PREAMBLE & ACCEPTANCE OF TERMS

These Terms of Use (the “Terms”) constitute a legally binding agreement between you (“User,” “you,” or “your”) and TTBCOM OÜ, a private limited company registered under the laws of the Republic of Estonia (registration number 16140001), having its registered address at Sepapaja 6, Tallinn, Estonia, 15551 (“Company,” “we,” “us,” or “our”), governing your access to and use of Glofinex.com, all subdomains, APIs, and related services (collectively, the “Platform”).

BY ACCESSING, REGISTERING ON, OR USING THE PLATFORM IN ANY MANNER WHATSOEVER, YOU ACKNOWLEDGE THAT YOU HAVE READ, FULLY UNDERSTOOD, AND UNCONDITIONALLY AGREE TO BE BOUND BY THESE TERMS. IF YOU DO NOT AGREE, YOU MUST IMMEDIATELY CEASE ALL USE OF THE PLATFORM.

These Terms apply to all visitors, registered users, and any other persons who access or use the Platform in any capacity. Your continued use of the Platform following any modification to these Terms constitutes your irrevocable acceptance of the revised Terms.

1. DEFINITIONS

Throughout these Terms, the following definitions apply:

• “Account” means the registered user account created on the Platform through the registration process.
• “Brand Profile” means any publicly accessible profile page on the Platform representing a financial institution, regulator, brokerage, bank, investment firm, or other entity.
• “Complaint” means any submission, review, rating, or communication filed by a User through the Platform against or about a Brand Profile.
• “User-Generated Content” or “UGC” means any and all text, data, files, complaints, reviews, comments, ratings, documents, or other material submitted, posted, uploaded, or transmitted through the Platform by any User.
• “Platform” means the website Glofinex.com, all subdomains, APIs, and any related mobile or web applications operated by the Company.
• “Services” means the technical infrastructure and tools made available by the Company through the Platform to enable Users to submit and view complaints.
• “Third Party” means any individual, entity, or organization other than the Company and the relevant User.
• “Personal Data” has the meaning given to it under the EU General Data Protection Regulation 2016/679 (“GDPR”).

2. NATURE OF THE PLATFORM — CRITICAL DISCLAIMERS

2.1 Infrastructure & Hosting Provider Only

Glofinex.com is an independent, neutral, and passive online infrastructure platform. The Company’s sole function is to provide a technical space — servers, software, and hosting infrastructure — that enables registered Users to voluntarily submit, publish, and view complaints and feedback relating to financial institutions, brokerages, banks, investment firms, financial regulators, and similar entities. The Company does not create, author, originate, commission, edit, curate, approve, endorse, verify, or take any editorial position on any User-Generated Content published on the Platform.

2.2 Absolute Disclaimer of Responsibility for User-Generated Content

THE COMPANY BEARS ABSOLUTELY NO RESPONSIBILITY, LIABILITY, OR ACCOUNTABILITY OF ANY NATURE — WHETHER CIVIL, CRIMINAL, REGULATORY, OR OTHERWISE — FOR ANY USER-GENERATED CONTENT SUBMITTED TO OR PUBLISHED ON THE PLATFORM. ALL COMPLAINTS, REVIEWS, RATINGS, STATEMENTS, AND OTHER CONTENT ON THE PLATFORM ARE CREATED EXCLUSIVELY BY USERS AND REPRESENT SOLELY THE PERSONAL OPINIONS AND EXPERIENCES OF THOSE USERS.

The Company is a hosting service provider within the meaning of Article 6 of EU Directive 2000/31/EC (the “E-Commerce Directive”) and, where applicable, the EU Digital Services Act (Regulation (EU) 2022/2065). In accordance with applicable law, the Company is not liable for information stored at the request of a User, provided the Company: (i) has no actual knowledge of illegal activity or content; and (ii) upon obtaining such knowledge, acts expeditiously to remove or disable access to such content.

2.3 No Promotion, Advertising, or Endorsement

THE COMPANY DOES NOT PROMOTE, ADVERTISE, ENDORSE, RECOMMEND, OR FAVOUR ANY FINANCIAL INSTITUTION, PRODUCT, SERVICE, INVESTMENT, REGULATOR, OR ANY OTHER ENTITY, WHETHER LISTED ON THE PLATFORM OR OTHERWISE. THE PRESENCE OF A BRAND PROFILE ON THE PLATFORM DOES NOT CONSTITUTE A RECOMMENDATION, ENDORSEMENT, OR VALIDATION OF THAT ENTITY BY THE COMPANY IN ANY FORM.

2.4 No Investment, Financial, Legal, or Regulatory Advice

NOTHING ON THE PLATFORM CONSTITUTES, OR SHOULD BE CONSTRUED AS, INVESTMENT ADVICE, FINANCIAL ADVICE, LEGAL ADVICE, REGULATORY GUIDANCE, OR ANY OTHER FORM OF PROFESSIONAL ADVICE. THE COMPANY IS NOT A FINANCIAL INSTITUTION, INVESTMENT FIRM, BROKER, REGULATOR, OR PROFESSIONAL ADVISER OF ANY KIND. USERS MUST SEEK INDEPENDENT PROFESSIONAL ADVICE BEFORE MAKING ANY FINANCIAL OR INVESTMENT DECISIONS.

2.5 Free Platform — No Payment by Users

The Platform is provided to Users free of charge. No fees, subscriptions, or payments of any kind are charged to Users for accessing, registering on, or using the Platform in any capacity. Consequently, to the maximum extent permitted by law, the Company’s liability to any User is nil (zero), as no commercial consideration passes between the User and the Company.

2.6 No Dispute Resolution or Adjudication

The Platform does not provide dispute resolution, mediation, arbitration, ombudsman services, or any form of legally binding adjudication. The Company does not investigate complaints, act as an intermediary, or guarantee any response, resolution, compensation, or outcome from any Brand Profile or third party. The act of filing a complaint through the Platform creates no obligation on any party to take action.

2.7 No Guarantee of Accuracy

The Company makes no representation or warranty regarding the accuracy, completeness, reliability, timeliness, or truthfulness of any User-Generated Content. All content is published as submitted by Users and reflects solely their individual experiences and opinions. The Company expressly disclaims any obligation to verify, fact-check, or validate any content.

3. ELIGIBILITY & USER REPRESENTATIONS

By creating an Account or using the Platform, you represent and warrant that:

• You are at least 18 years of age, or the legal age of majority in your jurisdiction, whichever is higher.
• You have full legal capacity and authority to enter into a binding agreement under these Terms.
• You are not prohibited under the laws of any applicable jurisdiction from accessing or using the Platform.
• All information you provide is and will remain accurate, current, complete, and truthful at all times.
• You are using the Platform in your individual capacity and not as a representative of a competing platform or service.
• You have not previously been suspended or terminated from the Platform.

The Company reserves the right to refuse registration or access to any person at its sole and absolute discretion, without providing a reason.

4. ACCOUNT REGISTRATION, SECURITY & DEACTIVATION

4.1 Registration & Accuracy

To access the complaint submission features of the Platform, you must register an Account. You agree to provide accurate, current, and complete information. You may not use a false identity, impersonate any person, or misrepresent your affiliation with any entity.

4.2 Identity Verification

The Company may require identity verification (including submission of government-issued identification) in order to maintain platform integrity, comply with legal obligations, or prevent fraud and abuse. You consent to such verification processes by registering an Account. Your identification data will be handled strictly in accordance with the Privacy Policy set out in Part II of this document.

4.3 Account Security

You are solely and exclusively responsible for maintaining the confidentiality of your login credentials and for all activity occurring under your Account. You agree to notify the Company immediately via https://glofinex.com/contact upon becoming aware of any unauthorized access to your Account. The Company will not be liable for any loss or damage arising from your failure to safeguard your credentials.

4.4 No Account Deletion — Deactivation Only

ACCOUNTS CANNOT BE DELETED. BY REGISTERING ON THE PLATFORM, YOU ACKNOWLEDGE AND IRREVOCABLY ACCEPT THAT YOUR ACCOUNT CANNOT BE FULLY DELETED AT ANY TIME OR FOR ANY REASON.

Glofinex.com operates as a financial transparency ledger — a permanent, immutable public record of consumer complaints relating to the financial industry. The integrity and continuity of this record requires that all accounts and their associated complaint filings remain permanently linked and traceable within the Platform. Full account deletion would sever the authorship chain of published complaints, destroying the evidentiary value and public interest function of the Platform.

Users who no longer wish to participate may request Account Deactivation. A deactivated account will:

• Be immediately suspended from submitting any new complaints, reviews, or content;
• Be prevented from logging in or accessing account management features;
• Remain stored in the Platform’s systems solely to preserve the integrity of previously filed complaints;
• Continue to be associated with all complaints filed prior to deactivation, which shall remain permanently published on the Platform in accordance with Section 8 of these Terms.

Deactivation requests may be submitted via https://glofinex.com/contact and will be processed within a reasonable period. Deactivation does not constitute deletion and does not trigger any right to erasure of associated complaint records, for the reasons set out in Section 8 and Section PP-8 of the Privacy Policy.

4.5 Suspension by the Company

The Company reserves the right, in its sole and absolute discretion and without prior notice or liability, to suspend or restrict your Account for any reason, including without limitation:

• Breach of any provision of these Terms;
• Submission of false, misleading, fraudulent, defamatory, or unlawful Content;
• Conduct that may expose the Company or any third party to legal, regulatory, or reputational risk;
• Conduct that disrupts or harms the integrity or operation of the Platform;
• Any conduct the Company deems, in its sole discretion, to be inappropriate or unacceptable.

Suspension does not relieve you of obligations or liabilities incurred prior to suspension. All provisions that by their nature survive suspension shall continue in full force.

5. USER CONDUCT & PROHIBITED ACTIVITIES

5.1 General Obligations

You agree to use the Platform only for its intended purpose — the good-faith, truthful submission of complaints and feedback based on your genuine, first-hand experience — and in strict compliance with all applicable laws and these Terms.

5.2 Prohibited Activities

You expressly agree not to, and shall not permit any third party to:

• Submit any Content that is false, fabricated, misleading, defamatory, harassing, threatening, obscene, hateful, discriminatory, or unlawful in any jurisdiction.
• File complaints that are vexatious, malicious, commercially motivated, or not based on your own genuine, direct personal experience.
• Use complaints as a tool for extortion, blackmail, competitive harm, or reputational attack campaigns.
• Impersonate any person, entity, or organization, or falsely claim affiliation with any person or entity.
• Use the Platform for any commercial purpose, advertising, promotional content, spam, or unsolicited communications.
• Attempt to gain unauthorized access to any part of the Platform, its systems, servers, or databases.
• Use automated means (bots, scrapers, crawlers, scripts) to access, harvest, copy, or monitor any content from the Platform.
• Upload or transmit viruses, malware, ransomware, or any other malicious or harmful code.
• Engage in any activity that disrupts, overloads, or impairs the Platform or the experience of other users.
• Collect personal data of other users without their explicit, informed consent.
• Circumvent, disable, or interfere with any security or access control measures on the Platform.
• Use the Platform in any manner that could create civil or criminal liability for the Company.

5.3 Content Standards

All User-Generated Content must: (i) be truthful and based on genuine first-hand experience; (ii) comply with all applicable laws and regulations; (iii) not infringe the intellectual property, privacy, or other rights of any third party; and (iv) not contain the personal data of third parties without their explicit consent.

The Company reserves the right — but is under no obligation — to review, moderate, remove, edit, or refuse to publish any User-Generated Content, at any time, at its sole discretion and without notice or liability. Exercise of this right shall not be construed as assumption of editorial responsibility for the Platform’s content.

6. USER-GENERATED CONTENT — FULL LIABILITY DISCLAIMER & INDEMNITY

6.1 You Are the Author — Not the Company

All User-Generated Content published on the Platform is created exclusively by Users. The Company does not author, co-author, edit, commission, approve, or endorse any User-Generated Content. The User who submits Content bears sole and exclusive legal responsibility for that Content and all consequences arising from its publication.

6.2 Company Has No Liability for UGC

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY ACCEPTS NO LIABILITY WHATSOEVER FOR ANY USER-GENERATED CONTENT PUBLISHED ON THE PLATFORM, INCLUDING BUT NOT LIMITED TO: DEFAMATORY STATEMENTS, INACCURATE INFORMATION, HARMFUL CONTENT, INTELLECTUAL PROPERTY INFRINGEMENT, PRIVACY VIOLATIONS, OR ANY OTHER HARM CAUSED BY SUCH CONTENT TO ANY PERSON OR ENTITY.

6.3 Licence Granted to Company

By submitting Content to the Platform, you grant the Company a worldwide, royalty-free, perpetual, irrevocable, sublicensable, non-exclusive licence to use, reproduce, modify, adapt, publish, translate, and distribute such Content in connection with the operation and promotion of the Platform. This licence survives deactivation of your Account.

6.4 You Retain Ownership

You retain ownership of your Content. You represent and warrant that you own, or have all necessary rights to submit, the Content and to grant the licence above, and that your Content does not infringe any third-party rights.

6.5 Indemnification for UGC

YOU AGREE TO FULLY DEFEND, INDEMNIFY, AND HOLD HARMLESS THE COMPANY, ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, AND AFFILIATES FROM AND AGAINST ANY AND ALL CLAIMS, LIABILITIES, DAMAGES, LOSSES, COSTS, AND LEGAL FEES ARISING FROM OR RELATED TO: (I) THE CONTENT YOU SUBMIT; (II) YOUR USE OF THE PLATFORM; (III) YOUR VIOLATION OF THESE TERMS; (IV) YOUR VIOLATION OF ANY THIRD-PARTY RIGHTS; OR (V) ANY COMPLAINT YOU FILE THROUGH THE PLATFORM.

7. COMPLAINTS SUBMISSION — KEY PROVISIONS

A full and dedicated Complaints Policy is published separately on the Platform and forms part of these Terms. The following key provisions apply to all complaint submissions:

• By submitting a complaint, you solemnly confirm that all information is truthful, accurate, and based exclusively on your own direct, personal experience.
• You acknowledge that the Company does not verify, investigate, adjudicate, or bear any responsibility for the accuracy, legality, or consequences of any complaint.
• You acknowledge that the Company does not act as mediator, arbitrator, ombudsman, or legal representative in connection with any complaint.
• The Company may publish, moderate, edit, or remove any complaint at its sole discretion without notice or liability.
• Brand Profiles may respond publicly to complaints. The Company bears no responsibility for such responses.
• The Company reserves the right to share complaint information with the relevant Brand Profile, competent regulatory authorities, or law enforcement where required by applicable law or deemed necessary by the Company.
• Filing a complaint through the Platform does not constitute the filing of a formal legal or regulatory complaint with any authority.
• Complaints that do not violate these Terms or the Complaints Policy will NOT be removed under any circumstances, including in response to requests from Brand Profiles, third parties, legal threats not supported by a binding court order, or commercial pressure of any kind. See Section 8 for the full Permanence Policy.
• The Company may remove complaints solely where they are found to be in clear breach of these Terms (e.g. false, defamatory, in violation of a binding court order) — and only at its sole discretion. No other grounds for removal are recognised.

8. FINANCIAL TRANSPARENCY LEDGER — PERMANENCE POLICY

8.1 Nature as a Permanent Public Record

Glofinex.com is designed and operated as a financial transparency ledger — a permanent, immutable, publicly accessible record of consumer complaints and experiences relating to the global financial industry. The Platform’s core public interest function depends on the permanence, continuity, and integrity of its records. Users, regulators, researchers, journalists, and the general public must be able to rely on the completeness and persistence of the complaint record.

8.2 Complaints Cannot Be Deleted

ONCE A COMPLAINT HAS BEEN SUBMITTED AND PUBLISHED ON THE PLATFORM, IT IS PERMANENT. COMPLAINTS WILL NOT BE DELETED, REMOVED, HIDDEN, SUPPRESSED, OR MADE INACCESSIBLE — FOR ANY REASON — AS LONG AS THEY DO NOT BREACH THESE TERMS OR THE COMPLAINTS POLICY.

This permanence policy applies absolutely and without exception to:

• Requests from the User who filed the complaint;
• Requests from the Brand Profile or entity against whom the complaint was filed;
• Requests from third parties, legal representatives, public relations firms, or reputation management services acting on behalf of any entity;
• Commercial pressure, negotiations, or settlement offers;
• Unsubstantiated legal threats or cease-and-desist letters not accompanied by a binding court order from a competent Estonian or EU jurisdiction;
• Any other request, demand, or pressure of any nature.

8.3 The Only Grounds for Removal

The Company may, in its sole discretion, remove or restrict access to a complaint only in the following limited circumstances:

• The complaint is found to be in clear and demonstrable breach of these Terms (e.g. contains provably false information, constitutes unlawful defamation, or was submitted through fraudulent means);
• A binding, final court order from a court of competent jurisdiction in Estonia or the European Union expressly requires its removal;
• Removal is required to comply with a mandatory legal obligation under applicable EU or Estonian law.

Even in such cases, the Company retains sole discretion over the form and extent of any removal or restriction. The Company accepts no liability to any party for its decision to remove or retain any content.

8.4 Pre-Submission Acknowledgment

By submitting any complaint, you expressly acknowledge and irrevocably agree that:

• You have read and understood this Permanence Policy;
• The complaint, once published, may remain on the Platform permanently and indefinitely;
• You will not request removal of a complaint except on the grounds set out in Section 8.3;
• You accept full and sole legal responsibility for the content of your complaint in perpetuity.

8.5 Interaction with GDPR Right to Erasure

The Company acknowledges that under GDPR Article 17, individuals have a right to request erasure of their Personal Data in certain circumstances. However, this right is not absolute. The right to erasure does not apply where processing is necessary for: (i) compliance with a legal obligation (Art. 17(3)(b)); (ii) the performance of a task carried out in the public interest (Art. 17(3)(e)); or (iii) the establishment, exercise, or defence of legal claims (Art. 17(3)(e)).

The Company considers the operation of a financial transparency ledger to constitute a task in the substantial public interest, and reserves its right to decline erasure requests where the removal of complaint records would undermine the integrity and public interest function of the Platform. Each erasure request will be assessed on its individual merits. Where a right to erasure is recognised, the Company will comply to the extent legally required while minimising impact on the Platform record (for example, by anonymising rather than deleting records where possible).

9. INTELLECTUAL PROPERTY RIGHTS

9.1 Company Ownership

The Platform and all its content, features, and functionality — including all software, design, graphics, text, data compilations, logos, and underlying code — are and shall remain the exclusive property of the Company or its licensors, protected by copyright, trademark, database rights, and other applicable intellectual property laws.

9.2 Limited User Licence

You are granted a limited, personal, non-exclusive, non-transferable, revocable licence to access and use the Platform solely for its intended personal, non-commercial purpose in accordance with these Terms. No other rights are granted. You may not copy, reproduce, distribute, sell, sublicense, modify, reverse-engineer, or exploit any part of the Platform without prior written consent from the Company.

9.3 Brand Profiles

Brand Profiles on the Platform may reference the names, logos, or trademarks of third-party entities for identification purposes only. Such references do not imply any affiliation, endorsement, partnership, or authorisation by those entities. All third-party trademarks are the property of their respective owners.

10. DISCLAIMERS OF WARRANTIES

THE PLATFORM AND ALL SERVICES ARE PROVIDED STRICTLY ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITH NO WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMITTED BY LAW, THE COMPANY EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING:

• Any implied warranties of merchantability, fitness for a particular purpose, title, accuracy, or non-infringement;
• That the Platform will be uninterrupted, timely, secure, virus-free, or error-free;
• That any information obtained through the Platform will be accurate, reliable, complete, or current;
• That any defects or errors in the Platform will be corrected;
• That any complaint filed through the Platform will result in any action, response, resolution, or outcome by any third party;
• That any Brand Profile listed on the Platform is legitimate, regulated, compliant, or trustworthy.

11. LIMITATION OF LIABILITY

11.1 Zero Monetary Liability

AS THE PLATFORM IS PROVIDED ENTIRELY FREE OF CHARGE AND NO FEES OR PAYMENTS ARE COLLECTED FROM USERS, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY’S TOTAL CUMULATIVE LIABILITY TO ANY USER FOR ALL CLAIMS OF ANY NATURE ARISING OUT OF OR RELATING TO THESE TERMS, THE PLATFORM, OR THE SERVICES IS ZERO (€0.00 / NIL).

11.2 Exclusion of Consequential Damages

IN NO EVENT SHALL THE COMPANY, ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, LICENSORS, OR AFFILIATES BE LIABLE FOR ANY: (I) INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES; (II) LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OR BUSINESS OPPORTUNITY; (III) LOSS OR CORRUPTION OF DATA; (IV) PERSONAL INJURY OR PROPERTY DAMAGE; OR (V) ANY OTHER INTANGIBLE LOSSES — HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY (CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE), EVEN IF THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

11.3 Third-Party Actions

The Company is not liable for the actions, omissions, decisions, or conduct of any Brand Profile, financial institution, regulator, or other third party, whether or not a complaint has been filed against them through the Platform.

11.4 User-Generated Content

The Company is not liable for any harm, loss, damage, or legal consequences suffered by any User, Brand Profile, or third party as a result of any User-Generated Content published on the Platform. The publishing User bears sole responsibility.

11.5 Platform Availability

The Company is not liable for any loss or damage caused by the unavailability, suspension, modification, or discontinuation of the Platform or any of its features, at any time and for any reason.

12. INDEMNIFICATION

You agree to defend, indemnify, and hold harmless the Company, its parent, subsidiaries, affiliates, officers, directors, employees, agents, licensors, and service providers from and against any and all claims, liabilities, damages, judgments, awards, losses, costs, expenses, and fees (including reasonable legal fees) arising out of or in connection with:

• Any Content you submit, post, upload, or transmit through the Platform;
• Any complaint you file and the consequences thereof;
• Your violation of any provision of these Terms;
• Your violation of any applicable law, regulation, or third-party right (including intellectual property rights, privacy rights, or defamation law);
• Your use or misuse of the Platform or Services;
• Any claim by a Brand Profile, financial institution, or regulator arising from your complaint.

The Company may, at its option, assume exclusive control of the defence of any matter subject to indemnification, at your expense. You agree to cooperate fully with the Company’s defence of such claims.

13. THIRD-PARTY LINKS & EXTERNAL CONTENT

The Platform may contain links to third-party websites or services. The Company has no control over and assumes no responsibility for the content, privacy policies, practices, accuracy, or availability of any third-party websites. Links do not constitute endorsement. You access third-party sites at your own risk. The Company shall not be liable for any damage or loss arising from your use of any third-party services or content.

14. MODIFICATIONS TO TERMS & PLATFORM

The Company reserves the right to modify these Terms at any time at its sole discretion. Where required by law, notice of material changes will be provided via the Platform or other appropriate means. Your continued use of the Platform following any modification constitutes binding acceptance of the updated Terms. If you do not agree to updated Terms, you must immediately discontinue use of the Platform. The Company may modify, suspend, withdraw, or discontinue any aspect of the Platform at any time without notice or liability.

15. GOVERNING LAW & DISPUTE RESOLUTION

15.1 Governing Law

These Terms and any dispute or claim arising out of or in connection with them shall be governed by and construed exclusively in accordance with the laws of the Republic of Estonia, without regard to conflict of law principles.

15.2 Exclusive Jurisdiction

Any disputes arising under or in connection with these Terms or the Platform shall be subject to the exclusive jurisdiction of the courts of Tallinn, Estonia. You irrevocably submit to the personal jurisdiction of such courts and waive any objection to venue.

15.3 Mandatory Informal Resolution

Before initiating any legal or regulatory proceedings against the Company, you agree to contact the Company via https://glofinex.com/contact and make a genuine, good-faith effort to resolve the dispute informally for a minimum period of sixty (60) days from the date of written notice.

15.4 Class Action Waiver

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, YOU WAIVE YOUR RIGHT TO PARTICIPATE AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS ACTION, COLLECTIVE ACTION, MASS ACTION, OR REPRESENTATIVE PROCEEDING AGAINST THE COMPANY.

16. GENERAL PROVISIONS

16.1 Entire Agreement

These Terms, together with the Privacy Policy (Part II) and the Complaints Policy published on the Platform, constitute the entire agreement between you and the Company regarding your use of the Platform, superseding all prior agreements and understandings.

16.2 Severability

If any provision of these Terms is found invalid, illegal, or unenforceable, it shall be modified to the minimum extent necessary, and the remaining provisions shall remain in full force and effect.

16.3 No Waiver

The Company’s failure to enforce any right or provision shall not constitute a waiver. Any waiver must be in writing and signed by an authorised representative of the Company.

16.4 Assignment

You may not assign these Terms or any rights hereunder without the Company’s prior written consent. The Company may freely assign these Terms without restriction, including in connection with a merger, acquisition, or sale of assets.

16.5 Force Majeure

The Company shall not be liable for any delay or failure to perform resulting from causes beyond its reasonable control, including acts of God, cyberattacks, war, government actions, pandemics, internet infrastructure failures, or other force majeure events.

16.6 Relationship of Parties

Nothing in these Terms creates any partnership, joint venture, employment, agency, or fiduciary relationship between you and the Company.

16.7 Language

These Terms are drafted in English. In the event of any conflict between a translated version and the English version, the English version shall prevail.

16.8 Contact

For all enquiries regarding these Terms, please use our contact form at: https://glofinex.com/contact

PART II — PRIVACY POLICY

Glofinex.com · TTBCOM OÜ · Effective: April 14, 2026

PP-1. DATA CONTROLLER & INTRODUCTION

TTBCOM OÜ (registration number 16140001), Sepapaja 6, Tallinn, Estonia, 15551, is the Data Controller of all Personal Data collected through Glofinex.com. We are fully committed to protecting your privacy in compliance with the EU General Data Protection Regulation (GDPR) 2016/679, the Estonian Personal Data Protection Act, and all other applicable data protection legislation.

Data protection contact form: https://glofinex.com/contact

PP-2. DATA WE COLLECT

PP-2.1 Data You Provide Directly

• Registration data: full name, email address, username, hashed password.
• Identity verification data: government-issued identification documents, where required for account verification.
• Complaint data: the full content of complaints and any supporting documentation you voluntarily attach.
• Communications: any messages, emails, or correspondence you send to us.

PP-2.2 Data Collected Automatically

• Technical data: IP address, browser type and version, operating system, device identifiers, referral URLs.
• Usage data: pages visited, features used, session duration, timestamps, clickstream data.
• Cookies and similar tracking technologies (see Section PP-7).

PP-2.3 Data From Third Parties

We may receive data about you from identity verification providers, fraud prevention services, and analytics partners, where permitted by applicable law and strictly as necessary.

PP-3. PURPOSES & LEGAL BASIS FOR PROCESSING

We process your Personal Data for the following purposes, each supported by the specified legal basis under GDPR Article 6:

• Account creation and management — Art. 6(1)(b): performance of contract.
• Providing and operating the Platform and Services — Art. 6(1)(b): performance of contract.
• Identity verification and fraud/abuse prevention — Art. 6(1)(c) and (f): legal obligation and legitimate interests.
• Publishing and managing complaint submissions — Art. 6(1)(b) and (f): performance of contract and legitimate interests.
• Compliance with legal and regulatory obligations — Art. 6(1)(c): legal obligation.
• Customer support and communications — Art. 6(1)(b) and (f): performance of contract and legitimate interests.
• Platform security and integrity — Art. 6(1)(f): legitimate interests.
• Analytics and platform improvement — Art. 6(1)(f): legitimate interests.
• Service-related notifications — Art. 6(1)(b): performance of contract.
• Marketing communications (where opted-in) — Art. 6(1)(a): consent. Consent may be withdrawn at any time.

PP-4. DATA SHARING & DISCLOSURE

We do not sell, rent, or trade your Personal Data. We may share your Personal Data only as follows:

• Service providers: third-party vendors (hosting, analytics, email delivery, identity verification) under strict Data Processing Agreements compliant with GDPR Article 28.
• Brand Profiles: where you file a complaint, information related to that complaint (but not necessarily your full identity, unless legally required or consented to) may be visible to or shared with the relevant Brand Profile.
• Legal authorities: we may disclose Personal Data to law enforcement, regulatory bodies, or courts where required by applicable law, court order, or where reasonably necessary to protect our rights or the safety of others.
• Business transfers: in the event of a merger, acquisition, or asset sale, Personal Data may be transferred subject to equivalent privacy protections and notification to affected users.
• Professional advisers: lawyers, auditors, and insurers, strictly as necessary for business operations and under obligations of confidentiality.

PP-5. INTERNATIONAL DATA TRANSFERS

As an Estonian company, your data is primarily processed within the European Economic Area (EEA). Where transfers outside the EEA are necessary, we ensure appropriate safeguards are in place in compliance with GDPR Chapter V, including EU Standard Contractual Clauses (SCCs) or applicable adequacy decisions.

PP-6. DATA RETENTION

We retain Personal Data only as long as necessary for the purposes for which it was collected and as required by law:

• Account data: retained for the duration of your Account and up to 5 years post-closure for legal and compliance purposes.
• Complaint data: retained for up to 7 years to meet legal, regulatory, and evidentiary obligations.
• Identity verification documents: retained for the period required by applicable AML/KYC regulations.
• Communication data: up to 3 years from the date of the communication.
• Technical/usage data: up to 2 years.

After the applicable retention period, Personal Data is securely deleted or irreversibly anonymised.

PP-7. COOKIES & TRACKING TECHNOLOGIES

We use cookies and similar technologies to operate and improve the Platform. Types used:

• Strictly necessary cookies: essential for Platform functionality. Cannot be disabled without impairing the Platform.
• Analytics cookies: help us understand user behaviour (e.g. Google Analytics). Used on the basis of your consent.
• Functional cookies: remember preferences and settings. Used on the basis of legitimate interests or consent.

You may manage cookie preferences via your browser settings or our cookie consent tool. Disabling certain cookies may impair Platform functionality.

PP-8. YOUR RIGHTS UNDER GDPR

As a data subject, you have the following rights, exercisable by submitting a request via our contact form at https://glofinex.com/contact:

• Right of Access (Art. 15): obtain a copy of Personal Data we hold about you.
• Right to Rectification (Art. 16): request correction of inaccurate or incomplete data.
• Right to Erasure (Art. 17): request deletion of your Personal Data where there is no legitimate basis for continued processing. Please note that this right does not apply to complaint records published on the Platform, which are retained as part of the financial transparency ledger in the substantial public interest. See Section 8.5 of the Terms of Use for full details.
• Right to Restriction (Art. 18): request limitation of processing in certain circumstances.
• Right to Data Portability (Art. 20): receive your data in a structured, machine-readable format.
• Right to Object (Art. 21): object to processing based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: withdraw consent at any time without affecting prior lawful processing.
• Right to Lodge a Complaint: contact the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at www.aki.ee, or the supervisory authority of your country of residence.

We will respond to verified requests within 30 days. In complex cases, this may be extended by up to 60 additional days with notice.

PP-9. DATA SECURITY

We implement appropriate technical and organisational measures to protect Personal Data against unauthorised access, accidental loss, destruction, or alteration. Measures include:

• Encryption in transit (TLS/SSL) and at rest.
• Role-based access controls and staff data protection training.
• Regular security assessments and vulnerability testing.
• Data breach response procedures in compliance with GDPR Articles 33–34.

No electronic transmission method is 100% secure. While we apply industry-standard measures, we cannot guarantee absolute security.

PP-10. MINORS

The Platform is not directed at individuals under 18 years of age. We do not knowingly collect Personal Data from minors. If we become aware of such collection, we will promptly delete the relevant data.

PP-11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy at any time. Material changes will be notified via the Platform or by other appropriate means with a revised effective date. Continued use of the Platform after changes constitutes acceptance of the updated Policy.

PP-12. CONTACT & DATA PROTECTION

For all privacy enquiries, GDPR requests, or data complaints, please use our contact form:

TTBCOM OÜ — Data Protection Contact
Contact: https://glofinex.com/contact
Address: Sepapaja 6, Tallinn, Estonia, 15551
Registration No.: 16140001

Supervisory Authority: Andmekaitse Inspektsioon (Estonian DPA) · www.aki.ee · info@aki.ee

ACKNOWLEDGMENT

BY USING GLOFINEX.COM, YOU CONFIRM THAT YOU HAVE READ, FULLY UNDERSTOOD, AND UNCONDITIONALLY AGREE TO THESE TERMS OF USE AND PRIVACY POLICY. THESE DOCUMENTS ARE LEGALLY BINDING. THE COMPANY PROVIDES INFRASTRUCTURE ONLY AND BEARS ZERO LIABILITY FOR USER-GENERATED CONTENT.

TTBCOM OÜ · Glofinex.com · April 14, 2026