plum Wallet to cover the amount of the requested transfer, your request for the transfer will be declined.
   • We may also transfer funds from your Plum Wallet to your Personal Account(s) without notice to you upon the closure of your Plum Account, and at any time if required under applicable law, or if we, in our sole discretion, reasonably suspect that the Products and Services, including the Plum Wallet, are being used for illicit purposes or otherwise in violation of these Terms.
   • Your Plum Wallet is operated and maintained by an E-Money Provider. The E-Money Provider is obliged to safeguard your money, which they will do by placing funds into a segregated account. If we cease to trade, or become insolvent, the E-Money Provider will arrange for the redemption of any funds in your Plum Wallet. If the E-Money Provider ceases to trade, or becomes insolvent, we will make claims for the redemption of your funds on your behalf. Even though your funds are segregated, you should know that your money is pooled with money belonging to other Plum users and other customers of the E-Money Provider. If the E-Money Provider is unable to redeem the funds in your Plum Wallet, your claim will not be against a specific account but against the pool in general.
   • We may create and maintain for you a Plum Wallet with more than one E-Money Provider, but we will always show your consolidated balance.
6. The Premium Services
   • The Premium Services are subject to specific additional terms and conditions (the “Premium Service Terms”) and may incur additional fees or subscription charges found in Appendix 1. The Premium Services Terms include:
     1. the Stock Investing Terms set out here;
     2. the Money Market Fund ("Plum Interest") Terms set out here; and
     3. any other service terms that we describe as “Premium Service Terms” from time to time.
   • Note that Premium Services may be provided by third parties. In these cases, provided we have exercised due skill, diligence, and care in selecting the relevant Third Party Providers, Plum is not responsible or liable for their supply (or failure to be supplied) and does not endorse or recommend any Premium Services offered by Third Party Providers. If you choose to proceed with a Premium Service offered by a third party, we will act as your agent in arranging it. When receiving a Premium Service from a Third Party Provider, in addition to the Premium Service Terms, you will also be subject to the terms and conditions of the relevant third party, over which we have no control or discretion. You should decide whether to use any Premium Services from a Third Party Provider only at your own discretion and risk. If you have any doubt about whether a certain Premium Service is provided by us or by a Third Party Provider, please ask us.
   • Premium Services may involve the transfer of funds from your Plum Wallet to facilitate move of funds in connection with the use of Premium Services or a Third Party Provider, and your ability to access your money will depend upon the relevant Premium Service Terms.
   • Funds released from closing, redeeming or withdrawing from a Premium Service will be paid back to your Plum Wallet, unless otherwise specified.
   • From time to time, we, or third parties on our behalf, may offer trials of Premium Services for a specified period (Trial Period) without payment or with payment at a reduced rate for a specified period (Discount Period). The selection of customers along with the specified period may vary based on various factors, including but not limited to, their usage history, subscription plans, engagement, or other criteria determined by us. Plum may determine at its sole discretion your eligibility for a Ttrial or Discount Period, and withdraw or modify a trial or discount at any time without prior notice and with no liability and obligation to provide any explanation or reasoning for the selection or discontinuation process, to the extent permitted under applicable law.
   • Trial and/or Discount Period may be communicated to you through various channels such as email, in-app notifications, or other means of communication and social media as deemed appropriate by us. To avail yourself of the Trial and/or Discount Period, you must follow any instructions provided in the communication received from us or in the Plum app. Failure to follow the specified instructions may result in the discontinuation of the Trial and/or Discount Period.
   • We may require you to provide your payment details to start the Trial and/or Discount Period. By providing such details you acknowledge and agree that we may automatically begin charging you for the Premium Services on the first day following the end of the Trial and/or Discount Period on a recurring monthly basis or another interval that we disclose to you in advance.
   • If you do not wish to continue receiving the Premium Service(s) you must cancel these, and the respective trial, via the App before the Trial Period lapses. Plum bears no responsibility for providing you with advanced notice of the expiry of a Trial Period and you bear sole responsibility for giving notice that you do not wish to continue to receive the Premium Services prior to the expiry of the Trial Period.
7. Plum Referral Programme
   • From time to time, you may be enrolled into a Referral Campaign under which you may be able to invite eligible persons to use our Products and Services. Provided the successful completion of the necessary steps described in each Referral Campaign, you may be eligible for a Referral Bonus.
   • An eligible person can be anyone over the age of 18, who is not an existing Plum user at the time they are invited.
   • We may suspend a Referral Campaign at any time, if we have reason to believe that it is being abused or not made in good faith. We may do this on an individual or campaign-wide basis.
   • In cases of suspected fraud and/or material abuse of the Plum Referral Programme, further action may result in the suspension of your Plum account. If the Referral Bonus has been paid to you, we have the right to recover it in such cases. If the Referral Bonus has not yet been paid to you, we have the right to not proceed with its payment in such cases.
   • Additional terms relating to the Plum Referral Programme can be found under the Plum Frequently Asked Questions (FAQ) section, which you can visit here. You must read these terms carefully to ensure that you understand your obligations under the Plum Referral Programme.
   • You must claim any Referral Bonus(es) when it’s paid to your Plum account. If you decide to close your Plum account, we may recover any unclaimed Referral Bonus(es) unless you reach out to claim it within one (1) month after the closure of your Plum account. Plum will not be liable for any loss when you fail to claim the Referral Bonus(es) in due time.

4. Using our Products and Services

1. Application
   • You must make an application (“Application”) via our App in order to use our Products and Services. You are not able to make an Application on behalf of another person.
   • By submitting your Application, you confirm that the information you have provided is accurate and complete. You acknowledge that we may require further information from you in order to consider your Application. If your Application involves a joint bank account, you acknowledge that we may require information from both named account holders. If any information provided in your Application is found to be incorrect or incomplete, we may reject your Application but will return to you any funds received.
   • If we have been unable to complete identity verification checks to our satisfaction following our receipt of your Application, we may reject your Application but will return to you any funds received.
   • We maintain full discretion to accept or reject your Application and reserve the right to do so without providing any reasons.
   • We will notify you once we have reached a decision (either positive or negative) regarding your Application, save where we are restricted from doing so by applicable law.
2. Access
   • You must make an application (“Application”) via our App in order to use our Products and Services. You are not able to make an Application on behalf of another person.
3. Eligibility
   • You must be over 18 years old to use our Products and Services and you must reside and maintain an individual bank account that is personal to you and not used for business or commercial purposes.
   • You must be a resident in an EU country or an EEA country.
4. Obligations
   • As a condition of receiving access to the Products and Services, you shall:
     1. exercise all due care, skill, and diligence in use of the Products and Services;
     2. ensure that you comply with all applicable laws and regulations in connection with its access to and use of the Products and Services;
     3. enter into and continuously comply with your obligations under all documentation required by Plum in connection with the provision of the Products and Services;
     4. provide all such documentation or information as may be reasonably required by Plum to ensure its compliance with applicable law and regulation, including, but not limited to, information to verify your identity, your financial circumstances, or other, and failure to do so may result in the termination of your Account in accordance with the provisions of these Terms;
     5. not use the Products or Services to provide products or services to any third party;
     give us consent to access your Personal Account(s) on a read-only basis in order to use our Product and Services. You must use said Personal Account(s) only for self-use or personal use, not business purposes;
     6. agree to submit only one Application to use our Products and Services and to have only one Plum Account. Any additional Plum Accounts identified, will result in termination of said Plum Accounts, in accordance with clause 13.1. of the Terms.

5. Fees

1. We reserve a right to charge a fee, in the form of subscription or other, for the Products and Services we provide to you. Any subscription fees you may have to pay to us are listed on the Plum Website, whereas all other related fees are listed on the Fees section of the Plum Website. Unless we have agreed otherwise, all fees arising in connection with the provision of the Products and Services shall be due and payable by you to us immediately.
2. If not enough money is held in your Personal Account or Plum Wallet to pay the fees or other amounts you owe us, we may recover the amount due by:
   • exercising our right of set-off; or
   • exercising our legal rights, such as instructing lawyers or debt collectors.
3. If we take any (or all) of these steps, we might charge you our reasonable costs.
4. You must pay, or reimburse, us for any taxes applicable to you, now or in the future, as a result of using the Products and Services.

6. Conflicts of Interest

1. Conflicts of Interest
   • We comply with applicable law concerning conflicts of interest and we maintain a conflicts of interest policy, a copy of which you can access here. To that end, we have put in place and comply with various organisational and administrative measures to avoid any conflicts which may negatively affect your and our interests.
   • If, in providing you with our Products and Services, there is a risk of a conflict of interest arising between you and us (including Plum’s managers, employees or persons directly or indirectly related to Plum), or between you and another client, we will clearly inform you about the general nature and/or sources of such conflicts of interest and the measures taken to mitigate such risks before providing you with any of our Products and Services.
   • Note that a separate policy in respect of avoiding and managing conflicts of interests may apply to you under the Premium Service Terms or the Third Party Provider Terms.
2. Record Keeping
• We maintain records relating to the verification of your identity and for activities carried out under this agreement in accordance with applicable law and the supervisory authorities rules/directives.
• We may record and monitor conversations and/or correspondence that we have with you. We will store recordings in accordance with applicable law and the supervisory authorities directives.
3. Appropriateness
• Before providing you with certain Products and Services, we may need to ask for information about your knowledge and experience relevant to specific financial instruments to enable us to carry out an appropriateness assessment. An appropriateness assessment is designed to ensure that you are able to understand the terms and risks involved in investing in a particular financial instrument.
4. Safeguarding your Funds
• We are not responsible for safeguarding your funds when using our Products and Services. Safeguarding obligations may apply to Third Party Providers. Please refer to the Third Party Providers Terms, as these may be applicable to you. We do not hold any client money or assets for you unless it is in relation to certain Products and Services where this has been specifically identified as such.

7. Third Party Providers

1. We may partner with Third Party Providers, including E-Money Providers, when making our Products and Services available to you. These Terms include important information about the relationship you might have with such Third Party Providers. Note that Third Party Providers may have their own terms and policies which may be applicable to you. Please also refer to our Privacy Policy for information about the processing of your personal data in this context.
2. When selecting Third Party Providers, we shall act in your best interests and in accordance with applicable laws.
3. The Third Party Providers we use in each case may differ. For instance, we may, as your agent, redeem e-money held with an E-Money Provider and distribute to you e-money of the same value issued by another appropriately authorised E-Money Provider. We may do this for regulatory reasons, to implement contingency measures in the event of business interruptions or to improve our technical capabilities and operational standards.
4. We will inform you of the identity and terms of any Third Party Providers you might use when providing you with our Products and Services. Should we decide to replace any of the Third Party Providers we have already spoken to you about, we will notify you as per the relevant provisions with the Third Party Provider, or otherwise at least ten (10) Business Days, in advance of the change being effected, unless we implement contingency plans or act to comply with applicable law, in which case we will tell you as soon as possible. If you do not consent to the replacement of a Third Party Provider, you may terminate your contract with us in accordance with clause 13.1.

8. Security Issues

1. General
   • You must not allow anyone to access our Products and Services on your behalf.
   • You must treat your security credentials, identification code, password, and any other piece of information linked to the applicable security procedures as confidential, and you must not disclose it to any third party.
   • You must notify us immediately if you have reason to believe that any of the aforementioned information, or any other information relevant to your app security have been disclosed to a third party.
   • You must use material, information, and content made available to you exclusively for the purposes of using the Products and Services. You may not copy, reproduce, distribute, or create derivative works from this content.
   • You may not reverse engineer or reverse compile any of the technology associated with us.
2. Access to your Personal Account(s):
• In order to ensure we can access information from your Personal Account(s) securely, we may work with and redirect you to one of our trusted Aggregation Partner(s). You will be asked to provide your explicit consent to enable us and our Aggregation Partner(s) to access specified information about your Personal Account(s) and your transactions on a read-only basis. To keep you safe, we will periodically ask you to renew your consent.
• You may withdraw your consent to access your Personal Account(s) at any point. If you do withdraw (or fail to renew) your consent, we may be unable to provide you with some or all of our Products and Services.
• If you have cancelled any of your Personal Account(s) or transferred a Personal Account to another bank, or where your Personal Account(s) has been restricted, disabled, suspended, or terminated by the provider of your Personal Account(s), you must inform us as soon as reasonably possible. You should be mindful that such an event may impact your ability to receive our Products and Services, but that such event will not impact your obligations under clause 5.2.
3. Your information
• For our compliance purposes, and in order to provide our Products and Services to you, you hereby authorise us to, directly or through a third-party, obtain, verify, record and, where appropriate, share information and documentation that helps us verify your identity and Personal Account(s) information. When you register to Plum, and from time to time thereafter, we may require you to provide and/or confirm information and documentation that will allow us to identify you and may include a “liveness check” (this is where your identity is verified via video-link or similar technological means using your webcam or phone camera to check your face against your photo ID). You agree to provide us from time to time with all such information and documentation about you as we may reasonably require in order to fulfil (i) our obligations under applicable laws; and/or (ii) our obligations to you under these Terms.
• Where we request information about your identity, including information relevant to third parties provided by you, we maintain such information under our record keeping requirements throughout which period these Terms are in effect in accordance with applicable law and the supervisory authorities rules/directives.
• By agreeing to these Terms, you grant us and our Aggregation Partner(s) a non-exclusive, royalty-free licence to use the information from your Personal Account(s) in connection to the Products and Services you have chosen to use or as otherwise required under these Terms. We will only have the right to use, modify, display, distribute, and create new material using or incorporating information from your Personal Account(s) to provide Products and Services to you. When retrieving information from your Personal Account(s), we are doing so only as your representative and on your behalf and not on behalf of or in the name of any third party.
• Our Aggregation Partner(s) and we may also use, sell, licence, reproduce, distribute and disclose aggregate, non-personally identifiable information that is derived through your use of the Products and Services.
• We may disclose your identity and information relating to your Personal Account(s) to third parties and authorities if we are required to do so under any applicable law or court order.
• We do not check the accuracy of the information in your Personal Account(s) or any other personal information you provide to us. We rely on you to ensure that any such information is up to date, complete, and accurate.
• By agreeing to these Terms, you represent that you are the legal owner of the data in your Personal Account(s) and that you have the authority to appoint, and do expressly appoint, our Aggregation Partner(s) as your agent and grant a limited power of attorney to access and retrieve such data on your behalf.
4. Security Incidents
• If we become aware or suspect that you are affected by fraud and/or an operational security incident, your access and use of our Products and Services may be restricted until such time that the suspected incident is resolved.
• If we believe that there is any suspected or actual fraud, or we suspect that there has been a security breach, we will contact you by email or any other secure means.
• If you believe that your account has been compromised or you do not recognise activity on your account, please contact us at help@withplum.com.
• Neither we nor our Aggregation Partner(s) can initiate any transaction on your Personal Account(s). However, if you are concerned about any activity on your Personal Account(s) please contact us.
5. Lost or Stolen Device
• If your mobile device is lost or stolen, or if you suspect someone has gained unauthorised access to your username, security credentials (e.g. PIN) or password, you must contact us immediately at help@withplum.com. In order to take any action, you will need to provide certain account information so we can verify your identity.
• You must ensure that you are the only person who accesses and uses the Products and Services via the app.
• You shall use reasonable endeavours such as using password protection on your device to prevent any unauthorised access to and use of the app and the Products and Services and, in the event that you suspect any such unauthorised access, promptly notify Plum.
• You shall be solely responsible for maintaining and keeping secure all security credentials (e.g. PIN) or passwords required to access the Products and Services. If you become aware that you have lost or misplaced your security credentials, or that the security credentials have become or may become compromised, you shall inform Plum immediately and Plum reserves the right to suspend your access to and use of the Products and Services until such time as changes are made to its security credentials.
• Until such time as you notify Plum that the security credentials have been lost or misplaced, Plum shall be entitled to rely on any instructions made via the Plum App or via email and you shall remain solely liable for any transactions entered into as a result.

9. Representations and Warranties

1. You expressly represent and warrant on a continuous basis that:
   • you are over 18 years old and have full legal capacity to enter into an agreement to use our Products and Services;
   • you are the legal and beneficial owner of any monies that are used by you in relation to any of our Products and Services;
   • any monies used by you in relation to any of our Products and Services do not constitute the proceeds of crime;
   • you are acting solely on your own behalf and not as agent for another;
   • you understand that you bear sole responsibility for all decisions made in connection with your access to and use of the Products and Services;
   • you will not use our Products and Services to engage in any activity that is fraudulent, deceptive, misleading, manipulative, abusive, or otherwise brings or causes to bring Plum into disrepute;
   • factual information heretofore or contemporaneously furnished by you to Plum, for purposes of or in connection with the Products and Services is true and accurate in all material respects;
   • you have not relied on any oral or written representation or warranty made by Plum or any other person on Plum’s behalf, other than those explicitly out in these Terms;
   • if you choose to download or otherwise obtain any information, material and other content made available by or through us or a Third Party Provider, you will do so at your own discretion and risk and you are solely responsible for any damage to your operating system or loss of data following the download of any such material;
   • if you choose to use any of our Product and Services, you will do so for domestic and private purposes only and you will not use any of the Products and Services for any commercial, business or resale purposes; and
   • you understand that we make our Products and Services available on an "as is" and "as available" basis.
2. Except as otherwise stated in these Terms, we and our Third Party Provider(s) expressly disclaim any other duties or warranties in relation to our Products and Services, as well as in relation to information, material, and other content made available by or through us or a Third Party Provider, whether express or implied, including, but not limited to the implied warranties of merchantability, fitness for a particular purpose, and non-infringement.
3. We will act reasonably to ensure that our Products and Services operate as intended. However, neither we nor our Third Party Provider(s) make any warranty that:
   • we will meet your requirements;
   • we will be uninterrupted, timely, secure, or error-free;
   • the results and data that may be obtained from the use of our Products and Services will be accurate or reliable;
   • the quality of Products and Services, or information, material and other content made available by or through us or a Third Party Provider will meet your expectations;
   • any errors in the technology will be corrected.
4. No advice or information, whether oral or written, obtained by you from or through us or our Third Party Provider(s) will create any warranty not expressly stated in these Terms.

10. Our liability

1. We will compensate you for any loss or damage you may suffer that is a foreseeable and direct result of our negligent breach of these Terms. A loss or damage is foreseeable in this context if it was contemplated by you and us at the time you agreed to these Terms.
2. Subject to applicable laws, we or any Third Party Provider(s) (provided that we have exercised due skill, diligence, and care in the appointment of such Third Party Provider(s)) are not liable or responsible to compensate you for:
   • any loss or damage you may suffer that was caused by events outside our control, including, but not limited to changes in applicable law, a major suspension or interruption of public services or electrical power and delays or other malfunctions in our communications systems (including phone and email), IT systems, or the internet;
   • any loss or damage you may suffer that was not foreseeable at the time you agreed to these Terms;
   • any loss or damage arising from a failure of Plum to perform its obligations under these Terms due to a Force Majeure Event;
   • any damage to a device or digital content belonging to you which resulted from the use of our Products and Services [and which could been have avoided if you had followed our advice and recommended technological updates in respect of the use of Products and Services];
   • any loss of profit, loss of business or goodwill, damage to reputation, business interruption, or loss of business opportunity resulting from the use of our Products or Services;
   • any loss of data which is caused by factors other than negligence or breach of statutory duty of us or our Aggregation Partner(s);
   • the acts or omissions of the providers of your Personal Account(s);
   • any statement or conduct on or via Plum Website or Plum App by any third party;
   • the cost to you of obtaining goods or services as substitutes for the Products and Services we provide;
   • any other loss or damage suffered by you in connection with the Services and Products or these Terms; or
   • any loss, damages, or lost opportunity that arises in connection with the Plum App being unavailable to you or which arises in connection with your failure to ensure that you have downloaded the latest version of the Plum App.
3. We do not in any way exclude or limit our liability for:
   • death or personal injury caused by our negligence; or
   • fraud or fraudulent misrepresentation.

11. Compensation

1. You may be entitled to compensation from the Investor Compensation Fund in respect of certain Products and Services. This depends on the type of business and the circumstances of the claim. Further information about the Investor Compensation Fund regulated by the Cyprus Securities and Exchange Commission about compensation arrangements is available here.

12. Indemnification

1. You agree to protect and fully compensate us, our affiliates and our Aggregation Partner(s) from any and all third party claims, liability, damages, expenses and costs (including, but not limited to, reasonable solicitors’ fees) caused by or arising from your use of the Services, your violation of these Terms or your infringement, or infringement by any other user of your Plum Account, of any intellectual property or other right of anyone.

13. Information about These Terms

1. Termination: These Terms will remain in force until either you or us seek their cancellation in accordance with this clause.
   1. Subject to these Terms, you can cancel your use of the Products and Services at any time by giving notice to us via email or via the Plum App.
   2. Subject to the Premium Services Terms, we can immediately cancel our provision of any of the Products and Services to you by giving notice to you via email or via the Plum App if:
      • your use of the Plum Account has been inactive for an extended period of time;
      • you commit a material breach of these Terms;
      • you commit a breach of the Terms of Website Use;
      • a Default Event occurs in relation to you.
2. Suspension: where we become aware of any circumstances, or the possibility of such circumstances, under clause 13.1.2. arising in connection with you, we may suspend your account with immediate effect and without prior notice to you whilst we conduct an investigation in relation to such circumstances. Where we suspend your Plum Account, we will notify you of that, save where we are restricted from doing so under applicable law.
3. Death: once we have received a notification that you have died, we will suspend your Plum Account as soon as reasonably practicable. The value of any funds held in your Plum Wallet or otherwise connected to your Plum Account, including any assets, may form part of your estate and, provided we receive appropriate evidence that an appropriate representative is responsible for the management of your estate, we will act on the instructions that are given by those representatives. These Terms will continue in full force and effect until such time as your Plum Account is closed, at which point these Terms will terminate. You acknowledge and agree that Plum shall not be responsible for any losses incurred on your Plum Account whilst we await instructions from your representative(s).
4. If your account is cancelled, we will subject to the completed cancellation process aim to complete transfer any funds in your Plum Account to your Personal Account as soon as reasonably possible. within two (2) Business Days. In the event you hold investments, these will be sold prior to your account being closed, as applicable your consent will be sought.
5. Interpretation: In the event of any conflict or inconsistency between these Terms, the Terms of Website Use, any applicable Premium Service Terms, and any other terms and conditions that apply to our Products and Services, the Premium Service Terms will prevail and take precedence over these Terms, which in turn shall prevail over the Terms of Website Use.
6. Language: These Terms and all information, notifications, and communication in relation to the Products and Services will be in the English language.
7. Updates and Amendments: We may from time to time update or amend these Terms, including, for the avoidance of doubt, the definitions, appendices and any arrangements made under or in connection with these Terms.
   • We can make changes to these Terms without your specific agreement. Unless required otherwise under the provisions of a Third Party Provider or applicable laws, we will make a reasonable effort to give you at least ten (10) Business Days’ notice of any changes and inform you of when these changes will become effective. If you do not agree to the changes, you can notify us and we will terminate these Terms in accordance with clause 13.1. and arrange for your account to be closed subject to any relevant Premium Service Terms. By continuing to use the Products and Services, or by failing to notify us of your objection within ten (10) Business Days after the changes to these Terms have been communicated to you, you agree to be bound by the revised Terms.
   • You can find the latest version of these Terms on the Plum Website. Any changes effected to the version of the Terms you originally agreed to, will be reflected in the latest version of the Terms available on the Plum Website.
8. Third Party Rights: To the extent we rely on third-party providers for the provision of our Products and Services, such third-party providers are to be treated as beneficiaries of the relevant provisions of these Terms with all rights to enforce such provisions as if they were a party to these Terms. Save as otherwise expressly provided for in these Terms, no other person will have any rights to enforce any of its terms.
9. Transfer of Rights: We may transfer our rights and obligations under these Terms to another legal entity. Your rights and obligations under these Terms will remain unchanged if this happens. Your consent is not required for such transfer, but we will notify you at least two (2) months before any changes are effected. You are not permitted to transfer or assign any of your rights and obligations under these Terms to any other person.

14. Data Protection

1. How we process your data: By accepting these Terms you agree that we may use your personal information, including sensitive personal information, and store it on our systems and may otherwise process it for the purposes of providing our Products and Services.
2. By accepting these Terms you agree that we may provide you with marketing materials, promotions and other information regarding any of our other Products and Services that we think may be of interest to you. If you do not wish to receive such materials, please contact us at help@withplum.com.
3. We may pass personal information relating to you to third parties appointed by us for the purpose of administration and verifying your identity, as well as for the provision of our Products and Services.
4. We may disclose your personal information if we are required to do so by law or we are requested to do so by the regulatory and supervisory authorities in the EU or the EEA, or any other relevant regulatory authority in any country.
5. Where it is necessary for the provision of our services, your personal data may be transferred to third parties outside the EU or the EEA as well as within it. You should be aware that in territories outside the EU or the EEA, laws and practises relating to the protection of personal data are likely to be different and, in some cases, may be weaker than those within the EU or the EEA. Where data is transferred outside of the EU or the EEA, Plum will take all reasonable steps to ensure that your data is protected to the most stringent degree possible and in line with industry guidance. By agreeing to these terms, you consent to such processing of your data.
6. Our full terms outlining the protection, processing and treatment of your data can be found in our Privacy Policy.
7. Questions, comments, and requests regarding our data protection policies are welcome and should be addressed to dpo@withplum.com.

15. Complaints

1. Should you have any complaint(s) in relation to the Plum app, the Products and Services, or any other aspect in regards to your experience with us, please notify us in accordance with the Complaints Policy. Your complaint will be acknowledged after receipt and arranged for the matter to be investigated in accordance with the applicable laws and regulations.
2. If your complaint relates to a service provided by Plum and not by a Third Party Provider of Plum, we will immediately carry out an investigation of your complaint in line with our Complaints Policy and will provide a written response, communicating the outcome of the investigation with you.
3. If your complaint relates to a service provided by any of our Third Party Provider(s), we will notify them of your complaint, they will investigate the complaint and we will then respond to you.
4. Complaints must be submitted to us either via email or via our help widget in our in-app. You may find more information and instructions on how to submit a complaint, visiting the Complaints section on the Plum Website.
5. If your complaint is not resolved or not settled to your satisfaction, within the specified timeline, you may refer it directly to the Financial Ombudsman of the Republic of Cyprus within a specified period of three (3) months from the date of receipt of the complaint. The complaint is submitted to the Financial Ombudsman within a specified period of four (4) months from either the date of receipt of the reply from Plum or the deadline of the three-month period during which Plum had to respond to your complaint. You can escalate your complaint to the Financial Ombudsman in one of three (3) ways: (a) by hand or by post to the address 15 Kypranoros, 1061 Nicosia or P.O. Box. 26722, 1647 Nicosia; (b) by facsimile (fax) to (+357) 22-660584 or to (+357) 22-660118; (c) by electronic mail (e-mail) to the address: complaints@financialombudsman.gov.cy. Further information about the Financial Ombudsman of the Republic of Cyprus is found on its website: http://www.financialombudsman.gov.cy/.

16. Communication

1. You may contact us and we may contact you as described in this clause.
2. When we refer, in these Terms, to "in writing", this will include email and instant messaging.
3. You can contact us in any of the following ways:
   • email us at help@withplum.com;
   • in-app via our help widget.
4. If we have to contact you or give you notice in writing, we will do so via email or through the App.
5. It is your responsibility to ensure the contact information we have for you is up to date.
6. You are required to notify us promptly if there is a change to: your legal name; your residential address; your Personal Account(s); your email address; your mobile number [if applicable]; and/or your status as an EU resident or an EEA resident. Following any of these changes, it might be necessary for us to ask you for, and for you to provide, more information as part of this process in order for you to continue accessing and using any Products and Services, if applicable.

17. Other important terms

1. Each of the paragraphs of these Terms, as applicable from time to time, operates separately. If any court or relevant authority decides that any of them are invalid, unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.
2. If we fail to insist that you perform any of your obligations under these Terms, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations. If we waive a default by you, we will only do so in writing, and that will not mean that we will automatically waive any later default by you.
3. These Terms are governed by Cyprus law. This means any dispute or claim arising out of or in connection with these Terms will be governed by Cyprus law. You and we both agree that the courts of the Republic of Cyprus will have jurisdiction to settle any dispute or claim arising out of or in connection with these Terms. However, if you are a resident in another EU country or another EEA country you may also be in a position to bring proceedings in that country if you have such a right under the law.

Annex 1 - Glossary

The following terms shall have the following meanings:

"Aggregation Partner(s)" means our Third Party Provider supplying the technology allowing us to aggregate your bank account information.

Depending on your bank, your aggregation partner is either: 1) TrueLayer (Ireland) Limited, a company registered in Ireland (company number 671615) with registered office at 25-28 North Wall Quay, Dublin 1, D01 H104, Ireland. TrueLayer (Ireland) is authorised as a payment institution by the Central Bank of Ireland ("CBI") under the European Union (Payment Services) Regulations 2018 and is listed in the CBI’s Register of Payment Institutions; or 2) Tink AB, a company registered in Sweden (company number 556898-2192) with registered office at Vasagatan 11, 111 20 Stockholm, Sweden. Tink is licensed as a payment institution and is supervised by the Swedish Financial Supervisory Authority (“FI”) under the European Union (Payment Services) Regulations 2018 and is listed in the FI’s register.

"Business Day(s)" means any day(s) except for Saturdays, Sundays and public holidays in the Republic of Cyprus.

"Default Event" means any one or more of the following events in respect to you:

1. you are the subject of, or are found guilty, or at fault in any criminal proceedings or investigation carried out by a governmental or regulatory authority in any jurisdiction;
2. you fail to pay any sum due and payable to Plum in accordance with the relevant time period for payment as prescribed within these Terms;
3. any representation or warranty made by you is or becomes untrue;
4. you are subject to a petition of bankruptcy, you make a general assignment for the benefit of, or enter into any reorganisation, arrangement or composition, with your creditors, or you state in writing that you are unable to pay your debts as they become due; or
5. any other circumstance occur or exist in respect of, in relation to or otherwise affecting it as a result of which Plum reasonably believes that it is necessary or desirable to take action under clause 13.1.2.

"E-Money Provider" means our provider of E-Money who will operate and maintain your Plum Wallet on our behalf. Plum has arrangements with one E-Money Provider:

Modulr Finance B.V., an e-money institution incorporated in the Netherlands, under registration number 81852401 and with registered address at Weteringschans 165C, 1017XD, Amsterdam, Netherlands. Modulr Finance B.V. is authorised and regulated by the De Nederlandsche Bank and its license number is R182870.

"EEA" means the European Economic Area

"EU" means the European Union consisting of the joined member states.

"Force Majeure Event" means acts of God, fire, flood, drought, earthquake or other natural disaster, epidemic or pandemic; terrorist attack, civil war, civil commotion or riots, war, threat of or preparation for war, armed conflict, imposition of sanctions, embargo, or breaking off of diplomatic relations; nuclear, chemical or biological contamination or sonic boom; any law or any action taken by a regulatory or governmental authority, including without limitation imposing an export or import restriction, quota or prohibition; collapse of buildings, fire, explosion or accident; any labour or trade dispute, strikes, industrial action or lockouts (other than in each case by the party seeking to rely on this clause, or companies in the same group as that party); non-performance by suppliers or subcontractors (other than by companies in the same group as the party seeking to rely on this clause); and interruption or failure of utility service.

"Payment Services Provider" means the party which facilitates payments (including direct debits) to be made from your bank account into your Plum Wallet. This may be one of several providers according to the type of payment, more information can be found in our Privacy Policy.

"Personal Account(s)" means the personal banking account(s) only used for self-use or personal use, that Plum accesses on a read-only basis after your consent.

"Plum Account" means the notional account which will encompass the totality of the services we will provide to you, and through which you will manage money.

"Plum Wallet" means an e-money wallet, the primary pocket in your Plum Account where funds originating from your Personal Account(s) are deposited to and withdrawn from.

"Products and Services" means the products and services made available to you by or through Plum, or through Third Party Provider(s).

"Third Party Provider" means any third party entity that we partner with and rely on for the provision of our Products and Services, including our Aggregation Partner(s), Payment Services Provider(s), E-Money Provider(s), and Premium Services Provider(s).

"Third Party Provider Terms" means terms, conditions and/or policies applicable in respect of and governing your relationship with a Third Party Provider.

"Trial Period" means the length of time that the trial will be in place for, before you are deemed to have taken up the Premium Service. If not otherwise agreed, this will be thirty (30) days and, unless cancelled, you will be charged on the first day following the end of said trial.

Terms of Website Use

These Terms of Website Use (together with any documents referred to in it) detail the terms of use under which you may make use of our website https://withplum.com and the chatbot available through our App, whether as a guest or a registered user. Website Use includes accessing, browsing, or registering to use Plum.

Please read these terms of use carefully before you start using Our Site, as these will apply to your use of Our Site.

By using Plum, you confirm that you accept these terms of use and that you agree to comply with them.

If you do not agree to these terms of use, you must not use Plum.

Other applicable terms

These terms of website use refer to the following additional terms, which also apply to your use of Our Site:

• Our Privacy Policy, sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using Our Site, you consent to such processing and you warrant that all data provided by you is accurate.
• Our Plum Terms & Conditions apply to users who sign up to use our services (“Terms”).
• The Premium Service Terms apply to users who sign up to use our premium services.
• The terms and conditions of our third party partners that may be providing services to you.
• Our Cookie Policy, sets out information about the cookies on Our Site.

Information about us

https://withplum.com is a site operated by Plum Fintech CY Limited. We are a private limited liability company registered in the Republic of Cyprus under registration number HE 414801 and have our registered office at 21 Panteli Katelari street, Libra House, Floor 6, 1097 Nicosia, Cyprus. Plum Fintech CY Limited is registered with the Central Bank of Cyprus (“CBC”) in Cyprus and the European Banking Authority ("EBA") with national identification number 115.1.2.40 to provide account information services. Plum Fintech CY Limited is a partner of Modulr Finance B.V., a company registered in the Netherlands with company number 81852401, which is authorised and regulated by the Dutch Central Bank (DNB) as an Electronic Money Institution (Firm Reference Number: R182870) for the issuance of electronic money and payment services. Your account and related payment services are provided by Modulr Finance B.V. Your funds will be held in one or more segregated accounts and safeguarded in line with the Financial Supervision Act.

Plum Money CY Limited, is a company incorporated in the Republic of Cyprus, under registration number HE 414587, with registered office at 21 Panteli Katelari street, Libra House, Floor 6, 1097 Nicosia, Cyprus. Plum Money CY is an investment firm authorised and regulated by the Cyprus Securities and Exchange Commission (CySEC) with license number 407/21 to provide regulated activities.

Changes to these terms

We may revise these terms of use at any time by amending this page.

Please check this page from time to time to take notice of any changes we made, as they are binding on you.

Changes to Our site

We may update Plum from time to time, and may change the content at any time. However, please note that any of the content on Plum may be out of date at any given time, and we are under no obligation to update it.

If we change these terms of use, we will post the revised document here with an updated effective date. If we make significant changes to these terms of use, we may also notify you by other means such as sending an email or posting a notice on our home page.

We do not guarantee that Our Site, or any content on it, will be free from errors or omissions.

Accessing Plum

Our Site is made available free of charge.

We do not guarantee that Our Site, or any content on it, will always be available or be uninterrupted. Access to Our Site is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of Plum without notice. We will not be liable to you if for any reason Our Site is unavailable at any time or for any period. We reserve the right to restrict or deny you access to all or some parts of Plum if, in our opinion, you have failed to comply with these terms of use.

You are responsible for making all arrangements necessary for you to have access to Plum.

You are also responsible for ensuring that all persons who access Our Site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.

Plum is directed to people residing in an EU country or in a EEA country. We do not represent that content available on or through Plum is appropriate or available in other locations. We may limit the availability of Our Site or any service or product described on Plum to any person or geographic area at any time. If you choose to access Plum from outside the European Union, you do so at your own risk.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in relation to Plum, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from Our Site for your personal use and you may draw the attention of others within your organisation to content posted on Our Site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of content on Our Site must always be acknowledged.

You must not use any part of the content on Our Site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of Plum in breach of these terms of use, your right to use Plum will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

No reliance on information

The content on Plum is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on Plum.

Although we make reasonable efforts to update the information on Our Site, we make no representations, warranties or guarantees, whether expressed or implied, that the content on Our Site is accurate, complete or up-to-date.

Limitation of our liability

Nothing in these terms of use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by applicable law.

To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to Our Site or any content on it, whether express or implied.

We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

• use of, or inability to use, Plum; or
• use of or reliance on any content displayed on Our Site.

As a consumer using Plum, please note that we only provide Plum for domestic and private use. You agree not to use Plum for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of Our Site or to your downloading of any content on it, or on any website linked to it.

We assume no responsibility for the content of websites linked to from Plum. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them.

Different limitations and exclusions of liability will apply to liability arising as a result of the supply of any services to you, which will be set out in the Plum Terms and Conditions.

Acceptable Communication

When using our App or Our Site, you may on occasion require assistance from members of Plum staff in connection with an issue, finding more information or any other query. In any and all communications with Plum staff, the customer must refrain from any language or actions which may be considered abusive, aggressive or harassment. Continued or repeating behaviour of this nature may result in the customer being banned from using the Plum App and cancellation of our agreement with the customer in accordance with clause 13 of the Terms and Conditions.

Viruses

We do not guarantee that Plum will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer programmes and platform in order to access Our Site. You should use your own virus protection software.

You must not misuse Our Site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to Our Site, the server on which Our Site is stored or any server, computer or database connected to Our Site. You must not attack Our Site via a denial-of-service attack or a distributed denial-of-service attack. By breaching this provision, you would commit a criminal offence. We will report any such breach to the relevant law enforcement authorities and we will cooperate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use Plum will cease immediately.

Linking to Plum

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.

You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not establish a link to Plum in any website that is not owned by you.

Plum must not be framed on any other site, nor may you create a link to any part of Our Site other than the home page.

We reserve the right to withdraw linking permission without notice.

If you wish to make any use of content on Plum other than that set out above, please contact help@withplum.com

Validity

If any part or provision of these terms of use are found to be unlawful or unenforceable, this shall not affect the validity of any other part or provision.

Third party links and resources in Our Site

Where Plum contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources.

Applicable law

As a consumer, please note that these terms of use, its subject matter and its formation, are governed by Cyprus law. You and we both agree that the courts of the Republic of Cyprus will have jurisdiction to settle any dispute or claim arising out of or in connection with these terms of use or generally the use of Our Site. However, if you are a resident in another EU country or another EEA country you may also be in a position to bring proceedings in that country if you have such a right under the law.

Contact us

To contact us, please email help@withplum.com.

Thank you for visiting Plum.

Introduction

This agreement (the Order Handling Services Terms) is between you, the client (Client, you, your) and Plum Money CY Limited , a company registered in Cyprus under company number HE 414587 and registered at Panteli Katelari, 21,Libra House, 6th Floor, 1097, Nicosia, Cyprus (Plum, we, us, our). These Order Handling Services Terms relate to the provision of certain order handling Services by Plum to you in the Securities (the Order Handling Services) via the Plum mobile application (the Plum App).

These Order Handling Services Terms act as an addendum to the Plum General Terms and Conditions that are in place between you and us. You are entering into this agreement because you wish to receive the Order Handling Services and any rights or obligation which you may have or be subject to under these Order Handling Services Terms are in addition to the rights and obligations arising under the Plum General Terms and Conditions to which you are a party. The Plum General Terms and Conditions will continue to apply to you when accessing and using the Order Handling Services. To the extent that any conflicts arise between the provisions of these Order Handling Services Terms and the Plum General Terms and Conditions in relation to the Order Handling Services, these Order Handling Services Terms will prevail.

Throughout this agreement, we use certain capitalised terms. A full list of these capitalised terms can be found in the Schedule to these Order Handling Services Terms.

These Order Handling Services Terms contain important information that you need to read carefully. Before confirming your agreement to these Order Handling Services Terms and opening a Stock Investing Account, you should carefully read our Risk Warning Notice (which can be found here) and our Order Execution Policy (which can be found here), each of which shall apply to Orders and Transactions made under these Order Handling Services. If you have any questions or doubts about any of the content in these Order Handling Services Terms, you should seek appropriate professional advice before opening your Stock Investing Account.

We may update these Order Handling Services Terms in accordance with any amendment provisions in force from time to time between you and us under the Plum General Terms and Conditions.

About us

Plum Money CY Limited is an Investment Firm, authorised and regulated by the Cyprus Securities and Exchange Commission (CySEC), under the license number 407/21 to provide regulated activities. We can be contacted at help@withplum.com.

CySEC’s contact details are as follows:
Office Address: 19 Diagorou Str. CY-1097 Nicosia, Cyprus
Telephone: +357 22506600
Postal Address: P.O BOX 24996, 1306 Nicosia, Cyprus.

Where you wish to trade Securities as part of the Order Handling Services, your Orders will be executed by the Third Party Broker, meaning you will need to open a separate account directly with the Third Party Broker which will be governed by terms and conditions of the Third Party Broker (the TPB Terms). Information on the Third Party Brokers’ regulatory status is detailed in the TPB Terms. If you do not agree to the TPB Terms, then you may not be able to submit Orders in relation to Securities. The TPB Terms are a matter between you and the Third Party Broker and we do not have any rights or obligations under such TPB Terms.

1. The Order Handling Services and our relationship

1. Plum will provide the Order Handling Services subject at all times to the provisions of these Order Handling Services Terms. These Order Handling Services Terms will govern all Orders and Transactions entered into by you under the Order Handling Services. You acknowledge that the TBP Terms may also apply to you where you wish to trade in Securities and you should read the TBP Terms carefully before agreeing to enter into such TBP Terms.
2. Access to the Order Handling Services is provided to you at Plum’s sole discretion. Plum may add, modify or discontinue any feature, functionality or any other tool within the Order Handling Services at its own discretion and without further notice to you.
3. Plum will exercise all due skill, care and diligence in the performance of the Order Handling Services and it shall owe no other duties to you other than those duties to perform the Order Handling Services in accordance with this Clause 1.3. Plum shall be responsible for the performance of the Order Handling Services as expressly set forth in these Order Handling Services Terms and shall have no implied duties or obligations whatsoever.
4. The Order Handling Services are provided in relation to the Securities only. You acknowledge and agree that Plum determines which Securities are available with respect to the Order Handling Services via the Plum App in its sole discretion and that it may add or remove Securities at any time and without prior notice to you.
5. You acknowledge and agree that you will enter into any Transactions as principal and not as agent for any undisclosed person. Unless we have agreed otherwise, you will be solely responsible for performing any obligations under these Order Handling Services Terms in connection with Transactions entered into as part of the Order Handling Services.
6. The Order Handling Services will be provided on a non-advised basis, meaning that we will not provide you with any advice as to the merits of any particular Security or Transaction or whether a particular Security or Transaction is suitable for you. We will not provide you with any investment, legal, tax or other form of advice, nor can you request any such advice from us. You are solely responsible for any decisions taken in respect of any and all Transactions that you choose to enter or not enter into.
7. We will treat you as a Retail Client in relation to the Order Handling Services unless we have informed you otherwise in writing, including following a request made by you in connection with other services provided by us that are not addressed by these Order Handling Services Terms. You may request a different client categorisation to the one we have given you and, if you do so, we will need to contact you to discuss what further information we may require and what additional requirements may apply in this context. Please be aware that we may reject any request made by you to change your client categorisation.
8. We may be required to obtain certain information from you such that we can comply with our obligations under applicable law and regulation and you agree to provide any such information that we may reasonably request in the format within which we request it. This includes, but is not limited to, any information we need to verify your identity, any information we require for purposes of reporting Transactions, and any information as to your knowledge and experience in relation to Securities that we may need to gather to assess whether or not such Securities, and the Order Handling Services generally, are appropriate for you. You may be denied access to the Order Handling Services until such time as we can obtain sufficient information from you to satisfy our obligations under applicable law and regulation.
9. Information relating to how to make a complaint in relation to the Order Handling Services and information relating to your rights to claim compensation can be found in the Plum General Terms and Conditions.
2. Stock Investing Account
1. The Plum General Terms and Conditions relating to account opening shall apply to any application made by you to open a Stock Investing Account and shall be supplemented by the provisions detailed in this Clause 2.
2. In order to receive the Fee you must ensure that you have the Plum App and that you have opened a Stock Investing Account with us. Further information relating to how to open accounts with us is provided in the Plum General Terms and Conditions and via our Website. When you open a Stock Investing Account, you will be deemed to confirm that the representations and warranties contained in the Plum General Terms and Conditions are true and accurate, and each time you submit an Order you will be deemed to confirm that such representations and warranties remain true and accurate. It is a condition of opening a Stock Investing Account that you agree to these Order Handling Services Terms and that you agree to comply with your obligations under these Order Handling Services Terms.
3. When opening your Stock Investing Account, we may utilise the services of third-party service providers to verify your identity and you agree that we may share your personal data with such providers for this specific purpose.
4. You acknowledge and agree that Plum retains sole discretion as to whether to accept any request made by you to open a Stock Investing Account and just because you currently receive other services from Plum does not guarantee that you will be able to open a Stock Investing Account with us.
5. Stock Investing Account.
6. Unless you have notified us of a lost or stolen device in accordance with the provisions in the Plum General Terms and Conditions, we are entitled to treat any Orders made via the Plum App as legitimate and rely on those Orders and you shall remain solely liable for any Orders and any Transactions that arise as a result.
3. Orders and Transactions
1. In order to enter into a Transaction, you must submit an Order to us in accordance with this Clause 3 of these Order Handling Services Terms.
2. An Order may only be made via the Plum App by completing the relevant information required to create such Order. Any Order is binding on you and you bear sole responsibility for any obligations arising out of or in connection with any Orders or Transactions. We retain sole discretion as to whether to accept or otherwise transmit any Order. Our acceptance of your Order will be evidenced through a confirmation in the Plum App. Where your Order relates to Securities, the Third Party Broker shall retain sole discretion as to whether to execute that Order. Under normal market conditions a market order would generally be fully executed. Partial order execution may occur in the event there are not enough Securities to fill your order or due to unexpected technical reasons in which case the unexecuted part of your order will be cancelled. You acknowledge and agree that we are reliant on various third-parties to facilitate the execution of your Orders and we cannot, therefore, guarantee that your Orders will be executed, nor can we guarantee that there will not be a delay in the execution of your Order. The price of any Security to which your Order relates may move between our acceptance of the Order and its ultimate execution and you acknowledge that such price movements may work in your favour or against you. Where we do not accept your Order, we will use reasonable endeavours to provide you with a reason why, save where the provision of such information to you would be prohibited by applicable law or regulation.
3. We reserve the right to cancel an Order previously accepted where we reasonably believe that:
   • (a) the Order was not made in accordance with these Order Handling Services Terms;
   • (b) the Order breaches or may reasonably breach a Risk Control;
   • (c) you no longer have sufficient funds in your Plum Wallet to cover any financial obligations that may arise in connection with the Order;
   • (d) we reasonably believe that the Order has not originated from you;
   • (e) the Order is suspicious in nature and we wish to clarify it with you;
   • (f) we may be in breach of these Order Handling Services Terms or applicable law or regulation if we continue to accept the Order; or
   • (g) any other circumstances arise following acceptance of the Order but prior to it becoming a Transaction that mean it is no longer reasonable or possible for us to act on the Order, including, but not limited to:
   • (i) the Order is suspicious in nature and we wish to clarify it with you;
   • (ii) a Force Majeure Event has occurred;
   • (iii) the relevant issuer of the Security becomes subject to an Insolvency Event;
   • (iv) trading in the relevant Security has been suspended by any relevant underlying market or exchange;
   • (v) we or the Third Party Broker no longer supports the Security to which the Order relates; or
   • (vi) we are required by any underlying market or exchange or by the Third Party Broker to cancel the Order.
4. Save where prohibited under applicable law or regulation, we will use reasonable endeavours to provide you with a reason as to why we have cancelled any Order submitted by you.
5. We will determine in our sole discretion what Orders are made available. At present, the only form of Order that can be made is a Market Order. We may notify you from time to time of any changes to the types of Orders that are available. Orders can only be made in relation to Securities and we will not facilitate any Orders that do not relate to Securities.
6. We determine, in our sole discretion, what Securities are made available via the Plum App and we may change such Securities at any time without notice to you. If we no longer wish to support a Security in which you have a Position, you may be required to close that Position and, in such circumstances, we will provide you with advance notice in writing of the relevant date by which you must close that Position. If you have not closed that Position by the relevant date specified in such notice, we will close that Position at the prevailing market price of that particular Security.
7. By default, all Orders will be treated as Manual Orders unless you have indicated that you wish for that Order to be an Automated Order.. Any Automated Orders will be executed on the predefined date selected for the transfer of relevant funds to the Stock Investing Account.
8. As may be applicable, where you submit an Order outside Trading Hours, that Order will be held until the commencement of the next period of Trading Hours and subsequently actioned during that period. In such circumstances, you may not be notified of the relevant price of any Securities to which that Order relates until that Order becomes a Transaction. The minimum value for Automated Orders is GBP 1.00. If the value available in the Plum Wallet to facilitate an Automated Order is less than this amount, then the Automated Order will not be created.We will notify you via the Plum App in the event that any of your Automated Orders cannot be created due to insufficient funds.
9. When your close a Position by submitting an Order to sell a Security, the Third Party Broker will credit any proceeds from that Transaction to your Stock Investing Account minus any fees or charges due and payable to us, but we will place a restriction on your ability to withdraw those funds from your Stock Investing Account until such time as the Transaction settles.
10. When you submit an Order to buy a Security we may agree to lend you the money to fund your buy Order by using an equal amount of funds from an executed sell Order(s) pending settlement. At any time, you will not be able to borrow money that exceeds the funds from executed but not yet settled sell Order(s). The availability payment of the arrangements set out in this Clause 3.10 is determined in ouris at our sole discretion and we may choose to refuse to offer this payment model at any time and for any reason (which we will not have to explain to you), but we will notify you if this payment model is not available to you. You acknowledge and agree that if you borrow funds from us under this Clause 3.10 you will owe us a debt equal to the value of the funds borrowed and you will repay this amount to us as soon as any executed sell Order(s) settles and you agree that we may deduct the value of any borrowed funds from the proceeds of your settled sell Order(s) when we credit such proceeds to your Plum Wallet.
11. We will not aggregate your Orders will those received from our other clients However, the Third Party Broker may, when it considers it necessary and in their customers’ best interests, aggregate (i.e. combine together) multiple orders. In certain circumstances, the aggregation of Orders may result in you obtaining a less favourable price on resulting Transactions. Because your investment may be bought or sold alongside the shares of other customers, the price obtained may not be the same as if it had been an individual order. You acknowledge and agree that we shall not have any liability to you as a result of you obtaining a less favourable price because of the aggregation of Orders by the Third Party Broker.
12. We will take all sufficient steps to provide you with best execution in relation to Orders and such Orders will be handled and executed in accordance with our Order Execution Policy. For Orders relating to Securities, you acknowledge that the Third Party Broker may not be subject to best execution requirements in the same manner as we are and it shall execute Orders in Securities in accordance with its obligations of the applicable law and regulation of the jurisdiction in which it is established.
13. By agreeing to these Order Handling Services Terms, you expressly agree that we may execute your Orders outside a regulated market or multilateral trading facility.
14. We shall have no liability to you for the actions or omissions of the Third Party Broker in relation to any Orders, Transactions or Positions relating to Securities.
4. Risk Controls and Limits
1. You acknowledge and agree that any Orders or Transactions submitted under or created by the use of the Order Handling Service may be subject to risk limits, risk tolerances and credit limits imposed by Plum from time to time (the Risk Controls). The Risk Controls may be general or specific to you, may apply to all Securities or only certain Securities, and at all times are imposed, amended, maintained or removed at the sole discretion of Plum without prior notice to you.
2. Plum may reject, cancel or amend any Order that, in its sole discretion, breaches or may breach a Risk Control. Plum shall have no liability to you for any losses or damages incurred by you in connection with any Orders which are rejected, cancelled or amended by us in circumstances where such Orders breach or are reasonably likely to breach a Risk Control.
3. You acknowledge that the Third Party Broker may impose its own risk limits and controls with respect to Orders and Transactions in relation to Securities and that Plum has no control or influence over any such limits and controls.
5. Your Obligations
1. As a condition of receiving the Order Handling Services, you shall:
   • (a) exercise all due care, skill and diligence in your use of the Order Handling Services;
   • (b) ensure that your comply with all applicable law and regulation in connection with your access to and use of the Order Handling Services and in particular, but without limitation, not: (i) engage in any practice that is considered to be market abuse, (ii) use your Stock Investing Account or act with any attempt to launder money or avoid applicable sanctions against any person, company or country, or (iii) 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 Stock Investing Account;
   • (c) not use any automated trading arrangements, algorithms or other software in connection with your access to and use of the Order Handling Services;
   • (d) provide all such documentation or information as may be reasonably required by Plum to ensure its compliance with applicable law and regulation;
   • (e) ensure that you regularly access the Plum App to monitor your Positions;
   • (f) inform Plum immediately if you become subject to any investigation, proceedings or actions undertaken by any regulatory or governmental authority;
   • (f) inform Plum immediately if you become a Sanctioned Person or if you are or become located, organised or resident in, or begin to conduct business in or with, any country or territory with which Order Handling Services are broadly restricted or prohibited by Sanctions; and
   • (f) not use the Order Handling Services to provide services or activities to your own clients, counterparties or customers.
6. Your Money
1. Plum will not hold any money from or for you. Any money received in connection with our provision of the Order Handling Services is held by PayrNet Limited (PayrNet). PayrNet will be responsible for safeguarding your money in accordance with applicable law of the jurisdiction in which PayrNet is established and the relevant terms and conditions agreed between you and PayrNet.
2. We will not be liable to you for the acts, omissions or insolvency of PayrNet or any third party banking institution which holds your money in accordance with this Clause 6, provided that we have exercised due skill, care and diligence in the selection of PayrNet.
7. Your Positions
1. Plum does not hold any Securities in connection to the Order Handling Services on your behalf. Securities are held by the Third Party Broker in accordance with applicable law of the jurisdiction in which the Third Party Broker is established and the TPB Terms agreed between and Third Party Broker. We will not be liable to you for the acts, omissions or insolvency of the Third Party Broker or any sub-custodian appointed in accordance with this Clause 7, provided that we have exercised due skill, care and diligence in the selection of such Third Party Broker.
8. Fees and Taxes
1. You have sole responsibility for making any payments that are due and payable under these Order Handling Services Terms. When you submit an Order to buy a Security, the amount you are required to pay in connection with that Order will become due and payable once that Order becomes a Transaction. It is your responsibility to ensure that there are sufficient funds on your Stock Investing Account to cover the value of your Transactions, including the payment of any fees due and payable to us in connection with those Transactions. The amount of fees that are due and payable to us in connection with Transactions are detailed on the Plum App and the Plum Website. You should familiarise yourself with such information before submitting any Orders.
2. You acknowledge and agree that the Third Party Broker may charge you additional fees in relation to Transactions in Securities and that Plum has no control or influence over such fees or the terms governing the payment of such fees. You have a direct obligation to the Third Party Broker to pay such fees in accordance with the requirements imposed by the Third Party Broker under the TPB Terms.
3. All amounts due and payable under these Order Handling Services shall be made in the Base Currency. Where a particular Transaction relates to a Security denominated in a currency other than the Base Currency, we will perform a currency conversion at the relevant prevailing exchange rate so as to facilitate the settlement of that Transaction. Similarly, where proceeds of any Transaction are in a currency other than the Base Currency, we will convert these proceeds into the Base Currency for the purposes of crediting such proceeds to your Stock Investing Account. You acknowledge and agree that, where you enter into Transactions relating to Securities which are not denominated in the Base Currency, you are exposing yourself to currency risk and you acknowledge and agree that it is your sole responsibility to manage this risk and that we are not liable to you for any losses arising in connection with such risk.
4. We reserve the right to deduct any monies from your Stock Investing Account to satisfy your obligation to pay us any amount under these Order Handling Services Terms.
5. If at any time in relation to the Order Handling Services we owe you and you owe us the same amount of money in the same currency, then each of our respective obligations to pay such monies to the other will be automatically satisfied and discharged. In the event that each of us owes one another different amounts of money in the same currency, then whichever of us owes more may pay the excess to the other and each of our respective obligations to pay such monies to the other will be satisfied and discharged.
6. Plum may, at any time and without prior notice to you, set off any liability of yours to us under these Order Handling Services Terms against any liability of ours to you under these Order Handling Services Terms, whether either liability is present or future, liquidated or unliquidated. If the liabilities to be set off are expressed in different currencies, we may convert either liability at a market rate of exchange for the purpose of set off.
7. You have sole responsibility for determining whether and to what extent any taxes or tax reporting obligations may apply in connection with your Transactions and your Positions. Plum shall have no responsibility for facilitating or otherwise making any payments of tax for or on your behalf and we provide no warranty or representation as to your tax position or the tax treatment of any Transactions. You must inform us of any changes to your tax status during the duration of these Order Handling Services Terms.
8. Where you wish to deal in Securities, you may be required, either by us or the Third Party Broker, to complete certain US tax documentation prior to submitting any Orders in relation to Securities.
9. Market Data
1. Plum may make available to you certain market data or other information in relation to the Securities (the Market Data). Any decision to make available Market Data is made in Plum’s sole discretion. The relevant Market Data is provided by a third-party unaffiliated to Plum called IEX Cloud Services LLC. Further information on IEX Cloud Services LLC can be found here: https://iexcloud.io.
2. The provision of Market Data does not form part of the Order Handling Services and Plum does not accept any responsibility for its accuracy or completeness, nor do we owe any obligations to you under these Order Handling Services Terms with respect to the provision of that Market Data.
3. You acknowledge and agree that you do not acquire any intellectual property rights in the Market Data and that IEX Cloud Services LLC retains all such intellectual property rights.
4. You will indemnify and hold Plum its affiliates and subsidiaries harmless against all Losses and all other reasonable professional costs and expenses suffered or incurred by Plum arising out of or in connection with any use of the Market Data which:
   • (a) involves use of the Market Data otherwise than in connection with the receipt of the Order Handling Services by you;
   • (b) violates, or encourages the violation of, the legal rights of others;
   • (c) results in the conducting, promotion or encouragement of illegal activity; or
   • (d) is unlawful, invasive, infringing, defamatory or fraudulent.
10. Corporate Actions
1. Unless otherwise agreed between you and us, any dividends or other cash distributions that are paid on Securities held by us on your behalf will be credited to the Stock Investing Account less any applicable withholding tax. The Currency Conversion Fee will be applied on dividends or other relevant cash distributions. We will not be responsible for claiming back any withholding tax on your behalf and, as per Clause 8.7, you have sole responsibility for addressing any tax obligations that arise in connection with Transactions.
2. We may, are not required to, inform you of any ordinary or extraordinary general meeting of any issuer of a Security you hold in your Positions. We may, but are not obliged to arrange for you to receive any information that receive in relation to an issuer of a Security.
3. We may, but are not required to, inform you or otherwise arrange for the exercise of any voting rights that relate to any Securities that we hold on your behalf.
4. If we are holding Securities on your behalf for which there is a rights issue, we will use reasonable endeavours to notify you of such an event. On notification, you can take up the option to receive the rights and have the opportunity to subscribe for new stocks, ignore the rights or sell the rights, if possible. In order to prevent renounceable rights from becoming worthless when they expire, if you have not provided us with any instructions by any deadlines specified by us to you, we may, but are not required to, sell the rights (if possible) on your behalf before the expiry of the rights. The proceeds from the sale of the rights will then be credited to your Stock Investing Account net of any applicable fees or charges.
5. We are not required to notify you of any class actions or group litigation that are underway or proposed in relation to any Securities that we are holding, or have previously held, on your behalf which are notified to us from time to time, nor are we required to act on any such notifications.
11. Termination
1. You or we may terminate your Stock Investing Account at any time and for any reason by you giving us notice, or we giving you notice. Notice of termination will not affect any responsibility for any obligations arising out of or in connection with these Order Handling Terms, including any Orders that have yet to be executed – we will continue to execute those in accordance with these Order Handling Services Terms (which may include refusal to execute Orders).

"Automated Order" means an Order the parameters of which are pre-determined and which is automated submitted to us on a set date.

"Base Currency" means the currency listed as the currency of your Plum Wallet.

"Currency Conversion Fee" means the Fee applied when converting from the Base Currency into another supporting currency or vice versa, the value of which will be listed on the Plum Website from time to time.

"Stock Investing Account" means the account opened by you with Third Party Broker for purposes of your access to and use of the Order Handling Services.

"Order Handling Services" has the meaning given in the Introduction.

"Order Handling Terms" has the meaning given in the Introduction.

"Eligible Counterparty" has the meaning given in the CySEC Rules

"CySEC"has the meaning given in the About Us section.

"CySEC Rules" means the rules of the CySEC as documented in CySEC’s rules from time to time

"Fees" means any fees, commissions or similarly payable to us under the Order Handling Services Terms in respect of the Order Handling Services, as these are listed on the Plum Website from time to time.

"Force Majeure Event" means acts of God, fire, flood, drought, earthquake or other natural disaster, epidemic or pandemic; terrorist attack, civil war, civil commotion or riots, war, threat of or preparation for war, armed conflict, imposition of Sanctions, embargo, or breaking off of diplomatic relations; nuclear, chemical or biological contamination or sonic boom; any law or any action taken by a regulatory or governmental authority, including without limitation imposing an export or import restriction, quota or prohibition; collapse of buildings, fire, explosion or accident; any labour or trade dispute, strikes, industrial action or lockouts (other than in each case by the party seeking to rely on this clause, or companies in the same group as that party); non-performance by suppliers or subcontractors (other than by companies in the same group as the party seeking to rely on this clause); and interruption or failure of utility service.

"Losses" means any liabilities, costs, expenses, damages and losses (including, but not limited to, any direct, indirect or consequential losses, loss of profits, goodwill, reputation, loss of business opportunity or anticipated savings, and all interest, penalties and legal costs (calculated on a full indemnity basis)).

"Market Data" has the meaning given in Clause 9.1.

"Manual Order" means an Order where you determine the relevant parameters via the Plum App.

"Market Order" means an instruction to us seeking the creation of a Transaction immediately at the best available price in relation to the Security in question.

"Order" means any instruction given by you to us under the Plum App in relation to a Security and includes a Market Order, a Manual Order and an Automated Order.

"Plum App" has the meaning given in the Introduction.

"Plum Wallet" means the electronic money wallet held with the E-Money Provider.

"Positions" means the Securities that the Third Party Broker hold on your behalf following the conclusion of a Transaction.

"Professional Client" has the meaning given in the CySEC Rules.

"Retail Client" has the meaning given in the CySEC Rules.

"Risk Control" has the meaning given under Clause 4.1.

"Sanctioned Person" The target of any Sanctions or located, organised or resident in a country or territory with which Order Handling Services are broadly restricted or prohibited by any Sanctions.

"Sanctions" any economic, financial or trade sanctions or embargoes, export controls or other restrictive measures imposed by the United States of America (including those administered by the United States Department of the Treasury’s Office of Foreign Assets Control), the European Union, any member state of the European Union, the United Kingdom (including those administered by HM Treasury) or the United Nations.

"Sanctioned Person" The target of any Sanctions or located, organised or resident in a country or territory with which Order Handling Services are broadly restricted or prohibited by any Sanctions.

"Securities" means the financial instruments made available via the Plum App which are capable of being subject to Orders.

"Third Party Broker" means Alpaca Securities LLC.

"TPB Terms" has the meaning given in the About Us section.

"Trading Hours" means regular trading hours for the stock markets as listed on the Plum Website from time to time.

"Transaction" means a transaction that arises following the execution of an Order.

"Website" means https://withplum.com/fr-FR/.

Introduction

Plum is committed to treating customers honestly, transparently and in the best interest of our customers.

This Order Handling and Best Interest Policy (“Policy”) provides information to customers of Plum (references to "Plum", "us", "our" and/or "we" means Plum Money CY Limited) on when, where and how we will treat your orders when received and transmitted for execution.

Purpose

The purpose of this Policy is to set out Plum’s approach to meeting our customer best interest and order handling obligations by setting the methods by which we take all sufficient steps to obtain the best possible results when acting on their behalf.

This Policy sets out our execution model and our overarching approach to overseeing execution, including the execution factors considered. In addition, the Policy sets out the key risks to best execution and the governance relevant to the monitoring and oversight of this Policy.

Our Execution Model

1. US Stocks

Through the Plum App, Plum offers its customers execution access to US stocks listed on the New York Stock Exchange (“NYSE”) and the Nasdaq Stock Market (“NASDAQ”). Plum receives the order from the customer through the Plum App and transmits the order to our third-party broker for execution.

Plum utilises a third-party broker, Alpaca Securities LLC (“Alpaca”), a US broker dealer registered with the Securities and Exchange Commission (“SEC”), and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (”SIPC”). Alpaca has relationships with multiple third party brokers that it can access for the purpose of directing orders in securities to particular market centres for execution and as such has the capacity to achieve best execution.

Under no circumstances will we act in any other capacity and a transaction will arise between you and Alpaca.

Details on how the Alpaca executes its orders can be obtained in the Alpaca Customer Agreement , https://files.alpaca.markets/disclosures/library/AcctAppMarginAndCustAgmt.pdf.

2. Money Market Fund (MMF)

Through the Plum App, Plum offers its customers execution access to Money Market Fund (MMF) which is the BlackRock ICS Euro Government Liquidity Fund issued by BlackRock (Netherlands) B.V. which is authorised and regulated by the Netherlands Authority for the Financial Markets (trade register no. 17068311 and license no. 12014230).

Plum receives the order from the customer through the Plum App and transmits the order to the MMF Manager for execution. The MMF Manager is BlackRock (Luxembourg) S.A. which is responsible for the day-to-day management of the MMF, either directly or by way of delegation.

Details of the MMF Managers and the executing broker’s Execution and Order Placement Policy is available here.

Order Execution

We will not execute any orders (either stock or MMF) that you submit via the Plum App, but rather will transmit orders for stocks to our third party broker Alpaca for execution or onward transmission by Alpaca to market centres or other third party brokers, or for MMFs to the MMF Manager BlackRock.

Whilst we are not ultimately responsible for execution of orders, we do have an obligation to take all sufficient steps to obtain the best result for our customers in transmitting orders to our third party broker.

Our primary obligation is to ensure that our customers’ orders are received and transmitted to Alpaca and/or the MMF Manager promptly and fairly. Unless instructed otherwise by the customer or where prevailing market conditions prevent us from doing so, all orders will be transmitted to Alpaca and/or the MMF Manager sequentially and promptly in accordance with our order handling process.

Plum cannot guarantee that the best execution is achieved for each and every trade. Plum’s best execution approach is focused on achieving the best possible results on a consistent basis, and not merely best execution for an individual order.

Orders for execution in US-listed securities on NYSE or NASDAQ are transmitted to Alpaca. Orders for full shares of a security will be executed by Alpaca, as agent, through any of their third party execution brokers or venues they interact with. Orders for fractions of a security will be executed by Alpaca, as principal. Where your order includes both a whole share and fraction of a share, it will be executed in a mixed capacity by Alpaca. Alpaca has a system in place with regards to its fractional shares and listed securities arrangements that aims to ensure that its customers obtain best execution and/or benefits from price improvements.

In all cases, Alpaca commits to execute at the National Best Bid or Offer (“NBBO”) as of the time of your order, for all whole share and fractional share components of a transaction, in line with its best execution objective.

Orders for execution in MMF will take place directly with the MMF Manager.

Under normal market conditions you should expect a market order to be fully executed. Partial order execution may occur in the event there are not enough shares to fill your order or due to unexpected technical reasons in which case the unexecuted part of your stock order will be cancelled.

For stock orders we do not aggregate a customer’s orders with those of any other customers. Although, Alpaca may, when it considers it necessary and in our customers’ best interests, aggregate (i.e. combine together) multiple orders. You should be aware that aggregating orders in this way may be to your disadvantage. Because your investment may be bought or sold alongside the shares of other customers, the price obtained may not be the same as if it had been an individual order.

For MMF orders we will be routinely aggregating all client buy orders and all client sell orders, respectively for submission before the cut-off time. The orders to the MMF Manager will be submitted in Plum’s name.

We will carry out transmission of orders as promptly as possible, or as otherwise set out in the relevant terms and conditions, unless the characteristics of the order or prevailing market conditions make this impracticable. In accordance with our processes we will inform customers about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.

Plum has various arrangements in place to review, monitor and oversee the standards of execution received by Alpaca or the MMF Manager and their counterparties.

Taking “Sufficient Steps”

In seeking the best possible result for the customers, Plum applies an order handling process that is structured around order initiation, order decision, execution to final settlement.

Plum takes all sufficient steps to achieve the best possible results for its customer by verifying that Plum’s order handling arrangements work well throughout the different stages of the order routing and execution by its selected third party broker and MMF Manager.

Taking all sufficient steps” includes order execution arrangements to ensure intended outcomes can be successfully achieved on an ongoing basis. It includes taking sufficient steps in overseeing that the third-party broker and MMF Manager that Plum uses for onward routing has the necessary arrangements in place to allow Plum to comply with its Policy, taking into account the execution criteria and execution factors.

Plum has identified a three step process for designing and maintaining an infrastructure design to achieve best execution for its customers.

Design: The design process is an ongoing process involving the continual review of execution arrangements made by Plum to deliver the best possible outcome for its customers and making enhancing arrangements as necessary. Matters relating to the design process are discussed within Plum’s governance arrangements relevant to best execution.

Implementation: The approved execution arrangements are implemented using routing technology and execution partnerships with third-party brokers, MMF managers and direct execution venue connection, as may be relevant. The execution arrangements are then subject to an ongoing review process which is done by ongoing monitoring of execution performance.

Updating: Any issues arising from the ongoing review process and/or monitoring of market structure developments are escalated, discussed and reviewed within Plum’s governance arrangements relevant to best execution.

Our Consideration For Execution Quality

Best execution is the duty that Plum owes the customer to take all sufficient steps to obtain the best possible result when receiving and transmitting orders for execution on the customer's behalf. In doing this we take into consideration the following execution factors:

• price
• costs
• speed
• likelihood of execution and settlement
• size of the order
• nature of the order
• any other consideration relevant to the execution of the order when executing an order on behalf of the customer.

The execution factors are considered in light of the execution criteria by assessing their relative weighting in light of elements that could influence the outcome of the execution and therefore the outcome for the customer.

In determining importance given to execution factors Plum will take into account relevant execution criteria and market conditions including (but not limited to):

• characteristics of the order (order type);
• liquidity in the relevant stock
• size of customer order;
• the time needed for completing the execution;
• availability for price improvement; and
• Plums’s fee model and the potential impact on total consideration.

In assessing the execution factors and the weighting of the criteria it is considered that in most instances priority should be given to the execution factor ‘price’ and ‘cost’. In certain circumstances Plum may determine that the speed and likelihood of execution may take precedence over immediate price and cost factors if these other factors are instrumental in delivering the best possible result. This may be the case for example for large customer orders in illiquid shares.

Customer fees and commissions are pre-agreed as per Plum’s fee model. As such, customers are not directly exposed to additional costs during the order handling and execution process. Both ex-ante and ex-post costs are made available to customers, and incidental costs and charges to customers such as implicit transaction costs are made available to customers in confirms and statements, including incidental costs and charges to customers such as implicit transaction.

Monitoring and Oversight

Plum monitors on a regular basis the effectiveness and application of this Policy.

The monitoring of executions and oversight is focused on an overall assessment to determine if the best result was achieved in accordance with this Policy.

Plum will correct any deficiencies identified as part of its monitoring. Plum evaluates the trading execution quality obtained on a periodic ex-ante basis and considers alternative methods designed to improve the execution process.

Generally, Plum's monitoring process will focus on the outcomes that have been achieved for customers and whether these are overall consistently giving customers the best outcome they could have had, given the relevant assessment criteria.

In order to analyse and draw conclusions from monitoring of quality of execution obtained by Alpaca and the MMF Manager, Plum’s monitoring is focused on the overall execution process as well as including identifying executions where trade is executed outside the best bit or offer at the time of the trade or where delays have occurred during the execution process.

The review occurs within Plum's governance arrangements relevant to best execution and includes an overall assessment of whether the execution policies and the arrangements include all sufficient steps that Plum could be taking to achieve best execution of customers' orders.

Consent

Once we have transmitted your orders to Alpaca and/or the MMF Manager, we cannot control when and how the Alpaca and/or the MMF Manager will execute your orders. By opening a Stock Investing Account and/or a Plum MMF Investment Account you are deemed to consent to our Order Handling and Best Interests Policy.

1. These Recurring Buy Transactions Terms & Conditions, along with our General Terms & Conditions, Stock Investing Terms & Conditions and any other documents we provide in relation to our services form a legal agreement between you and Plum.

2. These Recurring Buy Transactions Terms & Conditions will remain in effect after the initial Recurring Buy Transaction is executed in full and until you cancel your Recurring Buy Transaction using app settings in your Plum Stock Investing Account.

3. You can easily cancel any scheduled buy orders by tapping the Recurring Buy Order card on the instrument selection screen. This will open up the Order Details Screen. Here you can tap the red button that says “Cancel”.

4. By setting up a Recurring Buy Transaction, you authorise us to automatically create a Buy Order for you under the Stock Investing Terms & Conditions without any other consultation, consent or approval.

5. You can set up a Recurring Buy Transaction to purchase the company stocks you select, at regular intervals in the future, for the market price at the time your order is executed. Once you click “Confirm”, you authorise your Recurring Buy Transaction to repeat indefinitely and as such it’s important that you regularly review your recurring orders. Plum is not obliged to verify the information and details of the Recurring Buy Transactions provided by you, which shall be assumed accurate and complete.

6. Plum is not responsible for any losses incurred by you as a result of unauthorised, incorrect or failed transactions due to incomplete or outdated information (including having insufficient funds in your Plum Wallet to complete the transaction).

7. It is your responsibility to maintain an adequate balance and/or sufficient credit limits in order to avoid overdraft, non-sufficient funds, or fees charged by Plum.

8. Plum is not responsible for the delay caused (if any) in executing the Recurring Buy Transactions for any reason and/or for any merchant-initiated transactions.

9. Plum is unable to provide any guarantee relating to the performance of particular investments or strategy connected with Recurring Buy Transactions.

10. Plum reserves the right to refuse to process, cancel, terminate or reverse any Recurring Buy Transactions at its sole discretion and without any prior notice, even after funds have been debited from your Plum Wallet.

11. For the use of the Recurring Buy Transactions feature, Plum will not charge you any fees other than those specified under the Stock Investing Terms and Conditions.

12. Plum will reverse any transaction where there is suspicion that the order is erroneous or involving (or has a high risk of involvement in) market abuse, money laundering, terrorist financing, fraud or any other type of financial crime. In this instance, Plum will remain under no obligation to allow you to reinstate a buy order at the same price or under the same terms as the canceled transaction and cannot be held liable for any damages or losses caused due to the actions taken by Plum under these terms.

13. Plum does not provide personalised investment recommendations, investment advice, tax related advice or other financial related advice of any kind. Any explanation or information provided by Plum in relation to Recurring Buy Transactions is not intended to be (nor should it be considered as) advice. This information is provided by us solely for informational purposes.

14. You should perform your own independent research on potential investments and consult with your financial adviser to determine whether an investment or the use of the Recurring Buy Transactions feature is appropriate given your financial needs, objectives, and risk appetite.

15. You should understand that the Recurring Buy Transactions feature is speculative and that you could sustain significant losses due to volatility in the stock market. Once you’ve confirmed the details of your recurring order, the feature will automatically execute orders with no additional manual intervention for yourself.

DEFINITIONS:

Recurring Buy Transaction(s): is a feature that allows you to create investment buy orders that will repeat at a fixed frequency (be that daily, weekly or monthly), as specified by you.