1. PURPOSE OF THIS POLICY

Glofinex.com is a financial transparency ledger — a neutral, independent, and passive infrastructure platform that provides registered users with the technical space to submit, publish, and view complaints relating to financial institutions, brokerages, banks, investment firms, financial regulators, and similar entities.

This Complaint Policy governs exclusively the submission, publication, moderation, and retention of complaints on the Platform. It does not replace or limit the Terms of Use, which govern all other aspects of your relationship with the Company. In the event of any conflict between this Policy and the Terms of Use, the Terms of Use shall prevail.

2. WHO CAN FILE A COMPLAINT

To be eligible to file a complaint on Glofinex.com, you must meet all of the following requirements at the time of submission:

• Registered user: You must hold an active, verified Account on the Platform.
• Minimum age: You must be at least 18 years of age, or the legal age of majority in your jurisdiction, whichever is higher.
• First-hand experience: You must have had a direct, personal experience with the entity against whom you are filing the complaint. Complaints submitted on behalf of another person, based on hearsay, or derived from second-hand accounts are not permitted.
• Legal capacity: You must have the full legal capacity to enter into binding agreements and to take legal responsibility for the content you submit.

The Company reserves the right to verify eligibility at any time and to remove complaints or suspend accounts where eligibility requirements are not met, without prior notice or liability.

3. WHAT A COMPLAINT MUST BE

Every complaint submitted to Glofinex.com must satisfy all of the following standards:

3.1 Truthful and Accurate

The complaint must be factually truthful and accurate to the best of your knowledge. You may not exaggerate, distort, fabricate, or misrepresent any aspect of your experience. You are filing a factual account, not an opinion piece or a marketing exercise.

3.2 Based on Direct Personal Experience

The complaint must describe an experience you personally had with the entity in question. You must have been a direct party to the interaction, transaction, or event you are describing. You may not file complaints on behalf of others, aggregate multiple people’s experiences as your own, or describe events you did not personally witness or experience.

3.3 Related to Financial Services or Regulated Activity

Complaints must relate to the conduct, practices, products, or services of a financial institution, brokerage, bank, investment firm, financial regulator, or similar entity listed on the Platform. Off-topic or unrelated submissions will be subject to moderation.

3.4 Specific and Identifiable

The complaint must clearly identify the entity against whom it is directed and describe the specific conduct, event, or practice being complained about. Vague, generic, or unsubstantiated submissions are subject to moderation.

3.5 Lawful

The complaint must comply with all applicable laws and regulations in your jurisdiction and in the Republic of Estonia. You may not submit content that is unlawful under any applicable legal framework.

4. WHAT IS FORBIDDEN

The following types of content are strictly prohibited and will be subject to immediate moderation, removal, and potential account suspension:

4.1 False and Fabricated Claims

You may not submit complaints that contain false statements of fact, fabricated events, invented interactions, or information you know to be untrue or that you have no reasonable basis to believe is accurate.

4.2 Defamatory Content

You may not submit content that is defamatory — that is, content that makes false statements of fact that damage the reputation of an entity or individual, and which you know to be false or which you submit with reckless disregard for its truth or falsity.

4.3 Threats, Harassment, and Hate

You may not submit content that contains threats of any kind, personal harassment, hate speech, discriminatory language, or content targeting individuals based on race, ethnicity, religion, gender, sexual orientation, disability, or any other protected characteristic.

4.4 Spam and Duplicate Submissions

You may not submit duplicate complaints, mass submissions, automated filings, or complaints that are clearly designed to artificially inflate the complaint count against any entity rather than to document a genuine individual experience.

4.5 Extortion and Commercial Leverage

You may not use the complaint mechanism as a tool to extract money, benefits, settlements, or concessions from any entity. You may not threaten to file, or offer to withdraw, a complaint in exchange for any form of compensation or benefit. Such conduct may constitute extortion under applicable law and will be reported to the relevant authorities.

4.6 Competitor Attacks

You may not file complaints on behalf of, or at the direction of, a competitor of the entity against whom the complaint is directed. You may not use the Platform as a tool for organised competitive harm, negative review campaigns, or coordinated reputational attacks.

4.7 Personal Data of Third Parties

You may not include in your complaint the personal data of any third party — including names, identification numbers, contact details, financial account numbers, or any other information that identifies or could identify a private individual — without that person’s explicit, informed consent. Complaints containing unlawful personal data disclosures will be moderated and may be reported to the relevant data protection authority.

4.8 Obscene, Offensive, or Irrelevant Content

You may not submit content that is obscene, sexually explicit, gratuitously offensive, or entirely unrelated to the financial services experience being described.

5. USER RESPONSIBILITY

You are solely and exclusively responsible for every aspect of the complaint you submit. This includes, without limitation:

• The factual accuracy and truthfulness of all statements made;
• The lawfulness of the content under all applicable jurisdictions;
• Any legal consequences arising from the publication of your complaint, including but not limited to defamation claims, data protection violations, or regulatory sanctions;
• Any claims brought against you or against the Company as a result of your submission.

The Company does not review complaints before publication and does not assume any editorial responsibility for their content. The act of publishing a complaint on Glofinex.com does not constitute any validation, endorsement, or verification of its contents by the Company.

By submitting a complaint, you irrevocably confirm that:

• Every statement in the complaint is truthful and accurate to the best of your knowledge;
• The complaint is based exclusively on your own direct, first-hand experience;
• You accept full, sole, and perpetual legal responsibility for the content of your complaint;
• You will indemnify and hold harmless the Company from any claim, cost, or liability arising from your submission, in accordance with the Terms of Use.

6. PUBLIC NATURE OF COMPLAINTS

By submitting a complaint on Glofinex.com, you understand and accept that:

• Your complaint will be published publicly on the Platform and may be visible to any person accessing Glofinex.com, including the entity against whom you have complained, their legal representatives, regulatory authorities, journalists, researchers, and the general public.
• Your complaint may be indexed by search engines and may appear in search results associated with the entity named in the complaint.
• Your complaint may be visible indefinitely, subject to the Permanence Policy set out in Section 9 of this Policy and Section 8 of the Terms of Use.
• Your username or such identifying information as is associated with your Account may be displayed alongside your complaint.

You must not submit any complaint unless you are fully prepared for it to be publicly visible in perpetuity. If you have any doubt about the accuracy, lawfulness, or appropriateness of your complaint, do not submit it.

7. NO VERIFICATION, INVESTIGATION, OR ADJUDICATION

Glofinex.com is a passive hosting infrastructure platform. The Company does not, and is not obligated to:

• Verify the accuracy, truthfulness, or factual basis of any complaint before or after publication;
• Investigate the conduct of any entity named in a complaint;
• Mediate, arbitrate, or adjudicate any dispute between a complainant and an entity;
• Take any position on whether a complaint is well-founded, partially founded, or unfounded;
• Contact any entity named in a complaint on behalf of the complainant;
• Monitor outcomes, follow up, or report results to the complainant;
• Guarantee any response, resolution, compensation, or action by the entity named in the complaint.

The publication of a complaint on the Platform does not constitute any finding of fact, ruling, determination, or endorsement by the Company. It is a record of a user’s self-reported experience, published in the public interest, for which the submitting user bears sole responsibility.

8. MODERATION RIGHTS

8.1 Right to Moderate

The Company reserves the right — but not the obligation — to review, flag, edit, restrict, hide, or remove any complaint at any time, at its sole and absolute discretion, without prior notice and without liability to any party. The exercise of this right does not constitute assumption of editorial responsibility for the Platform’s content.

8.2 Grounds for Moderation

Moderation action may be taken where the Company has reason to believe that a complaint:

• Violates any provision of this Complaint Policy or the Terms of Use;
• Contains false, fabricated, or demonstrably inaccurate information;
• Is defamatory, harassing, threatening, hateful, obscene, or otherwise unlawful;
• Contains unlawfully disclosed personal data of third parties;
• Was submitted for the purpose of extortion, competitive harm, or reputational attack;
• Is the subject of a binding court order from a competent Estonian or EU jurisdiction requiring its removal;
• Must be removed to comply with a mandatory legal obligation under applicable EU or Estonian law.

8.3 No Obligation to Moderate

The Company is under no obligation to actively monitor the Platform or to review every complaint submitted. The absence of moderation action does not constitute approval, endorsement, or verification of any complaint’s contents.

8.4 Reporting Mechanism

Any person who believes a complaint violates this Policy may submit a report via https://glofinex.com/contact. The Company will review reports at its sole discretion. Submission of a report does not guarantee any moderation action will be taken.

9. PERMANENCE OF PUBLISHED COMPLAINTS

Glofinex.com operates as a permanent financial transparency ledger. Complaints that comply with this Policy and the Terms of Use are part of that permanent public record.

• A complaint that has been published and does not breach this Policy or the Terms of Use will not be removed, regardless of any request from the submitting user, the entity named in the complaint, third parties, legal representatives, or any other person or organisation.
• No commercial pressure, settlement offer, legal threat, or cease-and-desist letter — unless accompanied by a binding court order from a competent Estonian or EU court — will result in the removal of a compliant complaint.
• By submitting a complaint, you acknowledge and irrevocably accept that it may remain publicly visible on the Platform permanently and indefinitely.
• The only grounds on which the Company may remove a published complaint are those set out in Section 8.2 of this Policy and Section 8.3 of the Terms of Use.

For the full Permanence Policy, including its interaction with the GDPR right to erasure, please refer to Section 8 of the Terms of Use.

10. BRAND RESPONSES

Entities against whom complaints have been filed (“Brand Profiles”) may be given the opportunity to respond publicly to complaints on the Platform. You acknowledge and accept that:

• The Company is not responsible for the content, accuracy, or tone of any response submitted by a Brand Profile;
• The Company does not moderate, verify, or endorse Brand Profile responses;
• A Brand Profile’s response does not constitute a finding of fact or a resolution of the complaint;
• The Company will not adjudicate or take a position on any dispute between a complainant and a Brand Profile arising from a complaint or its response;
• The presence of a Brand Profile response does not affect the permanence of the original complaint.

11. INFORMATION SHARING

By submitting a complaint, you acknowledge that the Company may share information related to your complaint in the following circumstances:

• With the Brand Profile: information contained in or associated with your complaint may be shared with or made visible to the entity against whom the complaint is directed, as part of the normal operation of the Platform.
• With regulatory authorities: the Company may share complaint information with competent financial regulators, supervisory bodies, or other public authorities where it is required or permitted to do so by applicable law, or where it reasonably considers such disclosure to be in the public interest.
• With law enforcement: the Company may disclose complaint information to law enforcement agencies where required by law, by court order, or where the Company reasonably believes disclosure is necessary to prevent or address unlawful conduct.
• With legal advisers: the Company may share complaint information with its legal advisers for the purpose of obtaining legal advice or conducting legal proceedings.

All such sharing will be conducted in accordance with the Privacy Policy and applicable data protection law.

12. NOT AN OFFICIAL LEGAL OR REGULATORY FILING

Submitting a complaint on Glofinex.com is not equivalent to, and does not substitute for, filing a formal complaint, claim, or report with any court, regulatory authority, financial ombudsman, law enforcement agency, or any other official body.

Glofinex.com is a consumer transparency platform, not a legal or regulatory filing system. A complaint published on the Platform:

• Has no legal standing before any court, tribunal, or regulatory authority;
• Does not trigger any formal investigation, enforcement action, or regulatory process;
• Does not constitute evidence in any legal or regulatory proceeding unless independently obtained and admitted through proper legal channels;
• Does not create any legal obligation on the entity named in the complaint to respond, compensate, or take any action;
• Does not suspend, interrupt, or extend any legal deadline, limitation period, or regulatory filing window.

If you believe you have a legal claim or wish to file a formal regulatory complaint, you must do so independently through the appropriate legal or regulatory channels in your jurisdiction. The Company strongly encourages users with legal grievances to seek independent legal advice.

13. AMENDMENTS TO THIS POLICY

The Company reserves the right to amend this Complaint Policy at any time at its sole discretion. Material changes will be notified via the Platform. Your continued use of the complaint submission feature following any amendment constitutes your acceptance of the updated Policy. It is your responsibility to review this Policy periodically.

14. CONTACT

For all enquiries, reports, or requests related to this Complaint Policy, please use our contact form at: https://glofinex.com/contact

TTBCOM OÜ · Sepapaja 6, Tallinn, Estonia, 15551 · Registration No. 16140001

ACKNOWLEDGMENT

BY SUBMITTING A COMPLAINT ON GLOFINEX.COM, YOU CONFIRM THAT YOU HAVE READ, FULLY UNDERSTOOD, AND UNCONDITIONALLY ACCEPT THIS COMPLAINT POLICY. YOU ACCEPT SOLE AND PERPETUAL LEGAL RESPONSIBILITY FOR THE CONTENT OF YOUR SUBMISSION. THE COMPANY BEARS NO RESPONSIBILITY FOR USER-SUBMITTED COMPLAINTS.

TTBCOM OÜ · Glofinex.com · April 14, 2026