The below Terms & Conditions apply as of 22 May 2024.
Click here for Terms & Conditions that applied prior to 22 May 2024.
• Stock Investing Terms & Conditions
• Exchange-Traded Funds (ETFs) Terms & Conditions
• Money Market Fund ("Plum Interest") Terms and Condition
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. Depending on the Products and Services, specific and/or additional terms apply. You must be aware that certain Products and Services may not be accessible/available in your region, thus rendering the associated terms inapplicable 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.
| Product / Service | Provider | Relevant terms |
|---|---|---|
| Aggregation Partner(s) | TrueLayer (Ireland) Limited | Truelayer Terms |
| Tink AB | Tink AB Terms | |
| ITBS Finance SMPC “Finker” | https://www.finker.co/eula/ | |
| E-Money Provider | Modulr Finance B.V. | Modulr Finance B.V. Terms |
| Stock Investing | Alpaca Securities LLC | Stock Investing Terms |
| Exchange-Traded Funds (ETFs) | Upvest Securities GmbH | Exchange-Traded Funds (ETFs) Terms |
| Money Market Fund ("Plum Interest") | Plum Money CY Limited | Money Market Fund ("Plum Interest") Terms |
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.
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:
"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.
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.
These terms of website use refer to the following additional terms, which also apply to your use of Our Site:
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.
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.
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.
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.
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.
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.
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:
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.
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.
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.
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
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.
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.
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.
To contact us, please email help@withplum.com.
Thank you for visiting Plum.
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.
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.
"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/gr-CY/.
This agreement (the Exchange-Traded Funds (ETFs) 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 ETFs Terms relate to the provision of certain investment services by Plum to you in relation to Exchange Traded Funds Services (the ETFs Services) via the Plum mobile application (the Plum App).
These ETFs 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 ETFs Services and any rights or obligations which you may have or be subject to under these ETFs 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 ETFs Services. To the extent that any conflicts arise between the provisions of these ETFs Terms and the Plum General Terms and Conditions in relation to the ETFs Services, these ETFs Terms will prevail.
Throughout this agreement, we use certain capitalised terms. A full list of these capitalised terms can be found in the Schedule 1 to these ETFs Terms. For any capitalised term not defined in Schedule 1 of these ETFs Terms, the definition is the one given in the Plum General Terms & Conditions.
These ETFs Terms contain important information that you need to read carefully. Before confirming your agreement to these ETFs Terms and opening a Plum ETFs Investment Account, you should carefully read our Risk Warning Notice (which can be found here) and our Order Handling and Best Interest Policy (which can be found here), each of which shall apply to Orders and Transactions made under these ETFs Terms. By agreeing to these Terms, you will be giving your consent to our best execution arrangements. Also, by entering into this agreement, you confirm that you have read and understood the applicable Prospectus (which can be found via the Plum App) and the applicable Key Information Document, and will review each of these documents each time you submit an Order. The Key Information Document will be available via the Plum App and by placing an Order, you confirm you've read and understood the KID for the ETF you're investing in.
If you have any questions or doubts about any of the content in these ETFs Terms, you should seek appropriate professional advice before opening your Plum ETFs Investment Account.
We may update these ETFs Terms in accordance with any amendment provisions in force from time to time between you and us under the Plum General Terms and Conditions.
Plum Money CY Limited is an investment firm, authorised and regulated by the Cyprus Securities and Exchange Commission (CySEC), under the licence number 407/21 to provide regulated activities. We can be contacted at help@withplum.com or via the Plum App.
"CySEC" means the Cyprus Securities and Exchange Commission.
"CySEC Rules" means the rules of the CySEC as documented in CySEC’s directives and guidelines from time to time.
"Fees" means any fees, commissions or similarly payable to us under the ETFs Terms in respect of the ETFs Services, as these are listed on the Plum App and 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.
"ETF" means the exchange-traded funds which we may make available to trade via the Plum App through a third party broker.
"ETFs services" means the provision of certain investment and order handling services by Plum to you in ETFs through the Plum ETFs Investment Account.
"Third party broker" means Upvest Securities GmbH responsible for the execution of ETFs Orders which is a German broker registered and supervised at the Bundesanstalt für Finanzdienstleistungsaufsicht (Federal Financial Supervisory Authority - BaFin).
"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)).
"Net Asset Valuation" means the aggregate value of the securities and other assets allocated to the ETFs, minus any relevant liabilities and calculated in accordance with the terms of the Prospectus every Trading Day. This determines the trading value of Shares issued in the ETFs.
"ETFs terms" has the meaning given in the Introduction.
"Order" means an instruction from you to us to buy (including recurring buy order) or sell Shares in ETFs on your behalf at the price issued at the next Net Asset Valuation.
"Order" means an instruction from you to us to buy (including recurring buy order) or sell Shares in ETFs on your behalf at the price issued at the next Net Asset Valuation.
"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 App" has the meaning given in the Introduction.
"Plum ETFs Investment Account" 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.
"Plum Wallet" means the account opened for purposes of your access to and use of the ETFs Services and funded through the means of the Plum Wallet or through an instant payment directly from your Personal Account(s) via faster payment.
"Regular Market Hours" means from 8:00 CET to 21:00 CET, Monday through Friday.
"Recurring buy Order" means an Order to buy a predetermined value of ETFs on future dates and/or at defined intervals and may only be executed as Orders. Such orders are exclusively executable as buy Orders, subject to the same terms and conditions applicable to standard buy Orders under these ETFs Terms.
"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 ETFs 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.
"Share" means either the whole or a fraction of a share issued in the ETF.
"Trading Day" means Monday through Friday, excluding public holidays or any day when the ETF is not actively trading.
"Transaction" means a transaction that arises following the execution of an Order.
"US Person" means a citizen or resident of the United States as defined by the US Internal Revenue Service.
"Website" means https://withplum.com/gr-CY/.
Plum Money CY Limited (“Plum”, “us”, “our” and/or “we”) is committed to treating its customers with honesty, transparency and in their best interests.
This Order Handling and Best Interest Policy (“Policy”) outlines how, when and where we will treat Client (“you” and/or “your” and/or “customer”) orders when received and transmitted for execution, in order to meet the Best Execution requirements as defined in the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”).
The purpose of this Policy is to set out Plum’s approach to meeting our customers best interests 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 transmission and 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.
Plum handles the reception and transmission of client orders for execution. The financial instruments to which this Policy applies to are:
Through the Plum App, you will be able to submit orders 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.
Plum receives the order from the customer through the Plum App and transmits the order to Upvest for 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 here.
If Exchange Traded Funds (ETFs) are offered by Plum in your country, you can use the Plum App to submit orders for ETFs. Plum receives the order from the customer through the Plum App and transmits the order to our third-party broker for execution.
Our third party broker is Upvest Securities GmbH (“Upvest”). Upvest is a German broker registered and supervised at the Bundesanstalt für Finanzdienstleistungsaufsicht (Federal Financial Supervisory Authority - BaFin).
If Money Market Fund (MMF) is offered by Plum in your country, you can use the Plum App to have execution access to 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.
We will not execute any orders (either stock, MMF or ETFs) 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 ETFs to our third party broker Upvest, or for MMFs to the MMF Manager that is 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 Alpaca and/or Upvest and/or the MMF Manager.
Our primary obligation is to ensure that our customers’ orders are received and transmitted to partners and/or third party broker(s) accordingly for execution 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 Upvest 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 ETFs will take place with Upvest.
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 and/or ETFs orders we do not aggregate a customer’s orders with those of any other customers. Although, Alpaca and/or Upvest 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 and/or Upvest and/or the MMF Manager and their counterparties.
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 brokers (i.e. Alpaca and Upvest) and the 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 brokers and the 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.
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:
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):
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.
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/or Upvest and/or 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.
Once we have transmitted your orders to Alpaca and/or Upvest and/or BlackRock, we cannot control when and how these parties will execute your orders. By opening a Stock Investing Account and/or a Plum ETFs Investment Account and/or a Plum MMF Investment Account you are deemed to consent to our Order Handling and Best Interests Policy.
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.
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.
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”.
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.
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.
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).
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.
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.
Plum is unable to provide any guarantee relating to the performance of particular investments or strategy connected with Recurring Buy Transactions.
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.
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.
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.
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.
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.
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.
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.