Our Terms

This page (together with our Privacy Policy, which can be found on our site) tells you information about us and the legal terms and conditions ("Terms") on which we provide you with access to Plum, a personal savings assistant available through our mobile applications ("app") that monitors your daily spending and automatically sets aside money for you, as detailed on our website https://withplum.com ("Our Site") and the Services (as defined below).

For these Terms to apply, you must be resident in an EU country.

These Terms will apply to your use of Plum and the provision of our Services to you. Please read these Terms carefully and make sure that you understand them, before signing-up to use Plum. Please note that before you use the Services you will be asked to agree to these Terms. If you refuse to accept these Terms, you will not be able to use the Services.

We may amend these Terms from time to time as set out in clause 12. Please check these Terms periodically to ensure you understand the terms which will apply at that time. You may ask for a copy of these Terms at any time.

These Terms and all information will be in the English language. A glossary of defined terms used in these Terms is set out in Annex 1.

1. Information about us

1. We (“Plum”) are
1. Plum Fintech CY Limited, a company registered in the Republic of Cyprus under registration number HE 414801, whose registered office is at 21 Panteli Katelari street, Libra House, Floor 6, 1097 Nicosia, Cyprus.
2. We operate the website https://withplum.com and the Services available through our app.
2. Regulatory statuses
1. Plum Fintech CY Limited is a distributor of PayrNet UAB (“PayrNet”), an e-money institution incorporated in Lithuania under registration number 305264430 and with registered address at Girulių g. 20, LT-12123 Vilnius. PayrNet is authorised and regulated by the Bank of Lithuania and its licence number is LB001994. PayrNet is our provider of E-Money who will operate and maintain your Plum Wallet. The use of this service will be subject to PayrNet’s terms and conditions, which you can access here.
2. As applicable, for the purpose of providing you with access to your payment accounts and displaying the payment account data to you (a so-called ‘account information service’), we act as an agent of an authorised payment services provider, Tink AB. Tink is a Swedish limited company with its registered office in Stockholm, Sweden. Tink is supervised by the Swedish Financial Supervisory Authority.
3. The account information service is provided to you based on Tink’s terms and conditions found here.
4. When providing an account information service to you Tink processes your personal data as described in Tink’s privacy notice.
3. Precedence
   1. Your agreement with us is comprised of: (a) these Terms; (b) our Terms of Website Use; (c) any Premium Service Terms that apply to you (see clauses 2.3.3 and 2.6 below); (d) any other terms that apply to you.
   2. In the event of any conflict or inconsistency between:
      1. the Terms of Website Use;
      2. these Terms; and
      3. any applicable Premium Service Terms,
   the Premium Service Terms will prevail and take precedence over these Terms which shall prevail over the Terms of Website Use.
4. Contacting us
   1. If you wish to contact us for any reason, including because you have any complaints, you can contact us by emailing us at support@withplum.com or tweeting us at @withplum. We can also be contacted in-app via our help widget.
   2. If we have to contact you or give you notice in writing, we will do so by email, through the site or app or through an instant messaging service using details you provide to us. We may also contact you by telephone or SMS.
   3. It is your responsibility to ensure the contact information we have for you is up to date. You are required to notify us promptly if there is a change to: your name; your address; your Personal Accounts; your mobile number and/or your status as a resident of an EU country. 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.
   4. We may record and monitor telephone conversations that we have with you. We will store recordings in accordance with applicable law, and / or for as long as we consider necessary to be able to provide the Services to you.
5. Security incidents
   1. If we become aware or suspect that you are affected by fraud or an operational security incident, some or all of the functionality of your account may be limited until such time that the suspected incident is resolved.
   2. If you believe that your account has been compromised or do not recognise activity on your account, contact us via the means in clause 1.4.

2. Our Services

   1. You must be over 18 years old to use Plum and resident with a bank account in an EU country.
   2. You will be treated as a retail customer under applicable laws and regulations. This means that you are entitled to certain protections that are required to be provided to a retail customer under these laws and regulations.
   3. We may, at our discretion, allow you to:
      1. access details of transactions and balances on your bank account(s) held with your bank ("Personal Accounts") through our AIS Partner;
      2. put money aside into an e-wallet (your "Plum Wallet") for later use with one of our trusted E-Money Providers;
      3. enable you to access other financial products or services made available to Plum by our trusted third parties (the "Premium Services"); and
      4. access other products and services offered by us or third parties, (2.3.1 and 2.3.2 together, the “Plum Services” and 2.3.1 to 2.3.4 inclusive together the “Services”).
   4. The Plum Services: the purpose of the Plum Services is to try to help you put money aside with minimal effort. We monitor and analyse your Personal Account in cooperation with our AIS Partner. Based upon our analytics, we identify funds in your Personal Account that may be put aside; and such funds will be periodically transferred from your Personal Account to your Plum Wallet with the E-Money Provider (see clause 9). This will typically be done every few days. Only funds from your Personal Account may be transferred to your Plum Wallet.
   5. You acknowledge and agree that Plum is not endorsed or sponsored by the providers of your Personal Accounts.
   6. The Premium Services: Plum may, at its discretion, from time to time offer access to the Premium Services provided by Plum or third party partners (as applicable). The Premium Services are subject to specific additional terms and conditions (the “Premium Service Terms”) and to additional fees or subscription charges found in the Fee Schedule. The Premium Service Terms include:
      1. The Interest Pocket Terms set out in here (if this Premium Service is available in your region);
      2. the Card Terms set out here;
      3. any other services terms that we describe as “Premium Service Terms” from time to time. 2.6.3
   7. Premium Services may involve the transfer of funds from your Plum Wallet to Plum or a third-party and your ability to access your money will depend upon the relevant Premium Service Terms.
   8. Funds released from closing, redeeming or withdrawing from a Premium Service will be paid back to your Plum Wallet unless otherwise specified.
   9. If you choose to proceed with a Premium Service offered by a third party, we will act as your agent in arranging it. In doing so, in addition to the Premium Service Terms, you will be subject to the terms and conditions of the relevant third party, over which we have no control.
   10. We do not supply the third-party Premium Services and we are therefore not responsible or liable for their supply (or failure to be supplied).
   11. Obtaining a third-party Premium Services is at your discretion and risk. We do not endorse or recommend any third-party Premium Services.
   12. Plum Switching Services: Plum acts as an intermediary for product providers to assist you in saving money on your bills. These services can be found in the Lost Money section of the app.
   13. You will be required to provide Plum information relevant to your circumstances and as required by the switching product you have chosen to apply for. This data will be handled in line with Plum’s Privacy Policy.
   14. Once you have submitted your application, we will provide your information to the product provider who will treat your data in line with their own data privacy policy. Where the product provider partners up with other providers, this may include passing your data on to a third party provider.
   15. Where your application is successful and you decide to go ahead, you will form an agreement with the product provider. By entering into such an agreement, Plum will receive a fee directly from the product provider, never from you, in line with the Fee Schedule available on our website.
   16. Trial Periods: From time to time, we or others on our behalf may offer trials of Premium Services for a specified period without payment or at a reduced rate (a "Trial"). Plum may determine your eligibility for a Trial, and withdraw or modify a Trial at any time without prior notice and with no liability, to the extent permitted under applicable law.
   17. For some Trials, we’ll require you to provide your payment details to start the Trial. By providing such details you agree that we may automatically begin charging you for the Premium Services on the first day following the end of the Trial on a recurring monthly basis or another interval that we disclose to you in advance.
   18. If you do not wish to receive the Premium Services you must cancel these Services via the in-app instructions before the Trial Period lapses. Once the Trial Period has lapsed, you must cancel your account in accordance with clause 19.
   19. Decision Tech Services: This energy comparison and switching service is powered by Decision Technologies Limited, a company registered in England & Wales under company number 05341159 with its registered address at First Floor, High Holborn House 52-54 High Holborn London WC1V 6RL ("Decision Tech").

3. Application for Services

   1. In order to receive the Services, you must complete an application ("Application"). By completing our Application, you confirm that the information you have provided is accurate and complete.
   2. If any information provided in your Application is found to be incorrect or incomplete and we have not received the outstanding information within ten Business Days of receipt of your Application we may reject your Application and return to you any cash received.
   3. If we have been unable to complete identity verification checks to our satisfaction within ten Business Days of receipt of your Application (regardless of the method of payment), we may reject your Application and return any monies received from you.
   4. We have full discretion to accept or not to accept an Application and we reserve the right to reject your Application and not to give you any reasons for doing so.

4. Access to Plum

   1. Access to the Services will be through our app (or any other instant messaging service we approve). You will be bound by the relevant messaging service provider’s terms of use and policies, in addition to these Terms.
   2. You must not allow anyone to access the Services on your behalf. You must treat as confidential; the user identification code, password and any other piece of information as part of our and the relevant messaging service provider’s security procedures, and you must not disclose it to any third party.

5. Providing secure read-only access to your Personal Account

   1. To use the Plum Services that relate to accessing details of transactions and balances on your bank accounts,we will redirect you to our trusted AIS Partner who will take you through a secure process to access information from your Personal Account. You will be asked to provide your explicit consent to enable us and our AIS Partner to access specified information about your Personal Account and your transactions on a read-only basis. To keep you safe, we will periodically ask you to renew your consent.
   2. You may withdraw your consent to access your Personal Account at any time. If you do withdraw (or fail to renew) your consent we will be unable to set money aside for you.
   3. You grant to us and our AIS Partner a non-exclusive, royalty-free licence to use the information in your Personal Account(s) for all purposes connected with the Services or referred to in these Terms or the Privacy Policy, with the right to use, modify, display, distribute and create new material using or incorporating such information to provide the Services to you. Our AIS Partner and us may also use, sell, license, reproduce, distribute and disclose aggregate, non-personally identifiable information that is derived through your use of the Services. By submitting information, you agree (without the payment of any fees), that our AIS Partner and us may use the information for the purposes set out above.
   4. You are permitted to use content delivered to you only in order to use the Services. You may not copy, reproduce, distribute, or create derivative works from this content. Further, you agree not to reverse engineer or reverse compile any of the technology associated with us.
   5. You agree that when we retrieve your information relating to your Personal Accounts or your information required as part of the provision of the Services, we are doing so as your representative and on your behalf and not on behalf of or in the name of any third party.
   6. You agree that we will be entitled to disclose your identity and information relating to your Personal Account(s) to third parties if we are required to do so by any applicable law or court order.
   7. We do not check the accuracy of the Personal Accounts information and personal information you provide to us and we rely on you and your Personal Account providers to ensure that the Personal Accounts information and personal information you provide to us is up to date and accurate.
   8. By using the Services, you represent that you are the legal owner of the data in your Personal Accounts and that you have the authority to appoint, and do expressly appoint, our AIS Partner as your agent and grant a limited power of attorney to access and retrieve such data on your behalf.
   9. For our compliance purposes and in order to provide the 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 information. When you register for 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. You agree to provide us from time to time with all such information 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.
   10. You agree that our third-party services providers are third-party beneficiaries of the applicable provisions of these Terms, with all rights to enforce such provisions as if such service providers were a party to these Terms.
   11. Neither us nor our AIS Partner can initiate any transaction on your Personal Account. However, if you are concerned about any activity on your Personal Account please contact us. 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 we may think most appropriate.

6. Setting money aside through Plum

   1. We allow you to periodically put money aside for future payments. We analyse your Personal Account so we can learn about your income, expenses and spending patterns.
   2. We will set up a direct debit mandate for you with an appropriately authorised Payment Services Provider and every few days money will be transferred from your Personal Account to your Plum Wallet. The amount and frequency of each debit may vary.
   3. The direct debit will continue until you notify us that you wish to cancel by contacting us at the address in clause 1.4.1 above. We may not be able to stop payments which are already in progress or scheduled to take place when you give notice to cancel. You can also cancel a direct debit by contacting the provider of your Personal Account.
   4. We are not liable for any overdraft charges you may incur as a result of any direct debits related to your use of the Plum Services unless we are negligent in cancelling your direct debit when asked to do so.

7. Your Plum Wallet

   1. Your Plum Wallet is operated and maintained by an E-Money Provider (see clause 9 below) for whom we distribute and redeem electronic money.
   2. 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 the 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 Wallet, your claim will not be against a specific account but against the pool in general.
   3. 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.

8. Accessing your Plum Wallet

   1. Your funds will remain in your Plum Wallet until you instruct our E-Money Provider to transfer any or all of your funds from your Plum Wallet to your Personal Account by using the "withdraw" functionality. Subject to clause 8.2, we will generally transfer the requested funds from your Plum Wallet to your Personal Account within one Business Day of when we receive your request.
   2. If you do not have sufficient available 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 without notice to you upon the closure of your Plum Account as described below and at any time if required by applicable law or if we, in our sole discretion, suspect the Services are being used for illicit purposes or otherwise in violation of these Terms.

9. Plum partners and suppliers

   1. To provide the Services to you we partner with a number of third parties. You can find the details of our AIS Partner and E-Money Provider and where relevant, important terms on which they provide their services to you here. Please refer to our Privacy Policy for information about our partners’ and suppliers’ processing of personal data.
   2. We may from time to time, appoint additional or alternative partners and suppliers to provide the Services to you or services to us.
   3. Providing that we act in your best interests and in accordance with applicable laws, we may as your agent redeem e-money held with an E-Money Provider and distribute to you e-money issued by another appropriately authorised E-Money Provider of the same value. We may do this for regulatory reasons, to implement contingency measures in the event of business interruptions, to improve our technical capabilities, or to lower our operating costs.
   4. We will notify you of the identity and terms of any additional or replacement AIS Partner or E-Money Provider at least two months in advance (unless we implement contingency plans or act to comply with applicable laws in which case we will tell you as soon as possible).

10. Fees

    1. We reserve a right to charge a fee for the Services we offer, as set out on the site from time to time. For more information on our current Fee Schedule see our website or app.

11. Use of Plum

    1. Your use of Our Site and our app is governed by our Terms of Website Use which can be found on Our Site. Please take the time to read this, as it includes important terms which apply to you.

12. Our right to vary these Terms

    1. We expect to update or amend these Terms from time to time to comply with applicable laws or to meet our changing business requirements.
    2. We can make changes to these Terms without your specific agreement. We may not always be able to give you advance notice of such updates or amendments, but will make a reasonable effort to give at least 2 months notice, particularly where this is required by legal or regulatory requirements.
    3. When we make changes to these Terms we will always post them on Our Site so you can view them when you next visit Our Site. By continuing to use the Services after any changes to these Terms, you agree to be bound by the amended Terms.
    4. If you do not agree to the proposed changes you can notify us and we will arrange for your account to be closed, subject to any relevant Premium Service Terms.

13. Warranties

    1. You expressly understand and agree that:
       1. Your use of the Services and all information, products and other content (including that of third parties) included in or accessible from us is at your sole risk.
       2. the Services are provided on an "as is" and "as available" basis. We and our third-party services providers expressly disclaim all warranties of any kind as to us and all information, products and other content (including that of third parties) included in or accessible from us, whether express or implied, including, but not limited to the implied warranties of merchantability, fitness for a particular purpose and non-infringement.
    2. Neither we nor our third-party services providers make any warranty that:
       1. we will meet your requirements;
       2. we will be uninterrupted, timely, secure, or error-free;
       3. the results that may be obtained from the use of the Services will be accurate or reliable;
       4. the quality of the Services or any products, services, information, or other amenities or material purchased or obtained by you through us will meet your expectations; or
       5. any errors in the technology will be corrected.
    3. Any material downloaded or otherwise obtained through the use of the Services is done at your own discretion and risk and you are solely responsible for any damage to your computer system or loss of data that results from the download of any such material. No advice or information, whether oral or written, obtained by you from our third-party services providers or through or from us will create any warranty not expressly stated in these Terms.

14. Our liability

    1. If we fail to comply with these Terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breach of these Terms or our negligence, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if it is an obvious consequence of our breach or if it was contemplated by you and us at the time you started using the Services.
    2. If our app damages a device or digital content belonging to you, we will either repair the damage or pay you compensation. However, we will not be liable for damage that you could have avoided by following our advice to apply an update offered to you free of charge.
    3. We only provide the Services for domestic and private use. You agree not to use the Services for any commercial, business or resale purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
    4. We do not in any way exclude or limit our liability for:
       1. death or personal injury caused by our negligence; or
       2. fraud or fraudulent misrepresentation.
    5. Subject to clause 14.4, and to the maximum extent permitted by applicable law, neither we nor our third-party services providers will be liable to you (including your use or inability to use the Services) for:
       1. loss of profits or goodwill or damage to reputation;
       2. any statement or conduct on or via Our Site or app by any third party;
       3. loss of data which is caused by factors other than negligence or breach of statutory duty on the party of us or our third-party services providers;
       4. the acts or omissions of the providers of your Personal Account(s);
       5. the cost to you of obtaining goods or services as substitutes for the Services we provide; or
       6. any other loss or damage suffered by you in connection with the Services or these Terms.
    6. We are not a financial adviser, and we do not provide financial, legal, tax or any other advice. Your situation is unique. 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 Services are suitable or appropriate for you. If you are not sure whether any of the Services are suitable or appropriate for you then we recommend that you seek advice from a qualified financial, legal, tax or other adviser.

15. Indemnification

    1. You agree to protect and fully compensate our third-party services providers and us and our affiliates 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.

16. Data Protection

    1. How we use your Data 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 services.
    2. 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 services.
    3. We may disclose your personal information if we are required to do so by law or we are requested to do so by any competed regulatory authority in any country.
    4. Where it is necessary for the provision of our services, your personal data may be transferred to third parties outside the EEA as well as within it. You should be aware that in territories outside the EEA, laws and practices relating to the protection of personal data are likely to be different and, in some cases, may be weaker than those within the EEA. Where data is transferred outside of 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.
    5. Our full terms outlining the protection, processing and treatment if your data can be found in our Privacy Policy.
    6. Questions, comments and requests regarding our data protection policies are welcomed and should be addressed to dpo@withplum.com.

17. Communications between us

    1. When we refer, in these Terms, to "in writing", this will include email and instant messaging.
    2. You may contact us and we may contact you as described in clause 1.

18. Lost or Stolen Device

    1. 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.
    2. If you have lost or had stolen any payment card provided to you by Plum, you must follow the relevant instructions in the terms and conditions for such payment card, which can be found here.
    3. You must ensure that you are the only person who accesses and uses the Products and Services.
    4. You shall use reasonable endeavours such as using password protection on your device to prevent any unauthorised access to and use of the Products and Services and, in the event that you suspect any such unauthorised access, promptly notify Plum.
    5. 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.
    6. If you become aware that you have lost or misplaced your security credentials, or that the security credentials have become or may become compromised.
    7. 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.
    8. 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.

19. Cancelling your account

    1. You can cancel your use of the Plum Services at any time. Premium Services are subject to additional terms and your ability to dispose of or release a Premium Service will depend upon the relevant Premium Service Terms.
    2. We can cancel our provision of the Services to you if:
       1. your use of the Plum Account has been inactive for an extended period of time; or
       2. you commit a material breach of these Terms; or
       3. you breach the Terms of Website Use, provided in each case that we do so in accordance with any applicable Premium Service Terms.
    3. If your account is cancelled, we will transfer any funds standing to the credit of your Plum Account to your Personal Account within two Business Days.
    4. If you have cancelled any of your Personal Accounts or transferred a Personal Account to another bank, you must inform us as soon as reasonably possible by contacting us at the address in clause 1.4.1 above .

20. Complaints

    1. Should you have any complaints in relation to your use of the Services then please notify us in accordance with clause 1.4. We will acknowledge your complaint promptly and arrange for the matter to be investigated in accordance with applicable law and report the results to you.
    2. In addition, please note that disputes may be submitted for online resolution to the European Commission Online Dispute Resolution platform which can be accessed at http://ec.europa.eu/consumers/odr/.
    3. For complaints against our third-party services providers, please refer to their terms and conditions.

21. Other important terms

    1. We can transfer our rights and obligations under these Terms to another organisation, but this will not affect your rights or our obligations under these Terms. We will always notify you if this happens.
    2. Subject to clause 21.1 above, our agreement is between you and us. Save as otherwise expressly provided for in these Terms, no other person will have any rights to enforce any of its terms.
    3. Each of the paragraphs of these Terms 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.
    4. 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 do 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.
    5. 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 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

"Application" has the meaning given to it in clause 3.1.

"AIS Partner"means our third party provider supplying the services that enable the aggregation of 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.

"E-Money Provider" means our provider of E-Money who will operate and maintain your Plum Wallet . This is currently PayrNet UAB, an e-money institution incorporated in Lithuania, under registration number 305264430 and with registered address at Girulių g. 20, LT-12123 Vilnius. PayrNet UAB is authorised and regulated by the Bank of Lithuania and its licence number is LB001994.

"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" means the bank accounts of individual customers held with their banks.

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

"Plum Services" has the meaning given to in clause 2.3.

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

"Premium Services" means financial products or services made available to Plum by our trusted third parties as referred to in clause 2.6.

"Premium Service Terms" means the additional terms and conditions applicable to each Premium Service.

"Services" means the Plum Services and the Premium Services.

"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 noted, this will be 30 days.

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

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.

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

We will not execute any orders that you submit via the Plum App, but rather will transmit orders to our third party broker Alpaca for execution or onward transmission by Alpaca to market centres or other third party brokers. Under no circumstances will we act in any other capacity and a transaction will arise between you and Alpaca in all instances for the purposes of the execution of your order.

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 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 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.

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 order will be cancelled.

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.

We will carry out transmission of orders as promptly as possible 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 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.

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 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 in the Best Execution Oversight Group and submitted for relevant approvals.

Implementation: The approved execution arrangements are implemented using routing technology and execution partnerships with third-party brokers 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 by the Best Execution Oversight Group and incorporated in the design process.

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, 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 by the Best Execution Oversight Group is 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, we cannot control when and how the Alpaca will execute your orders. By opening a Stock Investing 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.