1. Terms of use validity

These terms of use for the website www.alliance-digital.fund (hereinafter “Terms of Use”) govern the legal relationship between registered investors (for those who want to invest) or borrowers (for those who want to raise funds), hereinafter referred to as the “User” on the website www.alliance-digital.fund and its sub-pages (hereinafter referred to as the "Personal Cabinet") and the Management Company Alliance Digital Fund a.s. (registration code 07458835, SLOVENSKA 1694/23, 12000, PRAHA 2, VINOHRADY, Czechia, email: [email protected], hereinafter "Management Company") arising in connection with the use of the Personal Cabinet.

1.2. When creating a User Account on the website of the Management Company, the User agrees to the Terms of Use and thereby enters into an agreement in accordance with these Terms of Use between the User who creates the account and the Management Company.

1.3. The Management Company reserves the right to change or expand the Terms of Use or set additional conditions. These amendments and additions become effective from the moment when the User agrees with the new Terms of Use through the Personal Cabinet on the website www.alliance-digital.fund.

1.4. By starting to use the Personal Cabinet, the User confirms that he has read the Terms of Use, understood them and agreed to implement and comply with them.

2. Services and Remuneration offered by the Management Company.

2.1. The Management company allows Users registered in the Personal Cabinet to use the Personal Cabinet for its intended purpose, first of all, add investment financing offers and / or familiarize with them, make statements of intent, make investments in accordance with the chosen direction. The Management Company has the exclusive right to change the functionality and terms of use of the Personal Cabinet without prior notice, including limiting or adding the functionality of the Personal Cabinet.

2.2. All expenses and remuneration of the Management Company related to investing when using the Personal Cabinet are paid by the User in accordance with the conditions specified in the investment contract, and the Management Company automatically withdraws (without additional permission from the User) the expenses and service fees of the Management Company from the Subaccount of the User ( as defined in clause 4.1).

3. User Account

3.1. In order to use the Personal Cabinet, a person is obliged to register a User Account in his name (hereinafter referred to as the “User Account”). Only persons who have been verified by the Management Company to the extent that the Management Company deems necessary, can register the User Account in their own name. The person requesting the registration of the User’s Account shall provide the Management Company with any information requested by the Management Company. The Management Company has the right to unilaterally refuse to open a user account.

3.2. After registering the User Account, the person enters his contact information and other data required by the Management Company in the appropriate environment and selects a unique Username and password.

3.3. The Management Company has the right to restrict the rights of certain groups of Users, including restricting access and / or rights to use certain parts of the Personal Cabinet.

3.4. In order to sign in to the Personal Cabinet, the User must enter his Username and password. In order to use the Personal Cabinet, the Management Company may unilaterally require the User to identify his identity by using an identification document (ID card, passport, driver's license) or any other identification method acceptable to the Management Company. In order to file statements of intent that have legal consequences and give official confirmation, the Management Company may request verification of the User’s signature using an identity document (ID card, passport, driver’s license) or mobile communication or any other means of authentication.

4. Personal Cabinet

4.1. After registering a User Account, the User will automatically be assigned (as part of the User Account) an individual virtual account for performing operations through the Personal Cabinet, by the User himself or by a legal entity represented by the User, both for tracking financial liabilities and claims, which may arise on the basis of the Terms of Use and / or as a result of transactions committed through the website (hereinafter referred to as the “Subaccount”).

4.2. The Management Company may verify the User of the Personal Cabinet to the extent that the Management Company deems necessary. The User of the Personal Cabinet is obliged to provide the Management Company with any information requested by the Management Company.

4.3. The person in whose name the Personal Cabinet was registered (the User of the Personal Cabinet) is responsible for the rights and obligations associated with the use of the Personal Cabinet. Among other things, the User of the Personal Cabinet is a party to transactions performed through the Personal Cabinet. For transactions made through the Personal Cabinet, the terms of the relevant transaction are applied, moreover, those terms shall be separately accepted by the User of the Personal Account.

4.4. The Subaccount opened for the User of Personal Cabinet should display, in the currency determined by the User, the amount of funds transferred by the User to the Management Company for the purpose of projects' investment through the Personal Cabinet, among other things, the amount payable to the Management Company or the compensation in accordance with the Terms of Use should be deducted from this amount.

4.5. The User of the Personal Cabinet can make statements about the intentions of investing through the Personal Cabinet in accordance with the chosen investment strategy. After selecting the investment strategy, the User indicates in the appropriate field the amount that he intends to invest and confirms the intention to invest. After that, a confirmation of the investment application acceptance with the attachment of the investment contract will be sent to the User’s e-mail, as well as the investment strategy and invoice with the details of the Management Company for the User to make a money transfer.

4.6. The User of Personal Cabinet can transfer funds to the Management Company only from a bank account registered in the name of the User, opened with an appropriately authorized credit or payment institution, which is registered or has operations in a country that is a member of the European Economic Area (EEA), or in a state where similar methods of combating money laundering and measures to prevent the financing of terrorism are applied (the Management Company has the right to request documents confirming compliance of the bank account with the conditions referred to in this clause). The User of the Personal Cabinet is obliged to indicate in the payment order the individual ID assigned by the Management Company to the User of the Personal Cabinet.

4.7. If the bank account from which the money transfer was made to the Management Company does not belong to the relevant User of the Personal Cabinet or does not comply with any other conditions set out in clause 4.6, and if the individual ID mentioned in clause 4.6 is not indicated in the payment procedure, the Management Company has the right to transfer the amount back to the person who made the money transfer, and to demand from the User compensation for expenses related to the return of the payment (automatically deduct them from the payment amount).

4.8. The amount of payment made by the User of the Personal Cabinet to the Management Company in accordance with clause 4.6 is recorded on the Subaccount in the relevant section of the Personal Cabinet and the User of the Personal Cabinet uses it to track income from investment and fulfill obligations to the Management Company arising from the Terms of Use.

4.9. Unless otherwise provided by the Terms of Use, the User of Personal Cabinet may instruct the Management Company to sell the investment share and then transfer the funds displayed on the Subaccount to the User of Personal Cabinet in the amount of the non reserved positive balance of the Subaccount, by giving the Management Company a corresponding order using the appropriate application of Personal Cabinet. The above order shall be considered as a directive from the User of Personal Cabinet to the Management Company of transferring the amount mentioned in the order (in the amount of the non reserved positive account balance) by using a bank transfer to the account of the User.

4.10. The Management Company makes payments to the User of the Personal Cabinet only to the bank account specified for the Management Company by the User of the Personal Cabinet. The User of the Personal Cabinet has the right to claim the Management Company to make payments only to a bank account registered in the name of the User, opened with a properly authorized credit or payment institution that is registered or has operations in a country that is a member of the European Economic Area (EEA), or in a state where similar methods of combating money laundering and measures to prevent the financing of terrorism are applied. The Management Company has the right to refuse proceeding with payment to a bank account that is not owned by the User of the Personal Cabinet or does not meet any other conditions set out in this clause (the Management Company has the right to demand documents confirming that the bank account complies with the conditions mentioned in this clause).

4.11. In the event that the User of Personal Cabinet wants to change the User’s bank account number provided earlier to the Management Company, the User must inform the Management Company of the new bank account number using the appropriate application of the Personal Cabinet, thereby confirming that the bank account was opened in the User’s name and corresponds to other conditions set out in clause 4.10.

4.12. The User of the Personal Cabinet pays the expenses for the transfer of funds to the Management Company by the User. Costs associated with payments made by the Management Company to the User of the Personal Cabinet, and other expenses related to payments by the Management Company to the User of the Personal Cabinet, are paid in accordance with the conditions specified in the investment contract.

4.13. The Management Company shall keep the funds transferred to the Company by the User of the Personal Cabinet in a bank account, which the Management Company has opened in its name solely for this purpose in the properly authorized credit or payment institution that is registered or operates in a state that is a member of the European Economic Area (EEA). Funds in the relevant bank account of the Management Company are not considered an asset of the Management Company. The Management Company must keep the funds of the Users separately from its own funds. The funds transferred by the User of the Personal Cabinet to the bank account of the Management Company belong to the User of the Personal Cabinet in the amount of the Subaccount positive balance. The interest on the funds of the User on the account of the Management Company is not charged by the Management Company and is not payable to the User of the Personal Cabinet.

5. Conclusion of investment and loan agreements

5.1. If the User wishes to borrow funds from other Users to finance investment projects, to finance projects for the growth of existing projects or for any other similar purposes, he uses the corresponding application of the Personal Cabinet and provides all data necessary for the application, including data relating to the User, the maximum amount of loan, the  minimum amount of loan, interest, loan period and data related to the investment project. When submitting an application for borrowing, the User confirms the conditions on which he is ready to raise funds for further investment in the project proposed for consideration.

5.2. The information provided by the User for borrowing funds is published for other Website Users in full along with the data of the borrower and any other additional data, publication of which may deem necessary by the Management Company and which were checked by the Management Company at its discretion. A publication of the information is the final proposal for borrowing.

5.3. The user who wants to invest money, selects in the appropriate section of the Personal Cabinet, the direction of investment to which this project belongs. The User of the Personal Cabinet can only invest using the funds shown on his Subaccount in the form of the non reserved positive balance. The User of the Personal Cabinet cannot invest money if the amount of investment and the fee payable to the Management Company exceeds the deposit shown on his Subaccount of the non reserved positive balance.

5.4. In order to make an investment, the User of the Personal Cabinet must submit a statement of intent to make an investment, confirmed through the appropriate application of the Personal Cabinet, in which the User of the Personal Cabinet indicates the amount of investment and accepts the conditions specified in the investment contract. Investment conditions, which are not indicated in the agreement to provide investment or in the offer provided to the User requesting the loan, are governed by the standard terms and conditions of the investment contract established by the Management Company. The User of the Personal Cabinet, who provides investment funds, cannot unilaterally refuse or cancel a confirmed consent, unless otherwise provided by peremptory legal norms or the investment contract.

5.5. By giving confirmation of the consent, the User of Personal Cabinet permits the Management Company to reserve a positive balance on the User's Subaccount in the amount of the investment amount specified in the consent and in the amount payable to the Management Company when making the transaction.

5.6. Upon confirmation of the consent, an investment contract is concluded between the giving his consent and providing investment User of the Personal Cabinet and the Management Company. Such an agreement shall be deemed concluded from the moment when the User of the Personal Cabinet who submitted the investment confirms the decision to invest in the relevant section of the Personal Cabinet. The contract comes into force when it is signed by both parties and funds are credited to the bank account of the Management Company.

5.7. Users have the opportunity to review the terms of the investment or loan agreement on the website of the Management Company before the agreement is signed and enters into force.

5.8. If the applying for loan User has entered into a loan agreement in the amount of at least the minimum total amount of the loan, the Management Company will settle reserved funds on the Subaccount of the investing User as follows: The Management Company automatically reduces the balance on the Subaccount of the investing User to the investment amount and increases the balance on the Subaccount of the loan applicant for the loan amount. The Management Company automatically reduces the balance on the Users' Subaccounts in the amount payable to the Management Company in connection with the implementation of this operation.

6. Sale of investment share through the User's Personal Cabinet

6.1. If the User of the Personal Cabinet wishes to prematurely terminate the investment contract and sell his investment share, he can do it through the Personal Cabinet. In this case, the User uses the corresponding applications of the Personal Cabinet for this and submits all the data required by the application, among other things - the investment contract number, the amount of investment, the date of conclusion of the contract, the date of termination of the contract and the sale price. When submitting an application for the sale of an investment share, the User grants the Management Company the right to place information on the sale of the investment share in the appropriate section of the site.

6.2. The information provided by the User of the Personal Account regarding the sale of the investment share is published on the website of the Management Company for other Users in full, along with additional data, the disclosure of which the Management Company considers necessary.

6.3. The User wishing to purchase an investment share may purchase an investment share solely using funds indicated as non-reserved positive balance on his Subaccount, for conduct the purchase he needs to enter into an investment contract with the Management Company and transfer the corresponding amount of funds to the bank account of the Management Company. The User of the Personal Cabinet cannot purchase an investment share if the share price and the amount paid to the Management Company for the transaction exceeds the positive non-reserved balance on his Subaccount.

6.4. To purchase an investment share, the User of Personal Cabinet, by using the appropriate Personal Cabinet application, submits a confirmed willingness to purchase or consent to purchase a share, with it the User of the Personal Cabinet accepts the share price and terms of the share purchase. The terms of the share sale, which are not specified either in the consent to acquire the share or in the application submitted by the User wishing to sell the share, are taken from the standard terms and conditions of the investment contract established by the Management Company. The Management Company serves, as a link for those wishing to purchase the investment share of the Personal Cabinet User in relation to the User wishing to sell the investment share.

6.5. By confirming acceptance, the User of the Personal Cabinet authorizes, in the specified in the offer price of the investment share and the amount to be paid for the Management Company when making a transaction, the reserve of a positive balance on the User's Subaccount (i.e. the corresponding amount cannot be used to conduct other transactions or it cannot be required for transferring to the User’s settlement account).

6.6. After confirming the acceptance between the User of Personal Cabinet who is submitting the acquisition of the investment share and the User who wishes to sell the investment share, the Management Company signs a new investment contract with the User who has submitted an acceptance for the acquisition of the investment share, and terminates the existing investment contract with the person willing to sell the investment share.

6.7. Before signing the investment contract, the User is obliged to review the text and the main provisions of the investment contract in the User’s Personal Cabinet.

6.8. If the User who wishes to sell the investment share rejects his intention, on the basis of imperative legal norms, of terminating the investment contract, the Management Company automatically returns to the User, who wishes to purchase the investment share, the amount deducted from his Subaccount.

7. Fulfillment of financial obligations through the User’s Personal Cabinet

7.1. All financial obligations arising from transactions carried out through the Personal Cabinet and in accordance with the Terms of Use are fulfilled through the Personal Cabinet, unless otherwise provided for in the Terms of Use. No other financial obligations can be fulfilled through the Personal Cabinet and no payments can be made, with the exception of payments that the Management Company makes automatically in accordance with the Terms of Use for the purpose of performing transactions through the Personal Cabinet.

7.2. The User submits an application of intent on the website to the Management Company, through the Personal Cabinet only in the amount of funds displayed on the User's Subaccount in the form of a non-reserved positive balance from which, pursuant to the Terms of Use, namely other financial obligations of the Personal Cabinet User shall not be paid. The Management Company has the right to establish restrictions or additional requirements with respect to the minimum or maximum balance on the Subaccount at its discretion.

7.3. When submitting an application of intent, the User of Personal Cabinet must submit an irreversible order to the Management Company so that there is no need to submit additional applications of intent, for reducing the balance of the User Subaccount to fulfill any financial obligations arising from the use of the site accordance with the conditions, size and term set for the operation, and accordingly increase the balance of the Payee Subaccount.

7.4. The User of the Personal Cabinet is obliged to ensure a sufficient non-reserved balance on the Subaccount to fulfill the obligations arising from any transactions made by him, in a proper and timely manner. The user of the Personal Cabinet is responsible for the violation of the above obligation in accordance with the terms of the operation underlying the obligation.

7.5. The Management Company has the right to use the funds transferred to it and displayed on the User's Subaccount of the Personal Cabinet, in order to carry out operations and actions carried out through the website in accordance with the Terms of Use and transactions concluded during the use of the site.

8. General Rights and Responsibilities of the User

8.1. In addition to the other responsibilities set forth in the Terms of Use, the User is obliged to:

8.1.1. Not using the site for illegal operations or activities, including fraud, money laundering or other similar actions, and must be polite and respectful towards other Users and the Management Company;

8.1.2. Use the site through web browsers designed for general purposes, rather than using programs that send automatic requests to the site for any purpose. It is forbidden to use, including but not limited to, robots, web spiders, scraper and other automatic input devices and data processing. The User is prohibited to perform any actions that violate or impede the use of the site for the purpose of the Management Company or other Users, among other things the User must avoid the overloading of computer network and servers related to the site;

8.1.3. Provide only reliable data and information during the registration of the Account and Personal Cabinet of the User and when using the site. If the User provides, when using the site, information or data, the reliability of which has not been verified by him, or of which he is not convinced that it is true, the User must indicate this when providing such data or information. The User shall be liable for damage caused as a result of a violation of the obligation set forth in this clause to the Management Company and other Users, first of all, in the case when the Management Company or another User submitted a statement of intent or performed an operation assuming the correctness of such false data. The Management Company does not verify the accuracy of the information provided by the Users, and does not bear any responsibility for the accuracy and reliability of the data provided by the Users;

8.1.4. Store data and devices necessary for logging in to the User's Account on the website, including the ID-card, the corresponding passwords and attributes of the User and authentication devices in such a way as not to allow third parties to take possession of them. However, if a third party sign in the Personal Cabinet by using the User's Account, all provisions arising from the Terms of Use are applied;

8.1.5. Inform the Management Company immediately of the loss or transfer to third parties of data and devices that allow the sign in to the User’s Personal Cabinet to third parties and the use of the Personal Cabinet by third parties, as well as about the risk of unauthorized use of the User Account and the Personal Cabinet that may occur;

8.1.6. Inform the Management Company as soon as possible about any changes in the data provided when opening a User Account or Personal Cabinet. As long as the Management Company is not notified of any changes in the data, the Management Company considers the data provided by the User when opening the User Account or Personal Cabinet as valid User data.

8.2. Up to 1 (one) business day from the date of receipt by the Management Company of the notice specified in clause 7.1.5, statements of intent and transactions carried out through the User Account, and the corresponding Personal Cabinet of the User shall be considered as statements of intent and as operations of the corresponding User's Personal Cabinet, and they are not subject to cancellation for the User, even if the User of the Personal Cabinet did not perform these operations. The relevant Subaccount User shall be liable for damage caused as a result of unauthorized use of the User Account, and Personal Cabinet, except in special cases when the responsibility of the Personal Cabinet User is limited by the relevant mandatory provisions of the current legislation.

8.3. In addition to other rights set forth in the Terms of Use, the registered User has the right to:

8.3.1. To sign in the personal Account using the login function, the security of which is ensured by the necessary measures, determined at the discretion of the Management Company;

8.3.2. Use the functionality of the website if the User meets the requirements established for the use of certain features;

8.3.3. Check User data stored by the Management Company, modify such data and request the Management Company to stop processing such data in accordance with the provisions of clause 8.3;

8.3.4. With the prior consent of the Management Company, authorize the representative of the User to use the Account of the User and register the representative as an Authorized User of the User's Account;

8.3.5. Give feedback on the services provided by the Management Company and respond to surveys conducted by the Management Company, including assessing the quality of services.

9. Processing User Data

9.1. For the purposes of these Terms of Use, all data and information about the User (who is an individual), that the User provided when registering a User Account or Personal Cabinet, by using the Personal Cabinet and submitting a statement of intent through the Personal Cabinet, or which the Management Company will receive about the User (who is a private person), from third parties. The provisions of this clause 9 established for any data must also be applicable to personal data.

9.2. By registering a User Account and / or providing the data, the User shall ensure that all data provided by him to the Management Company are correct and up-to-date, and confirms that he is aware and agrees that all legally collected data about the User, which are under the Management Company’s disposal, regardless of their origin, is processed by the Management Company for purposes related to the use of the site and to the extent necessary for this, as well as under and in accordance with the procedures specified in legislation.

9.3. The User acknowledges and thereby agrees, on his own behalf and on behalf of the Personal Cabinet User, to verify the accuracy of the data provided to the Management Company, as well as to receive additional data from third parties. For the above purposes, the Management Company has the right to transfer User data to third parties.

9.4. The User, who is an individual, has the right to revoke his consent to the processing of personal data at any time, to demand the termination of the processing of personal data, the end of access to them and the removal or closure of the collected personal data, provided that the User, or any associated to him User of Personal Cabinet is not in the process of concluding a contract through the site or not having contract in force concluded through the site, and provided that the legal acts do not oblige the Management Company to retain the data. When revoking consent to the processing of personal data of the User, all Accounts of the User must be closed.

9.5. The Management Company is obliged to keep User data confidential and comply with all rules arising from the Personal Data Protection Act of the Czech Republic. The Management Company has the right to disclose the personal data of the User to third parties, including other Users, only in cases provided for by law and the Terms of Use.

9.6. The Management Company has the right to disclose the (personal) data of the Personal Cabinet User to other Users of the Portal, as well as to persons who provide the Management Company with legal assistance, accounting, auditing services or any other services that involve the processing of personal data of the Users, under the condition that the respective service provider takes assume the obligation to the Management Company not to disclose the relevant personal data to third parties.

9.7. The Management Company has the right to process the data provided by the User, and use the data obtained during the use of the site by the User at any time for statistical purposes and disclose the statistical data obtained, ensuring that such data cannot be directly linked to any particular User.

9.8. The Management Company has the right to use the email address and the mobile phone number of the User to send information, advertising, and offers from the Management Company or its partners to the User. The User should have the right to choose which notifications and proposals he wants to receive through the Portal and, without relevant request through the Portal from his side,  be able to unsubscribe receiving offers from the Management Company and its partners. Information on how to unsubscribe offers and advertisements is provided to the Management Company’s Users in offers or advertisements and / or in the User Account settings.

10. Intellectual property

10.1. All intellectual property rights of the site, including the structure, web design elements, texts and other components of the site, as well as intellectual property rights associated with them (including the intellectual property rights of trademarks, logos, brands, software, databases, news, messages, texts, graphic, musical and other design) belong to Alliance Digital Fund a.s., unless the rights of another person are not indicated in relation to the component, or if the information has not been entered by the Users of the site. The User, without the prior written consent of the Management Company, has no right to change, reproduce, distribute, process, translate, extract, transfer, include in other databases and make public or use in any other way that goes beyond the proper use of the website, the Management Company's website or any of its contents or its components. In addition, the User is not entitled to grant sub-licences for using the website of the Management Company or any of its content or its components, or to create new intellectual property based on them.

10.2. The user is allowed to publish on the Portal only such materials in respect of which he has intellectual property rights to the extent necessary to publish the relevant materials on the website and to provide the consent specified in clause 9.3, the User is solely responsible for the materials published by him on the site, and is obliged to reimburse the Management Company for all expenses and damages (including consequential damages) related to the use of materials published by the User on the site in an unauthorized manner or in a manner that otherwise violates the rights arising from intellectual property.

10.3. By publishing any materials on the Site by the User, the User gives his unconditional and cost-free consent to the Management Company of storing, distributing and publishing such materials in accordance with the Terms of Use, as well as to modify or otherwise process this materials to the extent necessary for proper use of the site.

11. Responsibility

11.1. Despite the fact that the Management Company takes all measures to ensure the correctness and accuracy of the information published on the website, the Management Company is not responsible for the publication on the website of unreliable or misleading information, or for a violation committed or continuously committed through the website, or its consequences, about which the Management Company is not aware or in respect of which it takes measures to correct the information, to stop the offense or to eliminate the consequences.

11.2. The Management Company is not responsible for the correctness and completeness of information received from third parties if the Management Company publishes it on the website in the same form in which it was transmitted to the Management Company or made available in any other way. If the User finds incorrect information contained on the website, he is obliged to inform the Management Company about this as soon as possible.

11.3. The Management Company is not responsible for the information, opinions and any other materials published on websites owned by third parties to which the site is directly or indirectly referred to, or links that were published on the website.

11.4. The Management Company is not liable to other Users or third parties, if it violates the obligation specified in the Terms of Use or any other agreement concluded with the Management Company, a legal act or an agreement concluded between Users.

11.5. If the User by violating any obligations, causes damage to the Management Company, the User is obliged to fully reimburse the relevant losses to the Management Company upon request.

11.6. The Management Company is not liable for losses incurred by the User or third parties due to the fact that the Management Company used its legal remedies (for example, deleted information from the site or blocked access to it, restricted the rights of the User or blocked access of the User to the User's Account or to the website), if it was necessary in connection with a complaint submitted by the User regarding the violation and suspicion to the Management Company of execution the violation or having suspicion of unauthorized use User's account or Personal Cabinet, or directly from the fact that the information or user actions is contrary to the Terms of Use or legal acts. In this case, the Management Company is not responsible for the damage, even if the complaint or suspicion, was unreasonable or, if later it will appear that this case is not a violation.

11.7. The Management Company is not responsible for the temporary suspension of access to the website or its functionality.

11.8. The Management Company is liable only for direct material damage caused to the User by a material unlawful violation of the Management Company. Other losses or loss of profits are non-refundable. The Management Company is not liable if the breach of obligations is caused by the service provider or any other third party used by the Management Company.

11.9. The Management Company is not responsible for the settlement of disputes between Users, which arise from the use of the website, but reserves the right to intervene in such disputes at its discretion, if necessary, and if the violation of the Terms of Use are raised, including but not limited to the provisions of clause 11.2.1.

12. Duration of site use and termination of use

12.1. The Users' Accounts on the site can be open indefinitely. If the User and the associated User of the Personal Cabinet do not have any valid agreements concluded through the Personal Cabinet, and he no longer wishes to use the Personal Cabinet, he can close the User Account, and the associated Personal Cabinet and terminate the agreement concluded with the Management Company, without any notice. To do this, he must click on the appropriate field in the User Account settings of the Personal Cabinet or send the corresponding application to the Management Company to the email address [email protected]

12.2. The Management Company has the right to limit or cancel the User’s right to use the site and close the User’s Account and the associated Personal Cabinet (as defined in clause 4.1), as well as terminate the agreement concluded with the User at any time without prior notice, if it appears that:

12.2.1. The User violates or has violated the Terms of Use or any other obligations of the User;

12.2.2. The User does not accept the new Terms of Use when first entering the site after the new Terms of Use are available on the site;

12.2.3. The User has provided the Management Company or other Users with data and / or information that is incorrect, misleading and / or inaccurate;

12.2.4. The user behaves when using the site in bad faith, unworthily, illegally or in contradiction with the moral standards recognized in society;

12.2.5. The Management Company has discovered circumstances on the basis of which it may be suspected that third parties obtained access to data and devices that provide access to the User Account, and the User Account may be used by unauthorized persons.

12.3. The Management Company has the right to close the website.

12.4. After the site is closed or in the cases specified in clauses 11.2 and 11.1 (if the User can no longer use the site):

12.4.1. Transactions made through the site remain valid in accordance with the terms and conditions set forth therein, and

12.4.2. Settlements arising from transactions carried out between the respective User and the Management Company must continue to be carried through the bank accounts of the Management Company before the end of the settlements with the User. The Management Company informs the Users who have active operations performed through the site with the User, who no longer has the right to use the site, when the right of the corresponding User to use the site has expired; and

12.4.3. The Management Company must pay a positive balance registered on the Subaccount (as at the expiry of the right to use the site), after deducting the amount to be paid by the Management Company to the User of Personal Cabinet bank account within 10 (ten) working days from the expiration of the right to use the site.

13. Sending notifications

Notifications sent to the User in the mailbox of the User's Account are considered received after 24 hours from the moment of sending.

14. Other conditions

14.1. For questions about the use of the site that are not governed by the Terms of Use, the laws of the Czech Republic are applied. If any clause of the Terms of Use is invalidated due to a conflict with the law, this does not affect the validity of the other clauses.

14.2. Disagreements and disputes arising in connection with the implementation of the Terms of Use are resolved by the parties primarily through negotiations. The Management Company has the right to unilaterally establish a procedure for out-of-court settlement of disputes. If the settlement of disputes by negotiation is not possible, the dispute shall be settled in a court of mutual jurisdiction. If the User is a legal entity, or an individual engaged in an economic or professional activity, or a person who moved to a foreign state after using the site, or whose place of business, place of residence or location at the time of filing a claim is unknown, the competent authority for settlement of the dispute must be the Arbitration Court at the Economic Chamber of the Czech Republic.

Information on the website is for informational purposes only. Any of the information can not be considered as a sales offer, investment proposal, financial advisory, tax, legal, accounting or any other professional advice or confirmation of the suitability of the investment, security or performance.

The website briefly summarizes the information about the investment objectives, propetry location, general market conditions, action plan and financial modeling results. The summary is not necessarily complete and any investors making an investment decision should not be limiting themselves only to the information provided on this website.

Before making any investment decision, investors are advised to carefully examine the investment opportunity, its related information and legal documentation. Investors are encouraged to consult their tax, legal and financial advisors before making any investment decision.

The website may contain future forecasts and forward-looking views, which cannot be regarded as firm commitments or definite future events. Forecasts and views can be influenced by known and unknown risks, uncertain situations and other factors that may impact the actual results of the investment, the implementation of action plans, and the return on investment in both negative and positive directions. Any inforamtion on company, real estate, risk, specifications, plans and financial projections may contain forward-looking views and assumptions.

Although Alliance Digital Fund makes efforts to present accurate and complete information as well as reasonable and prudent forward-looking views and assumptions, Alliance Digital Fund does not warrant the completeness, accuracy, correctness, relevance and timeliness of such information. Some of the information may be sources from the reliable third parties, but Alliance Digital Fund cannot take any responsibility for the actual correctness of information received from third parties.

Alliance Digital Fund assumes no obligations to update and publish any forward-looking information in a manner that would ensure its compliance with the actual results.

The expected average annual return presented in Alliance Digital Fund financial models has been calculated at of its publishing date and is based on the information available to Alliance Digital Fund at this time.

Past performance does not guarantee similar future returns.

All investment opportunities might be open to risk which may result in significant changes in the value of investments over time.

Investment principal and returns are not guaranteed.

Investment opportunities presented on Alliance Digital Fund website do not fall under the supervision of any Financial Supervisory Authority and the presented information is not verified or approved by supervisory authorities.

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Alliance Digital Fund (also "we", the "Company" or "us") are committed to protecting and respecting your privacy, fully implementing and complying with data protection principles and all relevant provisions of the Personal Data Protection Act (the "PDPA").

We collect, use and share your information when you use our Services. This Privacy Policy applies to our use of any of the information that we receive through our various websites, APIs, email notifications, applications, buttons and widgets, the ("Services" or "Crowdestate").

By using the site you agree to this privacy policy.

Information collection and use

Regardless of which country you access the Services from, reside in, or supply information from, you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy and you expressly authorize us to collect, transfer, use and process your information in Czech and any other country in which the Company or our vendors operates. In giving this consent, you understand that the laws on holding, processing, using and transferring personal information in Czech may vary and be less protective of your privacy than laws of your state or country.

We may collect and process information in following cases and ways:

• Information provided during your registration process (e.g. your name, address, telephone number and email address);

• Data delivered to us through our website or any other communication channel (e.g. correspondence, surveys etc);

• Data acquired through the use of our website (e.g. from your account information, details of transactions you carry out through any of our Services, cookies etc);

• Data acquired from public and other sources.

Amongst other, we may collect information and record details of your visits and interactions and the way in which you use Crowdestate, including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access; and (on a non-obligatory basis) other information which from time to time may be relevant to the effective provision of our Services.

We may collect information about the device or any computer you may use to access the Services, including, where available, the device's or computer's unique device identifiers, operating system, browser type and mobile network information as well as the device's telephone number, for system administration and to report aggregate information to our advertisers. We may associate Device information with Registration Information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

When you use the Services or view content on Crowdestate, we may automatically collect and store certain information in server logs, including but not limited to internet protocol (IP) addresses, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, internet service provider (ISP), clickstream data, language, viewed and exit pages and date or time stamps and cookie information.

Our Services use cookie technology to distinguish you from other users of our Services. This helps us to provide you with a good experience when you use our Services and also allows us to improve Alliance Digital Fund and our Services as they evolve over time. A cookie is a small data file that is transferred to your computer's hard disk. Alliance Digital Fund may use different types of cookies to better understand how you interact with our Services, to monitor aggregate usage by our users and web traffic routing on our Services, and to customize and improve our Services. Most Internet browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, some Services may not function properly if you disable cookies.

Storing your personal data

All information you provide to us is stored on our secure servers. SSL encryption technology is used to ensure secure communication between you and us.

You are responsible for keeping your chosen password confidential. We ask you not to share a password with anyone.

The transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Crowdestate. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Certain Services may from time to time include chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

Usage of the information

We use information held about you in the following ways:

• To enable use of our Services and to ensure that content from our Services is presented in the most effective, safe and secure manner for you and your computer or device.

• To enable us to effectively market real estate opportunities to you and any incidental or related services that we consider may be of interest to you.

• For internal operations, including: troubleshooting, data analysis, testing, research and service improvement; and to notify you about changes to our Services.

• To carry out our obligations arising from any contracts entered into between you and us.

• To perform the necessary due diligence on our users to ensure you are who you say you are, and to reduce the risks of fraud in our system and across our Services and platforms.

We may also use your data to improve your user experience, to provide you with information, marketing and advertising and for statistical purposes.

Disclosure of your information

We will never disclose your personal information to any third parties without your consent. Companies belonging to Alliance Digital Fund Group (parent, subsidiaries, affiliates) are not considered to be third parties.

We may disclose your personal information to third parties in the following specific cases:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

• If Alliance Digital Fund or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

• If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.

• In order to protect the rights, property or safety of Crowdestate, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and risk reduction.

Changing your information

The PDPA gives you the right to access information held about you. Your right of access can be exercised in accordance with PDPA.

You may ask us to change, improve or delete any partial, false or outdated information regarding yourself or your activities.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes.

Our Services may, from time to time, contain links to and from the third-party websites. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Security

All personal data is being kept in our secure and firewalled network. All our and our Group’s employees have confidentiality clause in their agreements.

Changes to privacy policy

Our privacy policy might be a subject to change. Any changes we may make to our privacy policy in the future will be posted on this page.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to SLOVENSKA 1694/23, 12000, PRAHA 2, VINOHRADY, Czechia or by email: info(at)alliance-digital.fund.

Information memorandum

Personal Data Processing at Alliance Digital Fund, a.s.

On 25 May 2018, Regulation (EU) No. 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46 / EC (general regulation on the protection of personal data). This document contains information related to the processing of personal data within Alliance Digital Fund , a.s.

1. Who manages your personal data or who is their administrator?

The administrator of your personal data is Alliance Digital Fund , a.s.. with registered office at SLOVENSKA 1694/23, 12000, PRAHA 2, VINOHRADY, Czechia, IČO: 07458835, registered in the Commercial Register kept at the Municipal Court in Prague, file number B 23786 (hereinafter referred to as "the Company").

2. Who will be a contact person for personal data protection and what are his / her contact details?

A contact person for the protection of personal data is a person appointed by the administrator or by a person processing the personal data on the basis of his professional qualities, which fulfils statutory tasks, in particular acts as a contact point for our clients in all matters related to the processing of your personal data and the exercise of your rights in accordance with the law.

The contact person for the protection of personal data within the Company is Mgr. Podobnyy Andrey. You can contact him with your submissions via mailbox [email protected]

3. For what purposes and on what legal basis will the data be processed (reason for processing)?

The purpose of processing your personal data is to offer products and services provided by the Company as an administrator and/or fund manager. Processing is understood as analysis and segmentation in order to customize the offer to your needs as much as possible.

We do not want to bother our clients with unnecessary and inappropriate communication. We use the processed personal data to better understand your needs and to be able to offer you the right solution in the form of our products offerings, our fund products, service communications, satisfaction surveys, etc. Communication takes place through all channels including electronic ones (e-mail, SMS, web interface).

The company is required to process personal data for the purpose of preventing the legalization of proceeds from crime and the financing of terrorism.

4. What of your personal data do we process?

We only use personal data that is necessary for the above-mentioned processing purposes. These include in particular:

identification data (e.g. name, surname, date of birth or birth number);

contact details (e.g. address, telephone number, e-mail);

socio-demographic data (e.g. age, gender, occupation);

product data (e.g. type of investments).

5. What sources does this information come from?

The data processed within the Company are the data which you have provided us - from your contracts with the Company, from public sources and from cooperating third parties.

6. For what purposes can you grant consent? To whom do you grant this consent?

Specifically, the purpose of your consent is:

the possibility to contact you with the Company's business offer up to 5 years after the last contract;

the ability to pass on your personal information to other companies to offer their services and products;

the opportunity to reach you with our offer also electronically.

You give consent to the processing of the above mentioned categories of your personal data the Company and to the transfer of your identification and contact details to other companies. Obtaining consent is currently not relevant, detailed information will be published on the company’s website if the consent is given.

7. Who can process your personal data?

The law on the protection of personal data makes it possible for the administrator to authorize the processor's processing. The processor of personal data is any natural or legal person who processes personal data on the basis of a legal regulation or mandate given by the administrator. If this procedure is used to process your personal data by the Company, this is only the case if the data protection standards of a particular processor are contractually guaranteed at least at the same level as within the Company and such processor complies with the legal conditions.

The processors that the Company uses to process your personal information are as follows:

investment intermediaries (tied agents) authorized to mediate the Company's products or managed funds;

providers or operators of information technology;

marketing agencies and market research agencies.

8. How long will your personal data be stored?

Personal data that the Company has acquired is retained for the duration of our mutual contractual relationship and for the next 10 years after its termination.

After this deadline or after the expiration and validity of your consent to the processing of personal data, your personal data will be erased, anonymized, or processed only to the extent and for purposes for which your consent is not required.

9. What are your rights during the processing of your personal data?

Where personal data is concerned, you have the following rights:

Right of access - you may ask the Company to access personal data that concerns you / is processed about you; the Company will provide you with a copy of the processed personal data. For the second and subsequent copy, the Company is entitled to charge a reasonable fee based on administrative costs.

Right to rectification - you may ask the Company to correct inaccurate or incomplete personal data that concerns you.

Right to erasure - you may ask the Company to erase your personal data if any of the following situations occurs:

Your personal data are no longer required for the purposes for which it were collected or otherwise processed;

You withdraw your consent based on which your personal data has been processed and there is no legal reason for processing it

You raise and objection to being the subject of decision-making based on the automatic processing of your personal data and there are no prevailing legitimate reasons fort such processing, or you raise an objection to the processing of your personal data for direct marketing purposes

Your personal data has been processed illegally;

Your personal data has to be erased to comply with a legal obligation established by the law of the Union or a member state which applies to administrator;

Your personal data has been collected in connection with an offer of information society services.

Right to restrict processing - you may request the Company to restrict the processing of your personal data if one of the following situations occurs:

You deny the accuracy of your personal data for the time it takes for the Company to verify the accuracy of the personal data

The processing of your personal data is illegal but you refuse to have it erased and request that its use be restricted instead

The Company no longer requires your personal data for the purposes of processing but you require it for determining, exercising and defending legal claims

You raise an objection to the processing of your personal data under Article 21 (1) of the Directive, until it has been determined whether the Company’s legitimate reasons outweigh your legitimate reasons

Right to portability – you have the right to receive personal data which concerns you, and which you have supplied to the Company, in a structured, commonly used and machine-readable format. This right, however, must not unfavourably affect the rights and liberties of other persons.

Right to withdraw consent – you have the right to withdraw your consent to the processing of your personal data for the purpose for which you granted it at any time; the withdrawal your consent is without prejudice to the processing of personal data prior to such withdrawal.

Right to object – you can raise an objection with the Company to the processing of your personal data for direct marketing purposes carried out on the basis of a legitimate interest of the Company at any time

Right to lodge a complaint – you have the right to lodge a complaint with the Company, at the address SLOVENSKA 1694/23, 12000, PRAHA 2, VINOHRADY, Czechia or with the supervisory body, specifically the Office for Personal Data Protection, at the address Pplk. Sochora 27, 170 00 Prague 7, www.uoou.cz.

10. Is your consent to the personal data processing voluntary or compulsory?

Granting consent to process your personal data for sending business offers is entirely voluntary (currently not relevant).