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INVESTMENT-REFORM.COM — TERMS OF USE POLICY & DISCLAIMERS

PART 1: Definitions & Terms and Conditions

1.1 Definitions

• "Company" refers to Investment Reform, a business entity based in Athens, Greece, operating the platform investment-reform.com.
• "Service" refers to the AI Investment Advisor platform, including market screening across equities, bonds, ETFs, CFDs, crypto and FX, factsheet and track record access, and investment advisory services delivered via the platform or associated channels.
• "User" refers to any individual, company, or legal entity that accesses, registers for, uploads data to, or uses the Services.
• "Platform" refers to the digital infrastructure hosted at investment-reform.com and associated systems, APIs, or third-party integrations used to deliver the Services.
• "Screening Results" refers to any AI-generated or system-generated output, including but not limited to shortlists of investment instruments, filtered comparisons, factsheets, and track record summaries.
• "User Data" refers to all files, portfolio information, screening criteria, account details, and any other information uploaded or transmitted by the User.
• "AI Outputs" refers to all machine-generated shortlists, comparisons, summaries, and structured outputs generated from User Data and publicly available market information.

1.2 Terms of Use

By accessing or using the Service, the User agrees to be legally bound by these Terms. Investment Reform provides an AI-powered investment screening tool designed to turn user-defined filters into a shortlist of relevant investment options, alongside publicly available factsheets and track record information.

To use the Service, Users must complete the platform workflow:

• Sign-up / Account creation
• Selection of screening filters (asset class, risk level, sector, region, cost, and other criteria)
• AI processing and generation of a shortlist of matching investment options
• Review of publicly available factsheets and track records for the shortlisted options

The Company reserves the right to modify, suspend, or discontinue any part of the Service at any time to ensure operational integrity, security, or compliance.

1.3 User Responsibilities

The User bears full responsibility for all information and criteria submitted. By using the Service, the User represents and warrants that:

• Accuracy & Completeness: All submitted information is accurate, lawful, and complete to the best of the User's knowledge.
• Lawful Origin of Data: Any portfolio information or documents shared originate from lawful activities and comply with applicable laws and regulations.
• Rights & Authorization: The User owns or has lawful rights, licenses, or permissions to submit and process all submitted data.
• No Infringement: Submitted materials do not infringe upon intellectual property rights, confidentiality obligations, trade secrets, or third-party rights.
• Compliance: The User will not use the Service for market manipulation, fraudulent activity, money laundering, tax evasion, or any unlawful activity.

The Company disclaims any responsibility for the legality, accuracy, or integrity of User Data.

PART 2: Privacy Policy

Investment Reform processes data in accordance with the General Data Protection Regulation (GDPR – EU 2016/679) and applicable Greek data protection laws.

2.1 Data Collection

We collect and process:

• Account registration data (name, email, organization details)
• Screening criteria and portfolio information provided by Users
• System usage data (log data, performance metrics, interaction data)
• Technical metadata required for platform operation

2.2 Purpose of Processing

Data is processed strictly for:

• Generation of AI Investment Advisor screening results and shortlists
• Retrieval of publicly available factsheets and track record information
• Improvement of AI models, screening accuracy, and platform performance
• Ensuring platform security, fraud prevention, and system stability
• Providing customer support and advisory services

We do not sell personal or financial data.

2.3 Legal Basis for Processing

Processing is based on:

• Contractual necessity (service delivery)
• Legitimate interest (platform improvement, security)
• Legal obligations (where applicable)
• User consent (where explicitly required)

2.4 Data Security

The Company implements appropriate technical and organizational measures including:

• Encryption of data in transit and at rest
• Access control and authentication mechanisms
• Segregated processing environments
• Audit logging and monitoring
• Principle of least privilege access

While we implement strong safeguards, no system can guarantee absolute security.

2.5 Data Retention

Data is retained only as long as necessary to:

• Provide Services
• Comply with legal obligations
• Resolve disputes or enforce agreements

Users may request deletion subject to legal retention requirements.

PART 3: Cookie Policy

The Investment Reform platform uses cookies and similar technologies.

3.1 Types of Cookies

• Essential Cookies: Required for authentication, secure login, and core platform functionality.
• Functional Cookies: Improve user experience and workflow continuity.
• Performance & Analytics Cookies: Help measure system performance, AI processing efficiency, and platform optimization.
• Security Cookies: Detect anomalies, prevent abuse, and protect user accounts.

3.2 User Control

Users may manage or disable cookies via browser settings. However, disabling essential cookies may limit or prevent access to core AI Investment Advisor functionality.

PART 4: Disclaimers

4.1 AI & Investment Disclaimer

The Service uses artificial intelligence and statistical models to screen and shortlist investment options. All Screening Results and AI Outputs:

• Are generated using publicly available market data and User-defined filters
• Are probabilistic and interpretative in nature
• Do not constitute personalized investment, financial, legal, or tax advice
• Do not constitute a recommendation or an offer to buy or sell any security or financial instrument
• Should not be the sole basis for any investment decision

Investing involves risk, including the possible loss of principal. Past performance is not indicative of future results. Nothing on this platform constitutes personalized investment, legal, or tax advice.

The Generated Recommendations produced by the AI Investment Advisor are AI-generated outputs and, as such, involve inherent risk and may contain errors. They are indicative only and are not a guarantee of any outcome. Before investing any money based on a Generated Recommendation, the User must independently check its expected returns and confirm that it is suitable for their own risk profile, level of knowledge, and level of awareness of the relevant asset class.

Users are encouraged to consult a qualified, licensed advisor before making investment decisions.

4.2 Screening Results Disclaimer

Screening Results are generated exclusively from User-defined filters and publicly available market data. The Company:

• Does not guarantee the accuracy, completeness, or timeliness of underlying market data, factsheets, or track records sourced from third parties
• Does not guarantee the future performance of any shortlisted instrument
• Is not responsible for investment decisions based on Screening Results
• Does not assume liability for losses resulting from reliance on Screening Results

Market conditions, prices, and instrument availability are inherently uncertain and subject to change.

4.3 Data Submission Consent

By submitting screening criteria or account data, the User explicitly:

• Authorizes processing of submitted data via AI systems
• Accepts automated and semi-automated processing methods
• Consents to retrieval of publicly available market data matched against their criteria

4.4 Limitation of Liability

To the maximum extent permitted by law:

• The Company shall not be liable for indirect, incidental, consequential, or punitive damages
• Liability for investment decisions rests solely with the User
• Total liability shall not exceed the amount paid (if any) for the Service within the preceding 12 months

4.5 Risk Warnings for Complex and High-Risk Financial Instruments

Certain instruments that may appear in Screening Results carry a materially higher risk profile and are subject to specific regulatory risk warnings:

• Contracts for Difference (CFDs): CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. The vast majority of retail investor accounts lose money when trading CFDs. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.
• Crypto-Assets: Crypto-assets are highly volatile and are largely outside the scope of MiFID II; depending on their classification they may instead fall under Regulation (EU) 2023/1114 (MiCA) or remain outside any harmonised EU regulatory framework. You may lose all of the capital invested, and standard MiFID II investor protections (including suitability and appropriateness assessments or Investor Compensation Scheme coverage) may not apply.
• Leveraged FX: Foreign exchange trading on margin is highly speculative and carries a high level of risk, including the potential for losses that exceed your initial deposit, depending on the product and provider.

These risk warnings are provided for general information and do not replace the specific risk disclosures that a regulated broker or execution venue is required to give you before you trade.

PART 5: Data Processing Agreement (DPA)

This Data Processing Agreement governs processing under GDPR.

5.1 Roles

• User: Data Controller
• Investment Reform: Data Processor

5.2 Scope of Processing

The Processor shall process personal and portfolio data solely for:

• AI Investment Advisor screening
• Shortlist and comparison generation
• Factsheet and track record retrieval
• System optimization and service delivery

No processing occurs outside the documented scope without explicit instruction.

5.3 Confidentiality

All User Data is treated as strictly confidential. Access is limited to authorized personnel and secure systems under confidentiality obligations.

5.4 Sub-processors

The Company may engage third-party infrastructure providers or AI model providers to deliver Services. All sub-processors are required to:

• Maintain GDPR-compliant safeguards
• Implement industry-standard security controls
• Process data only under contractual instructions

5.5 Data Subject Rights

Investment Reform assists Users in fulfilling GDPR obligations, including:

• Right of access
• Right to rectification
• Right to erasure
• Right to restriction
• Right to data portability
• Right to objection

Requests will be addressed within legally required timeframes.

5.6 Data Breach Notification

In the event of a personal data breach, the Company will:

• Notify relevant authorities where legally required
• Inform affected Users without undue delay
• Take remedial action to mitigate risks

PART 6: MiFID II Investor Protection Disclosures

Where applicable, the following disclosures are provided in accordance with Directive 2014/65/EU on markets in financial instruments ("MiFID II") and its implementing measures (Delegated Regulation (EU) 2017/565 and Delegated Directive (EU) 2017/593).

6.1 Regulatory Status

[This section will state the Company's confirmed regulatory status — for example, that Investment Reform is authorised and regulated by [Competent Authority] under licence number [•]; or that Investment Reform acts as a tied agent of [Authorised Firm] under Article 29 MiFID II; or that the Advisory plans are provided in partnership with [licensed third-party investment firm], authorised and regulated by [Competent Authority].] Users will be informed of the Company's regulatory status, and of any change to it, before receiving the affected Service.

6.2 Client Categorisation

Under MiFID II, clients are categorised as retail clients, professional clients, or eligible counterparties, each benefiting from a different level of regulatory protection. Unless the Company notifies the User otherwise in writing, all Users are treated as retail clients, the category afforded the highest level of protection. A User who meets the quantitative and qualitative criteria set out in Annex II of MiFID II may request to be treated as a professional client, in which case certain protections described in this Part 6 will no longer apply. The Company will assess any such request before agreeing to it.

6.3 Nature of the Service: Screening Information vs. Investment Advice

The AI Investment Advisor screening functionality provides generic market information and Screening Results generated from User-defined filters and publicly available data. It does not take into account any individual User's personal circumstances and does not constitute a personal recommendation. Accordingly, it does not amount to "investment advice" within the meaning of Article 4(1)(4) MiFID II, and no suitability or appropriateness assessment is performed in connection with its use.

Where the Company's human advisory team provides a personal recommendation under an Advisory plan, that recommendation constitutes investment advice regulated under MiFID II. Such advice is provided on a non-independent basis: the Company does not assess a sufficiently large and diversified range of financial instruments available on the market from different product providers, and may receive or retain inducements in connection with the advice given, as described in Section 6.6. The Company will inform the User of the basis on which advice is given in advance, and in good time, before providing any personal recommendation.

6.4 Suitability and Appropriateness Assessments

Before providing a personal recommendation under an Advisory plan, the Company will obtain the necessary information regarding the User's knowledge and experience, financial situation (including ability to bear losses), and investment objectives (including risk tolerance) in order to assess suitability in accordance with Article 25(2) MiFID II. Users who do not provide sufficient or accurate information may not receive a suitability assessment, and the Company will not be able to determine whether a given recommendation is suitable for them.

Use of the AI Investment Advisor screening tool alone, without engaging the Company's advisory service, is provided on a non-advised (execution-only style) basis. Complex financial instruments — including but not limited to CFDs, derivatives, and certain crypto-assets — do not qualify for the simplified appropriateness regime under Article 25(4) MiFID II. Users intending to transact in such instruments without advice should ensure that an appropriateness assessment has been carried out by their broker or execution venue, and should carefully review Section 4.5 above.

6.5 Costs and Charges Disclosure

In accordance with Article 24(4) MiFID II and Article 50 of Delegated Regulation (EU) 2017/565, the Company will provide Users with aggregated information on all costs and associated charges relating to the Service — including subscription fees and, where applicable, any third-party product costs and charges known to the Company — on an ex-ante (before the service is provided) and ex-post (at least annually) basis, illustrating the cumulative effect of costs on return. Costs and charges relating to the underlying financial instruments themselves (e.g., broker commissions, fund management fees) are disclosed by the relevant product provider or execution venue and do not form part of the Company's own fee disclosures.

6.6 Inducements and Third-Party Payments

The Company [does not accept / may accept] fees, commissions, or non-monetary benefits from third parties (such as product providers or execution venues referenced in Screening Results) in connection with the Service. Where such inducements are accepted, they are designed to enhance the quality of the Service to Users and do not impair the Company's duty to act honestly, fairly, and professionally in accordance with the best interests of its clients. Details of any such arrangements, including their nature and amount (or a reasonable estimate thereof), will be disclosed to affected Users before the Service is provided.

6.7 Conflicts of Interest

The Company maintains organisational and administrative arrangements designed to identify, prevent, and manage conflicts of interest that may arise between the Company, its staff, and its Users, or between different Users, in accordance with Article 23 MiFID II. Where the Company's arrangements are not sufficient to ensure, with reasonable confidence, that risks of damage to a User's interests will be prevented, the Company will clearly disclose the general nature and/or source of the relevant conflict before undertaking business on the User's behalf.

6.8 Product Governance and Target Market

In accordance with Article 24(2) MiFID II and Delegated Directive (EU) 2017/593, the Service is designed for a target market of investors who have at least a basic understanding of the relevant asset classes (equities, bonds, ETFs, CFDs, crypto-assets, and FX), are able to bear the risk of loss associated with those asset classes, and are seeking to conduct their own market screening or to receive investment advice through the Advisory plans. The Service is not designed for investors seeking capital protection or guaranteed returns. Users should independently assess whether the instruments appearing in their Screening Results fall within their own risk tolerance and investment objectives.

6.9 Best Execution and Order Handling

The Company does not itself receive, transmit, or execute orders in financial instruments, and does not act as a broker, exchange, or execution venue. Any transaction a User chooses to enter into following use of the Service is placed directly with the User's own broker, platform, or execution venue, which is solely responsible for complying with its own best execution obligations under Article 27 MiFID II. The Company accepts no liability for the execution quality, pricing, or conduct of any third-party broker or venue.

6.10 Record Keeping and Suitability Reports

In accordance with Article 16(6)-(7) and Article 25(5)-(6) MiFID II, the Company retains records of communications relating to the investment advice provided under Advisory plans, and of the suitability assessments underlying that advice, for a period of at least five (5) years (or such longer period as required by applicable law) from the date the record was created. Users may request a copy of these records at any time during the applicable retention period. Where the Company provides a personal recommendation under an Advisory plan, it will also provide the User with a suitability report in a durable medium, specifying the advice given and explaining how it meets the User's preferences, objectives, and other characteristics.

6.11 Complaints Handling

Users who wish to raise a complaint regarding the Service may do so by contacting [complaints@investment-reform.com]. The Company will acknowledge receipt of a complaint within [X] business days and aim to provide a final response within [X] weeks. If a User is not satisfied with the outcome, they may be entitled to refer the complaint to the Hellenic Capital Market Commission (HCMC) or another competent out-of-court dispute resolution body, without prejudice to their right to bring proceedings before the competent courts.

6.12 Provision of Information

All information required to be provided under MiFID II will be made available to Users on the Platform, by email, or in another durable medium, in good time before the provision of the relevant service, unless the User expressly agrees to receive it after the service has commenced where this is necessary to meet the User's request without delay.