1. Introduction

1. Welcome to our Terms and Conditions for ETFmatic users (“Terms”). They are important so please
   read them carefully and ensure that you properly understand them prior to using our Services. If you
   have any questions please contact us for further information. You can email us at info@aion.be or
   contact us by post or telephone using the details on our Website. References to “us”, “we” and “our”
   mean Aion Bank SA/NV and any of its holding companies, subsidiary companies and all the subsidiary
   companies of such holding companies. The terms “client”, “you” and “your” mean the person or company
   having an account with us and, where applicable, their duly authorised representatives, legal
   representatives and successors.
2. These Terms together with (i) the information you provide to us in writing via our Website, Applications
   or otherwise, including information regarding your financial circumstances, financial knowledge and
   investment experience, attitude to risk and investment objectives (“Account”), (ii) our
   Security Policy, (iii) our Cookie Policy and (iv) our Privacy Policy constitute the investment
   management agreement (“Agreement”) which governs Aion Bank’s provision of investment services
   (“Services”) to you.
3. Aion Bank SA/NV is a credit institution incorporated as a limited liability company (“société
   anonyme”/”naamloze vennootschap”) under the laws of Belgium, having its registered office at Avenue
   du Boulevard 21, 1210 Brussels, Belgium, and registered with the Crossroad
   Bank of Enterprises under number 0403.199.306.

2. Commencement

1. This Agreement will become legally binding and we will start providing the Services to you as soon as
   you have passed our know your customer (“KYC”) and anti-money laundering (“AML”) checks. We’re
   obligated to run these checks by law.
2. For reasons beyond our control (e.g. your bank, location, method of payment etc.) it may take a few days
   for your money to reach us. So don’t worry if there’s a delay! We’ll confirm receipt of your money
   via email and via an in-app notification.
3. We do not provide advice. We will use our discretion to make investments on your behalf by acting on
   the information you have provided or will provide to us from time to time.
4. By entering this Agreement you acknowledge that there are risks associated with investing, and that
   you accept those risks. Below we have listed some of the most common risks associated with our
   proposition. This is not a comprehensive list of all the risks to which investors might be exposed –
   there may be others that exist now, or which may arise in future.
   1. Past performance is not an indicator of future performance;
   2. The value of investments may go down as well as up;
   3. You are not certain to make a profit;
   4. You may make a loss;
   5. You may lose your entire investment;
   6. The price or value of investments may fluctuate significantly; and
   7. Any income distributions may fluctuate significantly.

3. Eligibility

1. We offer our Services to residents in the European Economic Area (“EEA”), provided they are not also
   tax residents in the United States of America.
2. To open an Account with us, you must be a natural person over 18 and a named holder of a bank account
   (“Bank Account”).

4. Our Services

1. Under these Terms, we will provide you with some or all of the following services:
   1. Discretionary portfolio management;
   2. Safe custody of your assets;
   3. Trade execution.
2.  In conjunction with additional terms and conditions we may provide you with the Portfolio Gliding.

5. Discretionary Portfolio Management

1. We will manage your portfolio(s) (“Goal(s)”) in accordance with the instructions you provide us
   with so long as they are clear, reasonable and consistent with any applicable laws. Where we can act
   on your instructions we will do so promptly and with reasonable care and skill. We have the right to
   treat any information that you provide us with as accurate and complete. You may change your
   information at any time by updating the settings in your Account or by contacting us directly.
2. You authorise us to enter into any type of arrangement or transaction on your behalf and to invest
   any amount or any proportion of your Goal in any one investment or investment type, and we may do so
   in any currency and on any market. We reserve the right to exercise our discretion when deciding on
   or altering your asset allocation and/or instrument selection, and you acknowledge that we may make
   common investment decisions, which apply to a number of client Goals, including yours.
3. When you have more than one active Goal with us and you send us money without informing us of which Goal
   you would like to fund, we shall select one for you and allocate the funds accordingly.

6. Trade Execution

1. The base currency of your Goal will be:
   1. GBP if you choose to operate your portfolio in GBP;
   2. EUR if you choose to operate your portfolio in EUR; and/or
   3. USD if you choose to operate your portfolio in USD.
2. We invest primarily in Exchange Traded Products (“ETPs”) such as Exchange Traded Funds (“ETFs”),
   Exchange Traded Notes (“ETNs”) Equities and Bonds.
3. We will invest in ETPs that have the same base currency as the currency you have selected for your
   Goal (i.e. GBP, EUR or USD). However, it is important to note that although the instruments’ base
   currency will match the currency you have selected for your Goal, the underlying securities held by
   the ETP could be in any region, country or currency.

7. Personal Information

1. For the purposes of the General Data Protection Regulation, (Regulation (EU) 2016/679) (“GDPR”),
   the data controller is Aion Bank SA/NV. We are committed to protecting and respecting your privacy. For a
   detailed view of our practices and how we achieve compliance with data protection laws and
   regulations please read our privacy policy (available on our Website) applying at the relevant time
   when your information is being collected (“Privacy Policy”) and which is incorporated into this
   Agreement by reference.
2. Consistent with Anti-Money Laundering Regulations and to provide you with services, we collect, use,
   share and store certain information about you including personal information. We may use this
   information in order to carry out electronic searches on private and public databases. We will keep
   records of any information we obtain. We may use credit reference agencies which will record that we
   have made an enquiry about you. Such credit reference agencies may record, use and share any
   information we give them about you with other financial institutions, organisations and fraud
   prevention agencies, as the case may be. By entering into this Agreement, you agree to our use of
   credit reference agencies.
3. We make every effort to protect the privacy of your personal information. Other than as set out
   elsewhere in this Agreement or required under any law, rule or regulation and in accordance with our
   Privacy Policy, we will not disclose, sell or transfer your personal information to any third party.
4. You authorise us to use your personal information to provide our services to you in accordance with
   our Privacy Policy. We will record your personal information in a form that permits your
   identification for five (5) years and, in certain cases (for example, regulatory requirements), we
   may store your personal data for a longer period. We will not store your personal data for longer
   than is required by law. Your personal information may be processed by or transferred or disclosed to
   and/or by us, our suppliers, subcontractors and third parties (such as to Stock Exchanges, your
   financial advisor (if any) or regulators).
5. In some instances, we may require you to provide us with additional information and/or documents. You
   agree to provide us with such information and/or documents within a reasonable period of time. You
   agree that, if you do not provide us with the information/documents that we request from you, we may
   suspend your Account or take any other action against you in respect of your Account as necessary for
   us to further our legitimate business purpose or comply with any relevant law, rule or regulation.
6. We only use cookies in accordance with our Use of Cookies policy, which is incorporated into this
   Agreement by reference.
7. We may transfer your personal information outside of the European Economic Area (“EEA”) only
   in accordance with our Privacy Policy.
8. We may use your personal information to provide you with an improved user experience and/or
   further information and/or marketing materials. You have the right to ask us not to process your
   personal data for marketing purposes and you may exercise this right at any time by amending your
   preferences in your Account via the Website or Applications or by notifying us directly.
9. You can request copies of your personal information that we hold or that are held by any of the
   service provider we work with by communicating with us directly. We may charge a fee for providing
   you with this information, as permitted by the relevant jurisdiction’s law and regulation. Our
   current fee is published in the section Fees and Charges of this Agreement.
10. You agree to ensure that the personal information we hold on you is up to date and accurate. For
    further details in respect of our reasons and procedures for collecting, using, sharing and storing
    your personal information, please review our Privacy Policy.

8. ‘Retail Client’ Status

1. We will provide our services on the basis that you are a Retail Client as defined in the
   Directive 2014/65/EU on markets in financial instruments (“MiFID II”). This means that you are
   entitled to the protections provided for Retail Clients under the MiFID II rules and under relevant
   national legislation. If you would like further information on the nature of these protections,
   please contact us.

9. Communication

1. We may communicate with you from time to time including by telephone, email, app notification or by
   “text” / SMS message. All communications between you and us will be in the English language.
2. We may act on any communication that we believe to be from you without first acknowledging receipt
   nor carrying out any verification processes. We will not be liable for acting on a disingenuous or
   fraudulent request. We will not be liable for any loss arising from any error of transmission or
   misunderstanding, or from the fraud of any other party unless caused by our negligence, wilful
   default or fraud.
3. You will be solely liable for any and all losses arising from unauthorised transactions where:
   1. You have with intent or gross negligence compromised the security of your Account or failed
      to comply with your obligations to use your Account in a way prescribed by this Agreement; or
   2. You fail to notify us about an unauthorised or incorrect transaction within twelve (12) months
      of the date of that transaction.
4. We may record and monitor our telephone conversations with you. We will store recordings for at least
   the period required by law and not for longer than is necessary with regards to the purposes for
   which they are being processed in accordance with our Privacy Policy.
5. We cannot guarantee that electronic communications to you from us will be successfully delivered, or
   that they will be secure, uncorrupted, untampered and virus free. We will not be liable, in
   circumstances beyond our reasonable control, for any loss, damage, expense, harm or inconvenience
   caused as a result of an email being lost, not delivered, delayed, intercepted, corrupted or
   otherwise altered.
6. You may request a copy of any legally required disclosures (including this Agreement) from us.
   Following request, we will provide it to you in a form which allows for storage and reproducing of
   the information (including by email).
7. You may request that we stop sending you notifications. However if you request that we stop sending you
   any of the notifications that we deem necessary for the provision of our services to you, we reserve
   the right to terminate this Agreement and with it your Account. You may amend your preferences in
   respect of which electronic communications you want to receive at any time by logging in to your
   Account and using the tool available for this purpose.
   1. We will send all notices, information and other correspondence to you by email at the email
      address you have provided in your Account (and such other email address as you may designate
      from time to time) or by sending you a “text” / SMS message. You must have internet access
      and an active email account to receive communications and information (including notices)
      relating to your Account. With the exception of amendments to this Agreement, any notice will
      be considered to have been received by you twenty-four (24) hours after the time at which it
      is posted on our Website, emailed or texted to you. In the event that any notice, information
      or other correspondence is sent to you by post, the letter will be sent to the current postal
      address which you have recorded in your Account and will be deemed to be delivered:
      1. For Belgian residents, on the second business day after posting; or
      2. For residents of any other country, on the fifth business day after posting.

10. Account Security

1. We take security seriously, and we advise that you do too. Among other things, you are responsible for:
   1. Frequently changing your password;
   2. Notifying us immediately should you have reason to suspect that your Account is being
      accessed without your permission and/or that a transaction is incorrect;
   3. Ensuring that you follow sound online practices for creating and/or storing your passwords;
   4. Enabling 2­-step authentication for accessing your Account;
   5. Notifying us immediately should you suspect an email address that you have provided us with
      has become compromised; and,
   6. Taking all reasonable steps to ensure that no one accesses your account without permission.

11. Third Parties

1. You may request that third parties be permitted to access your Account to provide services to you,
   including account information services (“AIS”) and/or payment initiation services (“PIS”). You
   acknowledge that should you do so, we may disclose certain information about your Account to it. We
   are not responsible for any third party’s use of your Account, or any information that we share with
   it. Giving permission to a third party does not relieve you of your responsibilities under this
   Agreement.
2. We may refuse a third-party’s access to your Account if we have reason to suspect it is not acting in
   your best interests.
3. We will notify you if:
   1. We have reasons to believe that the security of your Account has become compromised;
   2. We have reasonable concerns or suspicions about a third party’s access to your account;
   3. We refuse access to one, some or all of the third parties who you have requested access for.
4. We reserve the right to perform any of our obligations to you through the agency of an associate or
   any third party of our choosing. We will take all reasonable steps to ensure that any third party
   that we appoint to provide a service to you is competent.

12. Notices

1. Providing notice to us in respect of this Agreement must be made by email or by post using the details
   on our Website.

13. Client Money

1. We will take reasonable steps to identify a bank with a competitive interest rate (determined by that
   bank) and deposit any of your uninvested money with that bank (the “Deposit Bank”), together with
   other clients’ money. You acknowledge that we also may decide to deposit the client money on our Aion
   Bank accounts and act as the Deposit Bank. We will exercise due skill, care and diligence and review
   periodically the adequacy and appropriateness of the Deposit Bank or any other bank/credit
   institution where your money is deposited and of our arrangements with it. We will not be responsible
   for any acts, omissions or default of a bank/credit institution chosen other than for exercising care
   in its choice and/or monitoring.
2. You accept that your money may get deposited in an account with our other clients’ money and, if so,
   you will not have a claim for a specific sum in a specific account. In such an event, given that your
   claim would be against the pool, if there is a shortfall, you would share pro rata in that loss.
3. We will inform you from time to time of the amount credited to your Account (determined by the Deposit
   Bank and us). No interest will accrue on your Account and you accept that we are not under any
   obligation to pay interest on any amount credited to your Account.
4. We reserve the right to pay away your client money balance to a registered charity of our choice if the
   balance is of 25 EUR/GBP/USD or less, those balances remain unclaimed at least six years following the
   last movement on your account and we have taken reasonable steps to trace you and you have not responded to such communication within 28 days of the communication having been made. As a result the released balance will cease to be client money.
5. We are under no obligation to tell you before terminating our relationship with the Deposit Bank
   and appointing a replacement.

14. Compensation Scheme

1. Aion Bank is a member of the Belgian Guarantee Fund.
2. All sums held in accounts with Aion, savings certificates and financial instruments are respectively
   protected under deposit guarantee and investor compensation schemes:
   1. All sums held in accounts with the Aion Bank and savings certificates are covered by the Guarantee
      Fund up to EUR 100.000 (regardless of the currency) per depositor; and
   2. Financial instruments are covered by the Guarantee Fund up to EUR 20.000 (regardless of the
      currency of the financial instruments).
3. For more information, please consult: https://www.fondsdegarantie.belgium.be/fr (French version)
   or https://garantiefonds.belgium.be/nl (Dutch version).

15. Client Assets

1. Client Assets are segregated in special bank or custody accounts, which are designated for the
   exclusive benefit of our clients. By properly segregating the client’s assets, if no money or stock
   is borrowed and no futures positions are held, the client’s assets are available to be returned to
   the client in the event of the company’s default. Aion Bank reserves the right to decide whether it will
   carry out an asset transfer, or whether it will liquidate the client’s portfolio and return cash. For
   the removal of doubt, should Aion decide to return cash it will not assume any of the client’s tax
   liabilities.

16. Your Investment Profile

1. You will provide us with information about yourself, your attitude to risk, your goals and your attitude
   to savings and investments by answering a series of questions on our Website or Applications. You
   must update such information as necessary.

17. Investment Thresholds

1. We require a minimum Account value of £1,000 / €1,000 / $1,000. If you subsequently withdraw money to
   bring the value of your Account below that minimum investment, we reserve the right to sell your
   assets and to hold your investment as cash, or to return the proceeds to you. For the removal of
   doubt, one may have several portfolios with values less than £1,000 / €1,000 / $1,000 provided that
   in aggregate they are valued at more than £1,000 / €1,000 / $1,000.

18. Reports

1. We will provide you with:
   1. Transaction statements following each transaction;
   2. Account statements detailing your holdings on a periodic basis;
   3. Annual statements (position, summary of dividends, transactions);
   4. Invoices with details of the fees charged.

19. Withdrawal Requests

1. When you make a Withdrawal Request, we may limit the destination Bank Account to the Bank Account that
   you used to fund your Account.
2. In exceptional circumstances, we may not be able to sell all the assets required to satisfy your
   Withdrawal Request in full (for example, where the order book for a particular ETF is below the
   minimum size required for execution on exchanges). When this happens, we will use our best efforts to
   sell the rest of the assets up to the Withdrawal Request during our subsequent trading sessions. We
   may have to make one or more transfers to your Bank Account in respect of the same Withdrawal
   Request.
3. The money will be transferred in the currency of your Goal/Portfolio and, where that currency differs
   from the currency of your Bank Account, you accept responsibility for any foreign exchange (“FX”)
   fees and other fees associated with the transaction, which means that you may receive less money than
   you expected. It may take up to fourteen (14) business days for the money you have requested to
   arrive in your account.

20. Pooling

1. We may pool (also known as aggregating) your transactions with those of other clients. We will only do
   so where we believe that it is unlikely to disadvantage your overall net position.

21. Fees and Charges

1. All fees stated herein include VAT. Unless explicitly stated otherwise, you may be charged:
   1. Our management fee
      1. Our standard management fee is equal to 0.48% and for adaptive portfolios is equal to 0.75% of your assets under management (AUM) per
         year calculated on a daily basis. Our management fee covers any other fees associated
         with:
         1. Trading
         2. Custody:
         3. Portfolio management
         4. Reporting
   2. The ETF issuers’ management fees (collectively known as the Total Expense Ratio or
      “TER.”):
      1. Your TER is charged in addition to our management fee and varies depending on your
         asset allocation.
   3. For requesting reports:
      1. Transmitted electronically are free of charge.
      2. Where requested in paper format, we will charge £20 / 20€ / $20 per report.
   4. Transfer fees
      1. Within the European Economic Area NIL (0%)*
      2. For transfers to accounts outside of the European Economic Area we will charge £25 / 25€
         / $25*
2. We may change these rates from time to time and will notify you of any such changes by publication on
   our Website and by email at least fourteen (14) calendar days prior to making the change.
3. We may deduct any amounts payable by you to us from your Account. If the available funds are
   insufficient, we may sell assets held as part of your Account to cover such charges. We may pay (or
   receive from third parties), fees in relation to referrals of business. We may receive payment from
   or share charges with a third party. If you require a service from us which is not listed in the
   section Fees and Charges of this Agreement, you should first enquire about the charge before
   instructing us to carry out the service.

22. Cash Deposits

1. All cash you deposit with us will be held in segregated accounts with Aion Bank or an approved bank
   (the “Custodian”) and may include the deposits of more than one client but without being mixed with
   our assets or the assets of the Custodian.
2. Income earned on the investments held in your Portfolio will be remitted to your Portfolio and may
   be reinvested. We will not pay or credit interest to you where we hold cash in your Account.
3. The Custodian may, at times, receive dividends, interest and other rights or payments in respect of
   the investments you hold and may, when required: (i) withhold or deduct tax or other amounts from
   such payments and (ii) deduct any costs incurred by it when complying with these obligations, from
   your Account. It will be your sole responsibility to reclaim any such withholdings or deductions
   where you are eligible to do so.
4. We are under no obligation to tell you before terminating our relationship with the Custodian and
   appointing a replacement.

23. Conflicts of Interest

1. We, or anyone connected with us, may carry out certain transactions for you where we, or another client
   of ours, have a duty that may conflict with our duty to you. We have developed protocols to manage
   conflicts of interest that enable us to act without bias or damage to your interests. Our employees
   are provided with training about the protocols and the standards of conduct to which they must
   adhere. Our management is responsible for ensuring the protocols are adhered to and to deal with any
   conflict that may arise. We will inform you if we reasonably believe that we cannot adequately manage
   a conflict.
2. We are committed to taking measures to recognise, supervise, examine and resolve conflicts of interest.
   We recognise that it is not possible to eliminate all sources of conflict of interest; however,
   safeguarding clients’ welfare remains our primary objective.
3. Examples of conflicts of interest include:
   1. Where we have a direct or indirect financial interest in a commercial undertaking you are
      connected to;
   2. Where we have a personal association or relationship with those affected, or likely to be
      affected, by the information or issue in question;
   3. Where we have an expectation of a future interest (eg, future employment);
   4. Where we have a previous association with a person affected or likely to be affected by
      the information or issue in question;
   5. Where we have an interest arising from a common interest group, such as a trade association or
      other public or private society;
   6. Where we accept gifts and/or hospitality or entertainment; and
   7. Where we have a close personal relationship with someone who has an interest as described above.
4. We maintain a log of conflicts that arise and note in it how each conflict was monitored and how a
   solution was developed and applied to resolve the problem and to prevent the client’s interests being
   affected. The effectiveness of our protocols is assessed by internal audit staff members who execute
   their duties in a wholly independent capacity.
5. Where our functions could create an internal conflict we separate the duties appropriately. The
   operations functions are maintained and conducted separately from the front office functions and an
   appropriate level of qualification, expertise and supervision is applied.
6. Staff remuneration is by means of a basic salary which is not linked to the underlying performance of
   the company. A remuneration committee agrees and monitors awards to achieve consistency and
   equitability and does not lead to conditions that may foster conflict.

24. Liability

1. We accept responsibility for any loss, damages or costs suffered or incurred by you only to the extent
   that such loss arises directly from our gross negligence, wilful default, fraud, and/or our
   deliberate and wilful breach of any duties which we owe you under the MiFID II rules of conduct as
   applied in Belgium . We will not be liable for any other losses, damages or costs suffered or
   incurred by you.
2. We will take reasonable care in the assessment and appointment of sub-custodians, bankers,
   counterparties, agents and other third parties. We accept responsibility for any loss, damages or
   costs incurred by you only where they arise directly from our negligence, wilful default or fraud in
   the assessment or appointment of such persons. We will not be responsible for the actions of any
   third parties. We do not accept responsibility for any loss, damages or costs you may incur as a
   result of any cause beyond our reasonable control.
3. Our duties to you are expressly stated in this Agreement or provided for in the MiFID II rules of
   conduct as applied in Belgium. We do not owe you any other duties.
4. You will indemnify us against any liability, cost, expense, loss or any damage incurred by us (including
   but not limited to professional advisors’ fees) arising from your breach of this Agreement,
   negligence, wilful default or fraud.

25. Amendments to this Agreement

1. We may amend or replace this Agreement. Should we opt to do so we will give you fourteen (14) calendar
   days’ notice via publication on our website, email or any other communication channels agreed upon
   with you from time to time. We will provide you a link to a revised version of this Agreement.
2. If we are required to amend this Agreement for reasons of (i) compliance with MiFID II rules of
   conduct, (ii) any other applicable law or regulation, (iii) adding new services or functionalities to
   your Account or (iv) any other changes which do not reduce your rights nor increase your liabilities,
   we may do so with immediate effect provided we inform you in advance. Any unilateral change that we
   make would be deemed accepted by you upon receipt of notice from us.
3. Should you not accept an amendment, you may object by closing your Account following the procedure in
   the section Closing Your Account. If you have not closed your Account within 14 days from the date of
   the notice of amendment, you will be deemed to have accepted it. If you close your Account, please
   note that you remain liable to us in respect of any fees, charges and other liabilities pursuant to
   the section Termination of this Agreement.

26. Complaints

1. Should you have any major issues with our website, applications, or services, please contact us and
   clearly indicate that you have a complaint. This helps us to distinguish a ‘complaint’ from a mere
   ‘query’. We aim to acknowledge your complaint promptly, investigate the circumstances and report the
   results to you.
2. If your complaint remains unresolved after 8 weeks from the date when you first made the complaint you
   may refer it directly to the competent Ombudsman for financial services, Ombudsfin, North gate II,
   Boulevard du Roi Albert II, 8 box 2, 1000 Brussels. Details on their complaints procedure can be
   found at: https://www.ombudsfin.be/en/individuals/introduce-complaint

27. Termination / Account Closure

1. You may close your Account and thus terminate this agreement at any time by providing 30 days written
   notice via email to support@etfmatic.com. Account closure is subject to the settlement of all
   outstanding transactions.
2. We may close your Account at any time at our discretion. Common reasons for closing an Account held with
   us include:
   1. You are in breach of any terms of this Agreement;
   2. You have not accessed your Account within the past five years;
   3. We suspect you of having ill intentions;
   4. You have not funded your account for more than one year;
   5. We have reasons to suspect that your Account was accessed without authorisation.
3. Where we decide to close your Account, we will provide you with notice of closure and where relevant,
   the reasons for doing so, together with the procedure to follow in order to withdraw any funds under
   our management. We may:
   1. Keep your Account’s personal information in our records in order to fulfil our legal
      obligations;
   2. Suspend, limit or deny your access to, or use of, our services, software, systems (including
      any networks and servers used to provide any of the services) operated by us or on our behalf
      or some or all of the services in respect of your Account;
   3. Retain your funds after closure, to the extent and until such time we may reasonably require
      them, in order to protect ourselves and/or a third party against risks, including but not
      limited to, claims, fines, fees, charges and any other liabilities; and/or
   4. Attempts to contact you after we have closed your Account for any reason.

1. If you are the legal representative of an incapacitated or deceased Account holder, please contact us.

28. Assignment and Transfer

1. You do not have the right to assign or otherwise transfer to any other party your rights or
   obligations under this Agreement.
2. We reserve the right to assign our rights and obligations under this Agreement at any time and will send
   you notice by email of any such assignment prior to its taking effect. This does not affect your
   right to terminate this Agreement under the section Termination of this Agreement.

29. Dormant Accounts

1. Your account will become “dormant” if you have not accessed it for at least five years. To protect both
   you and us, you will be unable to access a dormant Account. Contact us should you be unable to access
   your account and we shall activate it accordingly.

30. Taxes

1. We comply with the applicable EU laws and regulations on reporting and sharing of financial information
   for tax purposes. At the end of each tax year, we will provide you with a summary of all the taxable
   events on your Account, such as dividend distributions and capital gains or losses (“Account Tax
   Certificate”).
2. By entering into this Agreement, you acknowledge and agree that it will be your obligation to complete
   and submit the appropriate tax filings in your country of tax residence.

31. Governing Language

1. This Agreement has been drafted in English. If this Agreement is translated into another language and
   there is a conflict or inconsistency between the English language text and the translated text, the
   English language text prevails.

32. Governing Law and Jurisdiction

1. This Agreement and any non-contractual obligations or claims arising out of or in connection with it
   are governed by Belgian law. You and we irrevocably agree that the courts of Belgium will have
   exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with this
   Agreement (including non-contractual disputes or claims), without prejudice to mandatory rules of law
   stating otherwise.

33. Cancellation Rights

1. You have a period of fourteen (14) days, beginning on the date on which your Account is opened or the
   date on which you receive a copy of this Agreement, whichever is the latest, within which to cancel
   your Account. We will sell any investments made on your behalf but will not be responsible for any
   market loss that you may incur as a result.

34. Force Majeure

1. We will not be responsible for any failure in fulfilling a contractual obligation as a result of
   any situation, condition or event beyond our reasonable control (a “Force Majeure Event”), which may
   include, without limitation, an act of Parliament, an act of God, acts of terrorism, strike or riot,
   extreme fluctuations in the price of a security, failure of communication or electronic equipment or
   anything else that may reasonably impede our ability to act in line with this Agreement.
2. We will continue to take all reasonable steps to act in your best interests when a Force Majeure
   Event occurs and, to the extent that we can no longer comply with the term(s) in question, we may
   suspend or alter any part or all of the Agreement.

35. Third Party Rights

1. A person who is not a party to this agreement cannot enforce or enjoy the benefit of any term of
   this Agreement.

36. Effective Date

1. These Investment Terms take effect from 1 April 2021, and will not apply to services provided prior to
   1 April 2021. Please contact us at Our Support Desk if you require a copy of any prior version.

37. Instrument Risks

1. Some specific risks associated with investing in shares include:
   1. Dividend payment and growth is not guaranteed;
   2. Companies in which you invest are not obliged to pay dividends;
   3. Companies may go into liquidation or receivership which may result in the shares becoming
      worthless;
   4. Equity markets may decline in value;
   5. Corporate earnings and financial markets may be volatile;
   6. If there is no recognised market for shares, then these will be difficult to sell and
      accurate information about their value may be hard to obtain;
   7. Smaller company investments may be difficult to sell if there is little liquidity in the market
      for such shares and there may be substantial differences between the buying price and the
      selling price;
   8. Shares on overseas markets may involve different risks from EEA shares; and
   9. Investments in overseas companies depend not only on the performance of the shares but also
      upon foreign exchange rates which may change adversely affecting the value of the shares in
      your base currency.
2. Our fixed income securities (government bonds) are issued by governments, governmental
   bodies, quasi-governmental bodies, UK local authorities, and companies in the UK and in other
   countries. The main risks associated with these securities includes:
   1. There are few recognised markets in which such securities are traded because they are traded
      between the issuers, their brokers, and the banks and securities houses making a market in
      the securities;
   2. Capital may be lost if the issuer defaults;
   3. Capital may be eroded due to the effects of inflation; and,
   4. The value of fixed income securities may fall as well as rise.
3. Collective investment funds may be authorised by an approved regulator or unauthorised and unapproved.
   We will only invest your money in authorised funds quoted on recognised leading exchanges. The main
   risks associated with investing in collective investment funds are:
   1. There may be no recognised market for collective investment funds as units/shares are issued
      and redeemed by the managers of the funds;
   2. Funds may be valued for pricing and dealing purposes either daily, weekly, fortnightly, monthly
      or even less frequently by the fund managers;
   3. The prices of the underlying investments of the funds will vary according to the markets on
      which these are listed or traded;
   4. Some authorised funds are subject to greater supervision than others; and
   5. Funds in currencies other than the Client’s currency may be affected if foreign exchange rates
      move in an unfavourable direction thus reducing the valuation of investments in base currency
      terms.
4. We may from time to time carry out certain transactions on your behalf where the price may have
   been influenced by measures taken to stabilise it. Stabilisation enables the market price of a
   security to be maintained artificially during the period throughout which new securities are being
   sold to the public. Stabilisation may affect not only the price of the new issue but also the price
   of other securities. The effect of
   stabilisation may be to keep the price of certain securities at a higher level than they would
   otherwise be during the period of stabilisation. We will endeavour not to take part in stabilisation.
   The fact that a new issue or a related security is being stabilised should not be taken as any
   indication of the level of interest from investors, nor of the price at which they are prepared to
   buy the securities.
5. We may buy an investment denominated in a currency other than the agreed base currency of your Portfolio
   on your behalf. The main risks associated with this include:
   1. A movement in exchange rates may have a separate effect, favourable or unfavourable, on the gain
      or loss otherwise experienced on the investment;
   2. If depositing collateral denominated in one currency, you may be subject to margin calls
      in circumstances where the obligations are denominated in another currency (in addition to
      the risk of margin calls for fluctuations in relative values); and
   3. Some currencies are not freely convertible and restrictions may be placed on the conversion
      and/or repatriation of your funds including profits or dividends.

38. Best Execution Policy

1. We are bound by MiFID II rules to undertake transactions without disadvantaging our clients. Under MiFID
   II rules, we “must take sufficient steps to obtain the best possible result, taking into account
   price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration
   relevant to the execution of the order.” When trading, we provide best execution (applied equally to
   single bargains or aggregated/grouped orders), meaning that transactions should be on the best terms
   reasonably available.
2. We are a discretionary investment manager that treats all clients fairly and makes all decisions on
   which instruments to purchase and when to trade on behalf of our clients. We aggregate and net all
   client orders, trading on a consolidated basis. The steps of the process are:
   1. Our algorithm reviews each client’s goal to generate orders;
   2. All orders are executed according to the aforementioned best execution practices; and
   3. After execution and payment settlement the transactions are recorded on the client’s account and
      a trade confirmation is sent to the client.
3. To ensure best execution, we periodically review our procedures, trading system choices, arrangements,
   and any other relevant execution factors to ensure that there is sufficient liquidity in each of
   the instruments, and that we are able to deal on more than one market.
4. Factors to achieve best execution include, in the following priority: size and type of order, likelihood
   of execution, price, and any other relevant consideration. We determine the best possible result,
   summing the price of the financial instrument and the costs related to execution (which include all
   the expenses incurred and directly related to the execution of the order, i.e. execution venue fees,
   clearing and settlement fees, and any other fees paid to third parties involved in the execution of
   the order). All particular trade conditions which may restrict our ability to achieve best execution
   will be informed to the clients.
5. We transact trades in various manners, including by electronic order books, retail service providers,
   agency crosses, telephone and electronic algorithmic systems and, where relevant, make use of
   appointed representatives committed to achieving best execution for clients. We will keep a record of
   all previously mentioned trades. Those which do not fall into the above categories may have
   restricted liquidity or trade venues. We will assume best execution has been achieved with reference
   to any information provided by the market counterparty at each transaction.
6. We will execute the trade as soon as reasonably practicable unless a delay will better serve the
   client’s interest. Trades will be transacted in the same order as they were generated by our system
   unless specific trades have conditions attached which may alter the order of priority.
7. We use our discretion to determine the execution venue for a trade, which may include an
   exchange, multilateral trading facility (“MTF”), organised trading facility (“OTF”) or a broker. We
   will provide annual reports revealing the top five (5) execution venues for that year.
8. We typically trade on a biweekly basis, yet we reserve the right to change the days on which we trade or
   to trade less frequently if, in our discretion, we regard it as necessary or desirable to do so.

39. Fractional Investing

1. To provide you with a balanced portfolio regardless of the amount invested, our system can attribute you
   a proportion of an ETF. This means that where the amount invested does not allow us to construct a
   portfolio that is consistent with your risk appetite using whole shares, we will round down to the
   nearest number of whole shares and create fractional entitlements. Your portfolio will subsequently
   always be in line with your risk level and our rebalancing policy.
2. Where you hold fractional entitlements, the beneficial interest to them will be yours alone. As with
   your whole ETF shares, we will safeguard them for you as per our permissions and the MiFID II rules.

40. Additional Portfolio Gliding Terms and Conditions

1. 1. These are additional terms (“Additional Terms”) and conditions which apply when you opt in to
      our Portfolio Gliding feature. Opting in grants us authority to gradually adjust the target
      asset allocation of your Portfolio, with an aim to decrease your exposure to risk as your
      Portfolio progresses towards its designated end date (“Gliding”).
   2. When you activate Gliding for any of the Portfolios in your Account, you agree to these
      Additional Terms. For the avoidance of doubt, if there is any inconsistency between these
      Additional Terms and the Agreement, these Additional Terms shall prevail.
   3. When you opt in to Gliding, you authorise us to adjust the target asset allocation of your
      Portfolio over time pursuant to the settings you have selected which include:
      1. The asset allocation which you want to start Gliding from (“Starting Asset Allocation”);
      2. The desired asset allocation you want to achieve at the end of the Gliding period
         (“Target Asset Allocation”); and
      3. The period of time over which you want Gliding to occur (“Time Horizon”); (“Additional
         Mandate”).
   4. To opt in to Gliding, you must have an Account and at least one Portfolio open, active, and
      funded.
   5. We reserve the right to terminate Gliding for your Account if you cease to meet any of the
      conditions for eligibility in the section Availability of these Additional Terms.
   6. These Additional Terms will apply from the moment you opt in to Gliding by clicking the toggle
      bar in the edit portfolio/portfolio creation screen until the earlier of:
      1. Us fulfilling the Additional Mandate;
      2. Your opting out of Gliding by clicking the toggle bar in the edit portfolio/portfolio
         creation section;
      3. Your Account/Portfolio ceasing to meet the conditions for eligibility in the section
         Availability of these Additional Terms;
      4. Your Account/Portfolio suspension or closure, either by you or us in accordance with our
         Agreement.
   7. When Gliding is deactivated for your Portfolio, you agree to and accept the following actions:
      1. Your Portfolio will default to a Starter Portfolio with an asset allocation which most
         closely matches the current asset allocation on the Gliding path at the relevant
         time;
      2. The asset allocation of the Starter Portfolio referred to in this clause will be static
         and rebalanced periodically to the relevant static weights; and
      3. You will need to review and sign off on the starter portfolio’s asset allocation to
         ensure that you are satisfied that it meets your requirements.
   8. By opting in to Gliding, you agree to and accept that we will not be liable for any losses
      arising in relation to profits, taxation, fiscal affairs, or otherwise, which you may incur
      as a result of us gradually adjusting the target asset allocation of your Portfolio, except
      if such losses are caused by our gross negligence, wilful deceit, or fraud.

41. Glossary of Terms

Business Day means all days except for every Saturday, every Sunday, public holiday and days where the
company seat of Aion Bank in Belgium is not open.

Anti-Money Laundering Regulations means the Law of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash.

Netting means either of: (i) consolidating the value of two or more transactions, payments or positions in order to create a single value or (ii) offsetting a position in one security or currency with another position either in the same security or another one with the object of offsetting gains in one position against losses in another. Website means our website together with our app(s) and their functionalities, as developed from time to time.

As communicated various times before, on the 11th of November, ETFmatic Ltd ceased operations.

Therefore as of November 28th, 2022, Aion Bank NV/SA (being the parent company of ETFMatic Ltd) has taken over the safeguarding of the assets and cash for clients who have not yet requested the account to be closed, nor have informed us of where they would like to transfer their account.

Aion Bank NV/SA will not provide any portfolio management services, nor in any other way administer these accounts beyond simple safekeeping of the assets.

Please note that going forward these services will be provided in the EU, under Aion Bank’s own regulatory authorisations and in accordance with the Belgian rules and regulations on investments services. These clients will be considered as having solicited such services from Aion Bank in the EU.

In relation to our Terms and Conditions, please be informed that Article 4 will only be partially applied to these former ETFmatic Ltd accounts, meaning that the only action we will carry out is the safe custody of their assets. Furthermore, Article 5 and any other action that pertains to discretionary portfolio management will not be applicable to these accounts.

Please be advised that all former ETFmatic Ltd accounts have now been blocked as we did not receive any response following our previous correspondences.

Client money and ETFs are held in segregated accounts that are protected by the Belgium Guarantee Fund. For more information please refer to the official website of the Belgium Guarantee Fund: https://www.garantiefonds.belgium.be/en.

In addition, according to Article 21 of our Terms and Conditions, a monthly fee of 5 EUR will be applied to the former ETFmatic Ltd accounts from 1st of January 2023.

We strongly encourage you to reach out to us to cancel your current account with us by liquidating your portfolio at any time.

As a result of these changes, we will have an updated version of our terms and conditions active from 28.11.2022. The updated version can be found here: https://etfmatic.com/terms-and-conditions/.

For any questions, contact us via support@etfmatic.com

Kind regards,

Your Aion Bank NV/SA

Privacy Policy

(version effective as from 31.05.2021)

Protecting your personal data is very important to us. This Privacy Policy informs how Aion SA (“us”, “we” or “our”) collects and processes your personal data, notably through your use of our ETFmatic Mobile App (“App”), our website www.etfmatic.com (“Website”); jointly called “Services” and their functionalities as developed from time to time (“Website”), including any data you may provide through this Website when you sign up to our newsletter, purchase a product or service or take part in a competition.

This Website is not intended for children and we do not knowingly collect data relating to children except for the purposes of maintaining Children’s Custodial Accounts in accordance with the Additional Children’s Custodial Accounts Terms and Conditions available on our Website.

For the purpose of the relevant data protection legislation, the data controller responsible for your personal data is Aion SA whose registered office is located at avenue du Boulevard 21, 1210 Brussels.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any of your legal rights, please contact the DPO using the details set out below:

1. App: Customer Support (logged Users),
2. Email address: dpo@etfmatic.com
3. Postal address: Aion SA, avenue du Boulevard 21, 1210 Brussels.

It is important that the personal data we hold about you is accurate and up to date. Please inform us about any relevant changes during your relationship with us using the contact details as set out in the previous paragraph.

Terms not otherwise defined in this Privacy Policy have the meaning given to them in our Terms and Conditions which are available on our Website.

Our App, Website or Website App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Services, we encourage you to read the privacy notice of every third-party website you visit.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

WHAT DATA WE COLLECT ABOUT YOU

Personal data, or personal information means any information about an individual from which the person can be identified. It does not include data from which the identity of the natural person cannot be derived (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

1. Identity Data like your first and last name, date of birth, National Registration number, copies of identification documents, username, password, biometric data such as your facial image or movie and any other information we need to verify your identity or prove your eligibility to use our Services.
2. Contact Data includes billing address, delivery address, e-mail address and telephone number.
3. Financial Data is data collected and processed in order to provide you with financial products and services. This may include your identification number and bank account numbers, credit or debit card numbers, information on your savings and investments, loans and credits, information necessary to assess your creditworthiness (information about your employment and salary, credit history, marital status and family composition, education) or your investor profile (information on your knowledge and experience of financial instruments, investment targets, your capacity to bear losses and risk tolerance).
4. Transaction Data includes details about payments to and from you like account and card numbers, date, time, amount, currencies used, exchange rate, beneficiary details, details on the location of the merchant or CDM/ATM, IP address of sender and receiver, sender’s and receiver’s name, registration information, device information used to facilitate the payment and other details of services you have selected and the mandate you have given us.
5. Technical Data is data about your device or other equipment including information on the internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, the type of mobile device you use, device’s IMEI number, the MAC address of the device’s wireless network interface, mobile phone number used by the device, information stored on your device (including, if you allow us, access to contact information from your address book, login information, photos, videos or other digital content).
6. Usage Data is information about your usage of our Services, your browsing actions and patterns. This may be based on cookies, logs or similar technologies. It may include uniform resource locators (URL), clickstream, services you searched, viewed or used, length of visits, page interaction information. For more information about cookies, please see our Cookie Policy.
7. Marketing and Communications Data includes your preferences in receiving marketing from us and our third-parties and your communication preferences.
8. Location data is data determining your location using GPS technology or IP address.
9. Information from social media networks or online accounts – information from any account that you share with us.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

There may be times when you give us sensitive information, which may include your racial origin, political opinions, religious beliefs, trade union membership details or biometric data. We will only use this information in strict accordance with the law.

FAILURE TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the Investment Terms we entered with you and you fail to provide that data when requested, we may not be able to perform the obligations we have. In this case, we may have to terminate your Account but we will notify you if this is the case at the relevant time.

HOW WE COLLECT PERSONAL DATA

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us through the Website, by email, post, phone, or otherwise. This includes personal data you provide when you: i. create an Account on our Website; ii. report a problem with our Website; iii. subscribe to our communications or publications; iv. request marketing to be sent to you; v. enter a competition, promotion or survey; or vi. give us feedback.

Automated technologies or interactions. Each time you interact with our App, Web App, Website or use our Services we may automatically collect Transaction Data, Technical Data, Usage Data and Location Data.

Third parties or publicly available sources. We may receive personal data about you from third-party and public sources as set out below:

1. Banks you use to transfer money to the account(s) you hold with us;
2. Business partners such as those who offer complementary services (such as investment advisory),
3. Credit reference agencies, fraud prevention agencies or data brokers, including bodies charged with tasks in the public interest (e.g. the Official Belgian Gazette, the Central Individual Credit Register (CICR) and the file of non-governed registrations (ENR) of our regulator,
4. Advertising networks, analytics providers and search information providers based inside and outside the EU,
5. .Providers of technical, payment and delivery services.

Specific cases of personal data collection. In some cases we can collect information about you whereas you do not have a direct relationship with us in the capacity of one of our clients as such. This may happen if you are for example the beneficiary of a payment made by one of our clients or if you are a client’s

1. family member or heir
2. co-borrower / guarantor,
3. legal representative or contact person;
4. ultimate beneficial owner (UBO)
5. debtor (in case of bankruptcy),
6. creditor (in case of seizure requests);
7. shareholder, director or partner,
8. staff member.

LEGAL GROUNDS AND PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA

We will only process your personal data in accordance with the applicable laws, for the following legitimate purposes and based on the following legal grounds

Contract. We need your personal data to conclude a contract with you and to carry out our obligations relating to your contract with us or in order to take steps at your request prior to entering into a contract.
If you have not concluded a contract with us, we do not process your personal data on the basis of a contract. We may, however, use your personal data for other purposes, such as fraud detection. We always check first whether using your personal data for those other purposes is permitted.

Legal obligation. We process your personal data to adhere to statutory requirements. As a bank we are subject to various legal obligations which require us to process your personal data. These include our obligations to combat and prevent fraud, money laundering and terrorist financing (AML-CTF) and our obligation to adhere to the rules of conduct in economic and financial law. In some cases, we are also subject to the obligation to disclose your personal data to judicial authorities, intelligence agencies and regulatory and supervisory authorities. We must also comply with a number of obligations in application of the Foreign Account Tax Compliance Act (FATCA).

Legitimate interest. We have the right to process your personal data if it is necessary for the purposes of the legitimate interest pursued by the controller (us) or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. Legitimate interests on the basis of our processing activities are for example the following:

1. Research. We study possible trends, problems, root causes of errors and risks in order to prevent complaints and losses. This way, we are able to intervene and issue a warning in time, if need be. We also study trends and our clients’ preferences for the purpose of analysation and continuous development of the products and services we offer.
2. New and improved products and services. We use our clients’ personal data for the purpose of deploying and developing our products and services in order to keep up with our clients’ evolving wishes and expectations.
3. Marketing relating to our products and services. We process your personal data for the purpose of direct marketing communications through analysing your needs, preferences, habits and situation, and to market and/or communicate our products and services to you.
4. Risk management and protection of our legal rights. We use your personal data for the purpose of improving our risk management and to defend our legal rights, including:
   
   1. providing evidence of transactions you are involved in or communications between you and us;
   2. fraud prevention, for instance by detecting theft of your identity or credentials (e.g. phishing, theft of your ID document), unauthorised access to your data or device (hacking attempts);
   3. IT management, including infrastructure management, business continuity and IT security;
   4. establishing statistical models, (e.g. in order do to assess your credit risk score);
   5. performing internal control and audit;
   6. enforcement of claims and defence within legal disputes.

Public interest. We have the right to process your personal data if and insofar as it is necessary for reasons of substantial public interest (such as ensuring effective AML-CTF processes).

Consent. We may process your personal data if you have given us prior consent to do so for one or more specific purposes. You have the right to adapt or withdraw your consent at any time and free of charge in the section Notifications > Settings > Marketing in your Account on the Website or by contacting us at support@ETFmatic.com. Adaptation or withdrawal of your consent will not affect past processing activities (the previous processing of your data remains lawful) but will affect and possibly annul those processing activities which were previously based on your consent in the event no other legal ground is available to us to rely on for the specific processing activity.

Further processing. We may use your personal data for other purposes than the purpose for which your personal data was initially collected. In that case, the new purpose must be in line with the purposes for which your personal data was initially collected. In those cases, we will always check first if such further use of personal data is permitted, taking into account your rights and interests.

HOW WE USE YOUR PERSONAL DATA FOR PROFILING AND AUTOMATED DECISION-MAKING

As a credit institution, we make use of profiling. This entails that in certain situations we automatically assemble a profile using a set of your personal data. We do this for purposes of fraud detection when (potentially fraudulent) payment transactions are initiated, unusual transaction detection (based on risk profiles), client and product acceptance (based on profiles relating to creditworthiness) and direct marketing.

We make use of systems to make automated decisions. This helps us to make sure our decisions are quick and based on what we know. Automated decisions may affect the range of products, services or features offered to you now or in the future, or the price that we charge you for them. They are based on personal information that we have or that we are allowed to collect from others. Here are the types of automated decisions we make:

1. As a credit institution, we make use of profiling. This entails that in certain situations we automatically assemble a profile using a set of your personal data. We do this for purposes of fraud detection when (potentially fraudulent) payment transactions are initiated, unusual transaction detection (based on risk profiles), client and product acceptance (based on profiles relating to creditworthiness) and direct marketing.
2. We make use of systems to make automated decisions. This helps us to make sure our decisions are quick and based on what we know. Automated decisions may affect the range of products, services or features offered to you now or in the future, or the price that we charge you for them. They are based on personal information that we have or that we are allowed to collect from others. Here are the types of automated decisions we make:
   
   1. Detecting fraud. We use your personal information to help decide if your account(s) may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. We may also notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the account(s) or refuse access to them.
   2. Opening accounts. When you open an account with us, we check if the product or service is relevant for you, based on what we know. We also check that you or your business meet the conditions needed to open the account. This may include checking age, residency, nationality or financial position
   3. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or otherwise similarly significantly affects you. You can object to such automated decision-making, including profiling, by adjusting the settings in our App or Web App. We may perform a manual double check upon your request.You do not have this right if the decision is authorised by applicable laws we are subject to.
3. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or otherwise similarly significantly affects you. You can object to such automated decision-making, including profiling, by adjusting the settings in our App or Web App. We may perform a manual double check upon your request.You do not have this right if the decision is authorised by applicable laws we are subject to.

USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES

If you have previously purchased a product or service from us, we are legally allowed to keep you informed about similar products and services we offer that are suited to your needs. This also applies if you are a visitor to our Website. In order to do this properly, we use various sources, such as the personal data that we received from you in the context of the contract and information we collect about you through your use of the App or Web App. The use of social media data depends on the privacy settings you use on social media sites. Also other sources of information, including public sources, are relevant. We will always check first whether a public or another source of information can be used reliably. Where applicable, we will check whether you, as a client, have consented to the use of personal data that comes from another party. You have the unconditional right to object to our use of your personal data for direct marketing where this direct marketing is based on our legitimate interest and includes profiling and this at any time and free of charge. You can object to direct marketing by adjusting the settings in our App or Web App.

When you visit our App or Web App we may, upon your specific consent, show you direct marketing material of our products or services or product or services of third-party partners which are deemed to be relevant to you personally. In such cases your data will not be transferred to such third-party partners. You have the unconditional right to adapt or withdraw your consent to our use of your personal data for direct marketing of third-party partners’ products and/or services, and this at any time and free of charge. Withdrawal or adaptation of your consent is possible by adjusting the settings in our App or Web App. Please note that in such cases of withdrawal your will continue to see marketing material from third parties, which will however not be direct marketing and not based on your personal data, when using the App or Web App.

We may, upon your specific consent, transmit advertisements of our products or services or products or services of third parties to you by e-mail or telephone. In such cases your data will not be transferred to such third-party partners. You have the unconditional right to adapt or withdraw your consent to our use of your personal data for direct marketing of third-party partners’ products and/or services, and this at any time and free of charge. Withdrawal or adaptation of your consent is possible by adjusting the settings in our App or Web App. In cases of withdrawal we stop sending you advertisements by e-mail or telephone.

When you visit our App, Website or Web App, we can show you advertisements which we deem relevant to you personally based on cookies and similar technologies. In that case, you must have consented to our use of cookies and similar technologies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. For more information about cookies, please see our Cookie Policy. You have the unconditional right to adapt or withdraw your consent to our use of your personal data for direct marketing of third-party partners’ products and/or services, and this at any time and free of charge. Withdrawal or adaptation of your consent is possible by adjusting the settings in our App or Web App. In the event of withdrawal of your consent, you will only see generic advertisements from then on.

WHO DO WE SHARE YOUR PERSONAL DATA WITH

In order to fulfil the aforementioned purposes, we only disclose your personal data to:

1. Payment processors and networks (e.g. Swift, Visa, Master Card),
2. Credit reference agencies,
3. Know Your Customer (KYC), analytical and cyber security providers,
4. Other service providers which process personal data on our behalf, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. Commercial partners (e.g. investment advisory service provider).
6. Organisations set up for detection and prevention of terrorism.
7. Financial or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law,
8. Certain regulated professionals such as debt collection agencies, lawyers, notaries or auditors.
9. any other third party, but only subject to your prior consent.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

In case of international transfers originating from the EEA to a non-EEA country which the European Commission has recognised as providing an adequate level of data protection, your personal data will be transferred on this basis. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EEA and the US.

For transfers to non-EEA countries of which the level of protection has not been recognised by the European Commission as adequate, we will either rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to perform our contract with you such as when making an international payment) or implement one of the following safeguards to ensure the protection of your personal data:

1. Standard contractual clauses approved by the European Commission;
2. Binding Corporate Rules.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third-parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG DO WE KEEP YOUR PERSONAL DATA

We will retain your personal data for the duration required for the purposes of processing as set out above, in order to comply with applicable laws and regulations or as is necessary with regard to our operational requirements, such as account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests.

The period for which we will retain information about you will vary depending on the type of information and the purposes that we use it for. For instance:

1. data used for AML purposes – for 10 years as of the single transaction or as of the end of the contractual relationship;
2. data kept as a proof of transactions – for 10 years as from processing of the transaction concerned;
3. customer complaints – for 5 years as from the complaint concerned;
4. prospects data used for marketing purposes – for 3 years from the collection of the data concerned;
5. FATCA and CRS documents – for 7 years as from the 1st of January following the year of account closing, the statement or the operation.

WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM

In accordance with applicable regulations, you have the following rights:

1. To access: you can obtain information relating to the processing of your personal data, and a copy of all your personal data that is processed by us.
2. To rectify: when you consider that your personal data are inaccurate or incomplete, you can require that such personal data be modified or completed accordingly.
3. To erase: you can require the deletion of your personal data. We are not always able to do this, however, and we do not always have to agree to do this, for example if we are required by law to keep your personal data for a longer period of time.
4. To restrict: you can request a restriction of the processing of your personal data if:
   
   1. you think that your personal data is incorrect;
   2. you think that we are not supposed to process your personal data;
   3. we want to destroy your personal data but you still need it (e.g. after the retention period has ended).
5. To object: you can object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing
6. To data portability: where legally applicable, you have the right to have the personal data you have provided to be returned to you or, where technically feasible, transferred to a third party.
7. To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
8. To ask that we do not make our decision solely based on automated processes, including profiling. You can object to such an automated decision, and ask that a person reviews it unless such decision is authorised by applicable law to which we are subject.

You can exercise the rights listed above using the details set in Point 3. Please note that in case you contact us by Email or post you are required to provide at least your first and last name, signature and a copy of your ID document. Otherwise we won’t be able to identify you and, consequently, take actions on your request. If you make a request on behalf of someone else, you must provide evidence of your authority to make such a request.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month.

To do so, please contact us through the Website or by emailing us at support@ETFmatic.com.

COMPLAINTS

If you have any complaints regarding this Privacy Policy or on how we protect or use your data, please contact our DPO using the contact details as set out above in Point 3. Please note that in case you contact us by Email or post you are required to provide at least your first and last name, signature and a copy of your ID document. Otherwise we won’t be able to identify you and, consequently, reply to your complaint.

If you have any concerns about our use of your personal data or if you feel like we have not addressed your questions or concerns adequately, you have the right to lodge a complaint at any time with the Belgian Data Protection Authority, which regulates and supervises the processing of personal data in Belgium, by e-mail to contact@apd-gba.be, via their helpline on +32 (0)2 274 48 00 or by writing to Rue de la Presse 35, 1000 Brussels; or We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact our DPO in the first instance.

FEE

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

CHANGES TO THIS POLICY

As changes in the law or in our services and products may affect the way we use your personal data, we reserve the right to amend or modify this Privacy Policy, in accordance with the applicable laws. We will inform you of any material changes through our App, Website or Web App or through other usual communication channels. Your continued use of the App, Website or Web App after a modification of this Privacy Policy entails your acceptance of the modified Privacy Policy.

Use of Cookies Policy

Why we have them

We use cookies to give you the best possible experience on our website. We anonymously track page views in order to constantly improve for our customers.

Unless context otherwise requires, a reference to the website also refers to our ETFmatic application.

We use the following types of cookies

Operational cookies These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or our services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Cookies in use

Not for sale

None of our data or tracking information is for sale to third parties.

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You can tell your browser to reject them

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Terms of Website Use

Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site.

Reliance On Information Posted & Disclaimer

The materials contained on our site are provided for general information purposes only and do not claim to be or constitute legal or other professional advice and shall not be relied upon as such. We do not accept any responsibility for any loss which may arise from accessing or reliance on the information on this site and to the fullest extent permitted by English law, we exclude all liability for loss or damages direct or indirect arising from use of this site.

Information about us

ETFmatic is a trade mark of Aion Bank SA/NV. AION Bank SA/NV is a credit institution incorporated as a limited liability company (“société anonyme”/”naamloze vennootschap”) under the laws of Belgium, having its registered office at Avenue du Boulevard 21, 1210 Brussels, Belgium, and registered with the Crossroad bank of Enterprises under number 403.199.306. 

Accessing our site

Access to our site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our site without notice (see below). We will not be liable if for any reason our site is unavailable at any time or for any period.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our site, 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 reference and you may draw the attention of others within your organisation to material 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 material on our site must always be acknowledged. You must not use any part of the materials 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 our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

Our site changes regularly

We aim to update our site regularly, and may change the content at any time. If the need arises, we may suspend access to our site, or close it indefinitely. Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.

Our liability

The material displayed on our site is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, and third parties connected to us hereby expressly exclude: All conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity. Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, any websites linked to it and any materials posted on it, including, without limitation any liability for: loss of income or revenue; loss of business; loss of profits or contracts; loss of anticipated savings; loss of data; loss of goodwill; wasted management or office time; and for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above. This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.

Information about you and your visits to our site

We process information about you in accordance with our privacy policy. By using our site, you consent to such processing and you warrant that all data provided by you is accurate.

Viruses, hacking and other offences

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 under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately. We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses 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 material posted on it, or on any website linked to it.

Links from our site

Where our site 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, and accept no responsibility for them or for any loss or damage that may arise from your use of them. When accessing a site via our website we advise you check their terms of use and privacy policies to ensure compliance and determine how they may use your information.

Jurisdiction and applicable law

All the rights and obligations of the Clients and the Bank are governed by and should be construed in accordance with Belgian law. Without prejudice to overriding and mandatory legal provisions providing for the competence of other jurisdictions (for example for consumers), the Bank and the Client, either demanding or defending, may seize the courts of Brussels for any dispute arising from or relating directly or indirectly to their business relationship.

Variations

We may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our site.

Your concerns

If you have any concerns about material which appears on our site, please contact support@etfmatic.com. Thank you for visiting our site