Loan agreement #[loan:publicId]

This document template is created for DEMO version.

CloudCredit.net, registered in the Commercial Register with the uniform registration No. 40000000000, legal address Maskavas street 322, Riga, Latvia, LV-1045, represented by the Member of the Board, acting on the basis of the Articles of Association, hereinafter - the Creditor, on the one hand,

and

[customer:name] [customer:surname] ([customer:persId]) from [customer:legalAddrCity], [customer:legalAddrStreet] [customer:legalAddrNumber] further as the Borrower, on the other hand,

agree on this loan agreement Nr. [loan:publicId]

Loan details

1. The basic concepts used in this Agreement:
1.1. Creditor / Lender - Limited Liability Company "CloudCredit.net", unified registration number: 40000000000, legal address: Vēžu iela 1, Riga, Latvia, LV-1045.
1.2. Loan repayment day - the day of the month when the Lender is obliged to pay to the Creditor the Amount due in accordance with the provisions of the Credit Agreement.
1.3. Loan repayment period - the term from the date of receipt of the Credit to the Credit repayment day.
1.4. Loan Grant Commission - the amount that the Lender is obliged to pay to the Creditor for operations related to Credit servicing.
1.5. Interest on the use of the loan - the interest rate expressed as a fixed interest for which the Creditor and the Borrower agree on the Credit Agreement for the use of the Loan using interest rates.
1.6. Loan term - the term by which the Borrower is obliged to pay to the Creditor the amount to be repaid.
1.7. Loan / Loan - A short-term or long-term loan, the amount of money that the Creditor assigns to the Loan in accordance with the particular Loan conditions and is allocated within a certain limit for a certain period.
1.8. Payment - a known, specific amount of money that the Lender shall pay to the Creditor under the Credit Agreement.

2. Rights and obligations of the parties:
2.1. During the term of the Credit Agreement, the Creditor has the right to grant the Creditor the Credits, and the Creditor undertakes to repay the received Credits in a timely manner to the Creditor and to pay the Payments, the Credits usage interest, the Credit Granting Commission and other payments in accordance with the Credit Agreement, the Client's applications and regulatory enactments.
2.2. The Lender's financial service is deemed to be provided when the Credit is transferred to the Loan Beneficiary's bank account.

3. Procedure for the signing of a credit agreement:
3.1. In order to register and conclude a Loan Agreement, the Borrower must meet the following criteria:

• The borrower is a natural person;
• The borrower is not less than 21 years of age;
• The permanent declared place of residence of the borrower is the Republic of Latvia;
• The borrower has an open bank account with any bank registered in the Republic of Latvia;
• At the time of sending a loan application and at the time of conclusion of the Credit Agreement, the borrower is legally competent and is not under the influence of alcohol, narcotic, psychotropic or toxic substances.

4. Loan granting procedure:
4.1. In order to receive the Loan, the Borrower is obliged to select and approve the Loan terms.
4.2. After the Credit-borrower has approved the Credit terms and received a text message confirming the Credit terms and conditions of the Lender, the Creditor undertakes not later than within 2 hours to transfer to the Credit Loan Account.
4.3. Once the Credit Provider has approved the Loan Conditions, it is considered that the Parties have mutually agreed on the terms and conditions of the Loan and they fully agree.
4.4. Fee or other charges to the Bank for crediting the Loan to the Creditor's account are covered by the Loan.
4.5. The Creditor is entitled to refuse to issue the Credit to the Creditor, informing the Creditor about the mobile telephone number or e-mail address specified therein.

5. Loan repayment:
5.1. On or before the Credit repayment date, the Borrower shall be obliged to pay the Repayment amount all or in accordance with the Credit terms.
5.2. The loan is to be repaid in the same currency as paid to the Borrower.
5.3. For Bank's operations with which the Credit is being repayed, the Credit Interest, the Credit Granting Commission shall be covered by the Borrower.
5.4. If the Borrower pays more than the amount to be repaid, the Credit shall be entitled to repay the overpaid balance to the Loan.
5.5. The Borrower is entitled to repay the Loan before maturity. Informing the Creditor about this at least 5 (five) business days in advance.
5.6. The borrower has the right to extend the loan repayment term.

6. Additional conditions:
6.1. This Agreement may be amended and / or supplemented only by agreement of the Parties.
6.2. The Agreement may be terminated by agreement of the Parties.
6.3. The creditor is obligated to notify in writing 10 (ten) days in advance of the unilateral termination of the agreement. A notice of termination may be sent by post, fax or electronic mail.
6.4. The Borrower is entitled to unilaterally terminate the Agreement at any time at least 7 (seven) working days in advance by giving notice to the Lender in accordance with the procedures specified in this Agreement.
6.5. The agreement concluded by the borrower is kept on the Account of the borrower profile, while the respective Credit agreement is valid.
6.6. All communications between the Parties shall be made in writing to each other.
6.7. A message sent in the form of a text message is deemed to have been received after 24 hours have elapsed since it was sent.

Fees agreement

This is fees agreement for campaign id: [fundraisingCampaign:uuid]

Detailed analysis

This is detailed analysis for campaign id: [fundraisingCampaign:uuid]

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PERSONAL DATA PROCESSING POLICY (PDPP)

regulating the purpose and means of processing personal data when providing Services to Users under the Framework Agreement concluded between the User and the Company effective as of 21 April 2022.

The operator of the Platform is Fintown s.r.o., Business ID: 17323657, with registered office: Prvního pluku 211/5, Karlín, 186 00 Prague 8, registered in the Commercial Register kept by the Municipal Court in Prague under the registration number C 369924, represented by Mr. Maxim Vichorevy, the company's managing director, contact e-mail: admin@fintown.eu ("Company")

The Company is the controller of the personal data of Users listed below. The Company has not appointed a data protection officer.

Scope and legal basis of processing

The Company processes such Users' personal data collected from Users to the extent necessary for the following purposes:

1) login data (email address and, where applicable, password, stored in encrypted form using a one-way hashing function) that are necessary for the conclusion and performance of the contract or for the implementation of measures taken before the conclusion of the contract,

2) identification data (in particular name and surname, date of birth, permanent or other residence) necessary for the performance of the contract and for the fulfilment of the legal obligation to which the Company is subject,

3) contact information (e-mail address, mobile phone number, User's bank account, User's payment reference number) that is necessary for the performance of the contract or for the implementation of measures taken prior to the conclusion of the contract,

4) the history of transactions in the Wallet (details of deposits, withdrawals, amounts invested, proceeds received and fees charged) which are necessary for the performance of the contract, for the fulfilment of the legal obligation to which the Company is subject and for the protection of the Company's legitimate interests in the event of legal disputes,

5) the history of the User's movements on the Platform (for example, data on pages visited and actions on the site, including data on the HW and SW equipment used and the User's internet connection), which is necessary for the performance of the Agreement and for the protection of the Company's legitimate interests in the event of legal disputes.

6) data necessary to fulfil the obligation to identify and control the customer pursuant to Act No. 253/2008 Sb., on certain measures against the legalization of proceeds of crime and terrorist financing (e.g. a copy of the identity card, information on the source of income, purpose of the transaction, status of politically exposed person, place of birth)

Purpose of Processing

The Company processes Users' personal data to properly and efficiently provide its services to Users, in particular:

1) for the purpose of communication with the User in the performance of contractual obligations,

2) for the purpose of fulfilling legal obligations, in particular obligations of a public law nature,

3) for the purposes of troubleshooting and preventing technical problems, providing user support and generally improving the services provided by the Company,

4) for marketing purposes, where the Company is entitled to send Users marketing offers to a reasonable extent.

The provision of the User's personal data is the fulfilment of a contractual and legal obligation and is a necessary condition for the conclusion of the Framework Agreement. The consequence of not providing personal data is that the Company cannot conclude a Framework Agreement with the User and the User cannot invest on the Platform.

The Company will never sell or rent personal information to other entities.

Storage, Transmission and Protection of Personal Data

Users' personal data is stored on devices located in the European Union. The company has conducted a risk analysis and, on the basis of this analysis, has adopted technical and organizational measures to maximize the security of personal data against unauthorized access by third parties.

The personal data of Users is stored from the moment of creation of the User's Profile according to Article 2 of the Platform Rules until three (3) full calendar years after the cancellation of the Profile according to Article 8 of the Platform Rules.

Users' personal data is not subject to automated decision-making. The Company is entitled to transfer Users' personal data to the following processors and recipients to the extent and under the conditions set out below:

1) to state administration authorities and other persons exercising the authority's powers for the purpose of fulfilling the Company's obligations under applicable law, 2) to subcontractors of web hosting, mailing, cloud and transport services for the purpose of fulfilling the Company's contractual obligations to Users,

3) to banking institutions, in particular the bank with which the Company maintains a bank account where the Users' funds are collected, and to the insurance company with which the Company is insured against liability for damages towards the Users, for the purpose of fulfilling the Company's legal and contractual obligations towards the Users,

4) to Internet advertising service providers to the extent of the Company's legitimate interests.

User Rights

The User has the right to access and correct his/her personal data if the Company processes inaccurate or outdated personal data of the User. Upon request, the Company will verify the timeliness and completeness of the personal data and, if it finds any errors, will arrange for correction (by correction, completion or complete removal). During the period of verifying the accuracy of the User's personal data, the Company is obliged to restrict its processing and inform the User about the remedy and cancellation of the restriction of processing.

The User has the right to have personal data deleted. The User is entitled to exercise the right to erasure only if the purpose for which the Company processed the User's personal data ceases to exist, the User objects to the processing of his/her personal data and the objection is found to be justified, the processing of the User's personal data is unlawful, or the law obliges the Company to erase the User's personal data. The right to erasure of personal data is limited and cannot be exercised by the Company if the Company is legally obliged to process the User's personal data or if the User's personal data is processed for the establishment, exercise or defence of legal claims.

The User has the right to limit the processing of personal data, on the basis of which the Company is obliged to store the User's personal data only and not to process it further. This right may be exercised by the User in the event that he/she considers that his/her personal data is processed inaccurately (see the right to rectification), that the Company is obliged to delete the User's personal data due to a conflict with the law, but the User personally refuses the deletion, or in the event that, the Company no longer needs the User's personal data for the purpose for which it was obtained and is obliged to delete the User's personal data, but the User personally refuses the deletion for the establishment, exercise and defence of legal claims, and if the User has objected to the lawfulness of the processing of his/her personal data (see right to object). At the same time, the Company is entitled to process the User's personal data after exercising the right to restrict processing only with the User's consent and for the establishment, exercise and defence of legal claims or for the protection of the rights of another natural or legal person and for the purposes of an important public interest of the State or the European Union.

The User has the right to object to the processing of personal data if the Company processes the User's personal data on the basis of its legitimate interest, for the purposes of public interest or public authority, for direct marketing purposes or for scientific or historical research.

The User has the right to transfer his/her personal data to another personal data controller and the Company is obliged to provide the User with the processed personal data in a machine-readable format (.xls, .xlsx, etc.) in case the Company processes the User's personal data on the basis of his/her consent or for the purpose of contract performance or if it is sensitive personal data processed on the basis of the User's explicit consent.

The user has the right to file a complaint against the processing of his/her personal data with the supervisory authority of the Office for Personal Data Protection at Pplk. Sochora 27, 170 00 Prague 7, Phone: 234 665 125, or by calling a line specifically set up for GDPR consultations: 234 665 800 or by e-mail: posta@uoou.cz.

Changes to the PDPP

The Company is entitled to unilaterally change the PDPP in accordance with the provisions of Section 1752 of the CC, however, it is obliged to notify the User of such changes at least two (2) weeks prior totheir effectiveness. If the User does not agree with the changes, the User is entitled to terminate the Framework Agreement until the effective date of the changes. The User acknowledges that unless the User terminates the Framework Agreement for the reasons set out in the preceding sentence, the changes are effective as of the date specified in the notice.

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GENERAL TERMS AND CONDITIONS TO THE FRAMEWORK AGREEMENT (GTC)

regulating the general terms and conditions of the contractual relationship between the User and the Company established by the Framework Agreement concluded through the Platform effective as of 1 December 2022

The operator of the Platform is Fintown s.r.o., Business ID: 17323657, with registered office: Prvního pluku 211/5, Karlín, 186 00 Prague 8, registered in the Commercial Register kept by the Municipal Court in Prague under the registration number C 369924, represented by Mr. Maxim Vichorevy, the company's managing director, contact e-mail: admin@fintown.eu ("Company")

1. User

A User may become any natural person over 18 years of age who has sufficient intellectual qualities and understands the Czech language sufficiently to understand all terms and conditions of the Contractual Documentation.

The User, regardless of whether being an entrepreneur, always acts as a consumer in a contractual relationship with the Company.

2. Obligations of the User

The User is obliged to act personally in relation to the Company at all times. The Company is entitled to consider all actions taken when creating a Profile and when using it as actions taken personally by the User.

The User is obliged to use the Platform in a manner that is not detrimental to the Company or third parties, in accordance with Article 1 of the Platform Rules. The User is obliged to provide the Company with the truthful information provided in the Profile and to notify the Company of any changes thereto without undue delay in accordance with Article 4 of the Platform Rules.

The User expressly acknowledges the Company's right to set off its due and undue claims against its obligations to the User under the Framework Agreement.

3. Conclusion of the Framework Agreement

The Framework Agreement between the User and the Company is concluded exclusively remotely via the Platform, when creating a Profile in accordance with Article 2 of the Platform Rules. The text of the Framework Agreement is determined by the Company and the User has no possibility to change or amend it, he/she can either accept or reject it completely.

The User accepts the generated offer of the Framework Agreement on the Platform by clicking the "Accept and Sign" button. At this step, the Framework Agreement comes into force. The Framework Agreement enters into force and is binding on both parties after the first payment of the User is credited, the User is verified and the Profile is approved by the Company in accordance with Article 2 of the Platform Rules.

4. Investments

The details of underwriting and commencement of Investments and the performance of obligations thereunder shall be set out in the GTCPL.

5. Communication between the User and the Company

The User communicates with the Company primarily through the Platform, where the contact form is also available. The User may also contact the Company at the e-mail address and hotline listed on the Company's website. The Company will answer the User's questions within 7 days at the latest by e-mail.

The Company communicates with the User primarily through the Platform, whereby in principle all changes to the Profile are notified to the User on their Profile and by email. The User has the option to change the frequency of email notifications in the Profile settings, but is not authorized to disable them completely. Important messages, which are in particular messages about the commencement or termination of the Investment, changes to the Contractual Documentation, blocking of the Profile, termination of the Framework Agreement, will be sent to the User immediately outside the set frequency of notifications.

The User expressly accepts that in matters relating to the Framework Agreement and the performance thereof, communication between the Parties will be made electronically via the Platform and by e-mail, that such communication has the force of a written communication, and that the sender is entitled to treat such communication as having been received on the day following its dispatch. The User undertakes to familiarize themselves with the content of all messages sent to them by the Company in this way.

6. Liability of the Company for damages

The Company is obliged to provide the Services to the User within the agreed scope and terms. The Company is liable to the User for damages incurred as a result of the Company's breach of its contractual or legal obligations. The Company is not liable for damages if the breach of its obligations is due to a conflict between several different obligations and the Company has given priority to a more important interest - in this respect, the legal obligation prevails over the contractual obligation, the obligation under special regulations prevails over the obligation under general regulations and the avoidance of conflicts of interest prevails over other obligations. The Company is not liable for damage that occurs under circumstances excluding liability pursuant to Section 2913(2) of the Civil Code, i.e. due to an extraordinary, unforeseeable and insurmountable obstacle arising independently of the Company's will. Such obstacle includes, but is not limited to, unexpected failure of the Platform, failure of the Internet connection or software, or failure of any other technical means.

The Company is not liable for damage to the extent that it was not foreseeable. In particular, how the User intends to dispose of the payment funds obtained from the investment is considered unforeseeable.

7. Resolution of User complaints and objections

The User is entitled to contact the Company with complaints and objections via its contact email admin@fintown.eu. The Company undertakes to resolve complaints and objections within seven (7) days and, in the case of a particularly difficult problem, within a period to be determined and communicated to the User within seven (7) days.

Any out-of-court resolution of consumer disputes is provided by the Czech Trade Inspection or the User may use the European Dispute Resolution Platform online operated by the European Commission.

8. Termination of the Framework Agreement

The Framework Agreement may be terminated:

1. by the User withdrawing from the Framework Agreement without giving reasons within fourteen (14) days of its conclusion using the form available on the User's Profile; the User expressly requests that the Company commence the provision of Services before the expiry of the withdrawal period, therefore the Company is entitled to reimbursement of the fees for the Services provided to the User prior to such withdrawal; the withdrawal is effective upon its delivery to the Company,

2. by notice from the User without giving any reason, using the form available on the User Profile; the notice period is fourteen (14) days,

3. termination by the Company for a serious breach of the User's obligations, for which the Company has blocked the User's account pursuant to Article 6 of the Platform Rules and the User has not fulfilled the conditions for its release or objected to the blocking for a period of one (1) month, or its objections have been rejected by the Company; the notice period is fourteen (14) days,

4. by notice from the Company because the Company will no longer provide the Services; the notice period is fourteen (14) days.

From the moment of delivery of the withdrawal or termination of the Framework Agreement to the other party, the User will not be allowed to subscribe for new Investments. The termination of the Framework Agreement is treated in the same way as if the User had proposed to terminate all its investments pursuant to Article 5 of the GTCPL, which proposal cannot be revoked by the User.

After the return of the Invested Amounts from all investments of the User, the Company will cancel the Profile in accordance with Article 7 of the Platform Rules.

Death of the User is not a reason for termination of the Framework Agreement. The Company will allow the Profile to be disposed of by the administrator of the estate or a beneficiary of the estate on the basis of a final decision issued in the succession proceedings. If there are more than one such person, the Company will allocate the funds in the Wallet and the User's Investments according to the specified shares, taking into account that the Profile may belong to only one person at any time.

9. Changes to the GTC

The Company is entitled to unilaterally change the GTC in accordance with the provisions of Section 1752 of the CC, but is obliged to notify the User of such changes at least two (2) weeks before their effectiveness. If the User does not agree with the changes, the User is entitled to terminate the Framework Agreement until the effective date of the changes. The User acknowledges that unless the User terminates the Framework Agreement for the reasons set out in the preceding sentence, the changes are effective as of the date specified in the notice.

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GENERAL TERMS AND CONDITIONS FOR LOAN PARTICIPATIONS

(GTCPL)

governing the manner in which the User participates with its Investment in the Loan under the Framework Agreement concluded between the User and the Company

effective as of 1 November 2022

The service provider is Fintown s.r.o., Business ID: 17323657, with registered office: Prvního pluku 211/5, Karlín, 186 00 Prague 8, registered in the Commercial Register kept by the Municipal Court in Prague under the registration number C 369924, represented by Mr. Maxim Vichorevy, the company's managing director, contact e-mail: admin@fintown.eu ("Company")

1. What is Investment

The Company enters into Loan Agreements with third parties (the Borrowers) whereby the Company makes a Loan to the Borrower to finance a specific property and the Borrower agrees to pay interest on the proceeds representing a percentage of the rent collected on an ongoing basis and to repay the Principal together with the Interest on the Principal upon demand.

Through the Investment, the User participates in the provision of the Loan and in a proportionate share of the interest received on the proceeds. The User has information about the return percentage of his/her Investment for the entire duration of the Investment. The rent collected does not include security deposits, deposits for services connected with the lease or compensation for damages, includes any interest for late payment, penalties or compensation for legal costs and is reduced by the actual costs incurred in collecting debts from the tenant.

Where reference is made in this GTCPL or other related documents to a leased property, this includes a property whose tenant is temporarily Vihorev Management Company Ltd. Business ID: 06137512. All legal actions regarding the Investment are conducted through the Platform in accordance with the Platform Rules. The User declares that he/she is not restricted in the use of the funds in the Wallet for Investments, that they are his/her sole property or that he/she subscribes to Investments with the consent of the other spouse and to the extent appropriate to his/her financial circumstances. The User acknowledges that the funds raised by the Company under the Investment may be used to finance the purchase of the relevant property and to pay the related liabilities as well as any other costs relating to the relevant property. The User also acknowledges that the funds received by the Borrower under the Loan Agreement may be used to pay fees and other charges related to the provision of the Loan, in particular fees to the Company or fees related to the establishment of security for the Loan.

2. Offer and Subscription of Investments

The Company will publish the following information on the Platform for each Offer:

- basic description of the property,

- the current volume of investments that can be subscribed and the yield percentage

- the duration of the Investment until its completion

- the minimum and maximum amount invested per User (usually between EUR 50 and EUR 500,000)

The User shall subscribe to the Investment by filling in the Invested Amount in the specified range for the Investment offer and confirming it by clicking on the "Invest" button. The Company deducts from the User's Wallet an amount equal to the Invested Amount and the Investment is initiated. At this point, the Participation Subcontract is concluded between the Company and the User.

The User may only subscribe to Investments for which he/she has sufficient funds in the Wallet.

3. Rights and Obligations during the Investment

For the duration of the Investment, the User is entitled to a Yield in the form of a share of the Yield Interest in the proportion of his/her Investment to the total volume of the Offer. The User acknowledges that the Yield may change as the rent increases or decreases according to market conditions or in some months may be zero if the rent for that month has not been paid. The proceeds are credited to the User's Wallet within three (3) business days after the Company receives the performance from the Borrower.

The Company informs the User that the Proceeds are subject to income tax as other income under Section 10 of the Income Tax Act and that the User is obliged to declare such income and pay the relevant tax thereon.

The User's claim to the Proceeds is secured by the User's lien on the proportionate part of the Company's claim against the Borrower under the Loan Agreement according to the ratio of the Invested Amount to the Offer Amount. In the event that the Company defaults on its obligations to the User, the User is entitled to demand that the Borrower perform its pro rata share of its obligations under the Loan Agreement directly to the User.

The Investment represents a contractual relationship solely between the Company and the User. The User is not entitled to transfer, lease, grant any rights to or allow any other person to dispose of the Investment, unless the User receives the express prior written consent of the Company.

If the User disagrees with the Company's procedure in providing the Services, he/she has the right to object pursuant to Article 7 of the GTC.

The Company is entitled to decide that the User will be granted the status of a Premium Account ("Premium"), in particular if the User holds at least ten (10) Investments at any time or meets other conditions specified by the Company ("Premium Terms and Conditions"). In the event that the User ceases to comply with the Premium Terms and Conditions, the Company is entitled, but not obliged, to withdraw the Premium from the User. There are certain benefits associated with the Premium Account as further defined on the Company's website www.fintown.eu, including the right to priority customer support and the right to participate in Investments associated with a special bonus ("Bonus"). The amount of the Bonus and the conditions for obtaining it, including the length of the investment horizon that the User must comply with, are listed on the Company's website www.fintown.eu. If the User fails to comply with these conditions, in particular if his/her Investment expires before the expiry of the specified investment horizon, the User's right to the Bonus expires.

4. Changes in Investment

From the time of publication of the Offer, the Investment is unchangeable.

In particular, the User is not entitled to claim direct performance for the Borrower or to influence the amendment of the Loan Agreement or the method of recovery of the claim against the Borrower. These steps are fundamentally and fully within the Company's responsibility.

5. Termination of Investment

The investment terminates by:

1. the expiration of the term of the Investment, which is also the expiration of the agreed term of the Loan Agreement,

2. a proposal for termination of the Investment or part thereof by the User, which the Company is not obliged to accept; the User is entitled to withdraw his/her proposal for termination of the Investment until the Company accepts it, however, this does not apply if the User made it in connection with termination of the Framework Agreement pursuant to Article 8 of the GTC; for termination of the Investment at the User's proposal, the User will be charged a fee of 0.9% of the Invested Amount,

3. the Company's decision to terminate the Investment early due to an amendment to the Loan Agreement,

4. withdrawal of the User from the Framework Agreement within fourteen (14) days of its conclusion; for termination of the Investment due to withdrawal from the Framework Agreement, the User will be charged a fee of 0.9% of the Invested Amount.

Upon termination of the Investment, the Company will return the Invested Amount to the User's Wallet within three (3) business days after the record date, which is:

- upon termination of the Investment pursuant to point 1 or 3 above, repayment of the Loan and Interest on the principal by the Borrower,

- upon termination of the Investment according to point 2 above, subscription of the Investment by another user

- upon termination of the Investment pursuant to point 4 above, delivery of the termination of the Framework Agreement to the Company.

The User acknowledges that in case of necessity to recover the debt from the Borrower, the Company is entitled to deduct from the recovered performance its costs incurred for the recovery and to divide the difference between the Users.

The return of the entire Invested Amount upon termination of the Investment pursuant to this Article of the GTCPL extinguishes all claims of the User to the Investment Proceeds.

6. Changes to the GTCPL

The Company is entitled to unilaterally change the GTCPL in accordance with the provisions of Section 1752 of the Civil Code, but is obliged to notify the User of such changes at least two (2) weeks before their effectiveness. If the User does not agree with the changes, the User is entitled to terminate the Framework Agreement until the effective date of the changes. The User acknowledges that unless the User terminates the Framework Agreement for the reasons set out in the preceding sentence, the changes are effective as of the date specified in the notice.

Annex 1

Risk Warning

The investment involves a number of risks. This annex lists those risks that the Company considers to be the most significant. The summary of these risks is not exhaustive and is not a substitute for the User's own professional analysis and is not a recommendation of any kind for an Investment. Any decision of the User regarding the Investment should be based on the information contained in the Pre-Contractual Information, the Contractual Documentation and the Framework Agreement, and in particular on the User's own analysis of the benefits and risks associated with the Investment. Above all, the User must be aware that he/she always risks losing part or all of his/her Investment.

The Company draws the User's attention in particular to the following:

1. The Investment represents a high-risk venture, as there is a risk of losing up to all the funds provided by the User (the entire User's Investment). The investment is then only for Users for whom the possible loss of part or even all of the funds provided will not mean a significant deterioration of their financial situation.

2. Before making an Investment, the User should carefully consider his/her objectives, as well as the risks, fees and expenses related to the Investment, as well as taxation in relation to his/her personal circumstances. The value of the Investments and any returns may go down or up. Any past performance, estimate or forecast is not a reflection of future or probable performance.

3. The yield on Investment is also influenced by economic prospects, political and legislative realities or factors affecting the national economy in general. These factors may also lead to losses on the part of the User.

4. If the amount due under the Loan Agreement with third parties (Borrowers) is not repaid to the Company, or if any other adverse development or adverse circumstance affecting the third party's (Borrower's) performance under the Loan Agreement occurs, this may result in the total loss of funds provided by the User.

5. The Investment does not establish any legal relationship between the User and the Borrower. Even if any of the situations described in clause 4 occur, the User has no direct claim against the Borrower.

6. The Investor must consider the credit profile and risk of the Borrower, as the amount of consideration paid to the Investor in respect of the Investment corresponds to the amount of funds the Company will receive in repayment of the Loan.

7. If the Company charges fees, the Investment may also be affected by the amount of such fees, primarily because fees are charged regardless of whether

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The User makes a profit or loss on the Investment. Before Investing, the User should familiarize himself/herself with whether and what fees the Company charges.

8. There is a risk of insolvency of the Company, both as a result of unfavourable market developments and due to an error in the business judgment of the Company's management. This may also affect the Company's ability to meet its obligations, including to Users. Whilst the Company has acted with due regard to its professional and expert experience and has certain mechanisms in place to minimize such risks, it cannot be excluded that such an event may occur and the User may lose all or part of the Investment as a result.

9. The Company, as a creditor, has the right to collect amounts due under the Loan Agreement. The Company decides on the method of recovery of the amount due at its own discretion, acting with due diligence to ensure that the amount recovered from the Loan is as high as possible. The Company makes no representations or warranties with respect to the Borrower's ability or willingness to perform its obligations under the Loan Agreements and to repay the applicable Loans. The Company may, but need not, evaluate or monitor on an ongoing basis the Borrower's ability to perform its obligations under the Loan Agreement and to repay the Loan to which any of the Participations relate. The Company is not obliged to take any enforcement action, nor it is obliged to take any action or make any recommendations unless the Company is required by law to do so. Furthermore, the Company is not obliged to follow any requests, recommendations or instructions of Users in this respect.

10. The Participation Agreement establishes a contractual binding relationship between the Company and the User. On the basis of this relationship, the Company is entitled to change it in specified cases during its duration, even without the User's consent. The Company informs the User of any changes to this relationship in the agreed manner.

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PLATFORM RULES

governing the operation of the Internet platform available at www.fintown.eu and through the Company's mobile application ("Platform"), on which the Company provides the Services to Users pursuant to the Framework Agreement concluded between the User and the Company

effective as of 1 December 2022

The operator of the Platform is Fintown s.r.o., Business ID: 17323657, with registered office: Prvního pluku 211/5, Karlín, 186 00 Prague 8, registered in the Commercial Register kept by the Municipal Court in Prague under the registration number C 369924, represented by Mr. Maxim Vichorevy, the company's managing director, contact e-mail: admin@fintown.eu ("Company")

1. Basic Rules for Using the Platform

The Platform is available to Users at www.fintown.eu and through the Company's mobile application.

The platform is available 24 hours a day, 7 days a week. The Company undertakes to rectify any defects in availability as soon as possible. The Company undertakes to carry out regular maintenance in such a way as to minimize the impact on the availability of the Platform to Users. However, the company

is not liable for any damages resulting from the temporary unavailability of the Platform. All content of the Platform and the publicly accessible parts of the www.fintown.eu website, including the software solution, are copyrighted works protected by copyright law and the exercise of proprietary rights in them belongs to the Company, unless otherwise stated in specific cases. Some elements of the Platform and the Website may be trademarked, in which case they may not be used in any way without the Company's permission.

No one may use the Platform and the Website for illegal, fraudulent or illicit purposes or seek to gain unauthorized access to user profiles, computer systems or networks. No person shall take any action that could damage, overburden or render inoperable any part of the Platform or the Website, or upload any virus, Trojan horse or other program that could damage the property of the Company or any third party.

Users are obliged not to upload any content to the Platform that could be considered defamatory, vulgar, illegal or infringing on the rights of others.

2. Creation of a User Profile

The person referred to in Article 1 of the GTC may become a User. In order to conclude the Framework Agreement with the User, it is necessary to obtain personal data from the User to identify him/her and verify his/her identity.

The User's profile is created when the User registers on the Platform. The User may use the Profile in full only after the Framework Agreement has come into force after these steps have been taken:

1. Registration of e-mail address, name and surname, confirmation of consent to the PDPP,

2. Generation of the Framework Agreement and its signature via SMS confirmation, 1

3. Crediting the User's first payment to the Company's bank account, marked with the User's payment reference number and transferred from the User's Bank Account,

4. Checking that all the requirements have been met and that the Profile has been approved by the Company. After creating a Profile, the User appears on the Platform under his/her first and last name, or under a nickname if he/she chooses.

3. Profile Security

The Profile is accessible to the User after entering the e-mail address indicated on the Profile and the password chosen by the User or after authorization by a third party. The User is responsible for ensuring that the password used to log in to the Profile or to the third-party account used to log in is sufficiently complex and unique, that it cannot be cracked by normal means and that he/she does not disclose it to a third party or otherwise allow another person to access his/her Profile. If the User discovers that another person has gained access to his/her Profile, he/she shall immediately notify the Company.

The Company will use its best efforts to prevent unauthorized access to Users' personal data by any other person. Users' personal data is processed in accordance with the PDPP.

4. Personal Data of the User

The User's profile contains the User's personal data and all contractual documentation governing the contractual relationship between the User and the Company. This information is available in the "My Profile" section.

The User's Profile contains the User's personal data that the Company needs for the performance of its contractual obligations. These are:

1) identification data: name and surname, date of birth, permanent address or other residence,

2) contact details: email address, mobile phone number, registered User's bank accounts, User's payment reference number.

The User is obliged to provide the Company with true information about his/her Profile and to notify the Company of any changes. The User may do so by pressing the "Correct Data" button on the User's Profile, whereby:

a) only notify the Company of the change in identification data,

b) confirm the change of email address by clicking on the link in the email delivered to that email address,

c) confirm the change of mobile telephone number by entering the verification code delivered to that telephone number,

d) register a new Bank Account by making a payment of at least CZK 1 from this Bank Account.

On the User's Profile, in the subsection "Documents", copies of all contractual arrangements governing the contractual relationship between the User and the Company are stored. The Company provides the User with the no longer effective versions of the contractual provisions upon request. The Company is the controller of the User's personal data, including the data provided on the User's profile, and manages it in accordance with the PDPP.

5. Wallet

The Profile includes a Wallet, through which the User invests in Loans and receives a Return on Investments. The Wallet is not a payment account within the meaning of Act No. 370/2017 Sb., on payment transactions.

In order for the Framework Agreement to become effective, the User is obliged to make the first deposit of funds into the Wallet by transferring funds of at least EUR 1 to the Company's bank account specified in the header of the Framework Agreement from the Bank Account in the User's nameThe User can make additional deposits only from the Bank Account registered in the Profile. The User can withdraw only to the Bank Accounts registered in the Profile, in accordance with Article 4 of the Platform Rules. All deposits of funds must bear the User's payment reference number specified in the header of the Framework Agreement for the purpose of identification of the User. The Company is not obliged to make deposits not marked with the User's payment reference number. If the User fails to provide the correct information when requested, the Company will return the funds to the Bank Account from which it was received. The Company is entitled to charge a fee of EUR 10 for each incorrectly marked deposit. The Wallet is kept in euros (EUR). Also, all transactions are carried out in Euros (EUR) and are rounded to the nearest cent in favour of the Company. The Company is entitled not to redeem a deposit received in another currency and to return it to the bank account from which it was received. The Company is also entitled to charge a fee of EUR 20 for deposits received in other currencies. Depositing funds in the Wallet is entirely at the User's discretion and the Company does not provide any interest or other benefits to the User for such funds depending on the length of time the funds are deposited in the Wallet.

Deposits to and withdrawals from the Wallet will be made by the Company no later than the end of the next business day. In case of multiple withdrawals from the Wallet in one day, the Company is entitled to charge a fee of EUR 1 for the second and subsequent withdrawal in one day.

The Company is not obliged to carry out the transaction if:

- the transaction violates the terms of the Contractual Documentation, in particular the Platform Rules,

- the execution of the transaction would cause the Company to violate an effective legal regulation or an enforceable decision of a court or governmental authority,

- Wallet balance is not sufficient to complete the transaction,

- the Company suspects that the transaction was not entered by the User. The User is entitled to dispose of the funds in the Wallet exclusively through the Platform and up to the amount of the balance in the Wallet. The Company is authorized to dispose of the funds in the Wallet only for the following purposes:

- fulfilment of the User's due debt to the Company,

- compliance with an enforceable decision of a court or government authority. In case of doubts about the correctness of the transaction, the User may submit an objection according to Article 7 of the GTC and the Company will decide on it within three (3) working days.

6. Blocking a Profile

The Company is entitled to temporarily block the User's Profile in case of:

1. suspected unauthorized access to the Profile,

2. suspicion of making changes to the Profile by a person other than the User,

3. conducting transactions in unusual quantities or volumes,

4. suspected risk of damage,

5. doubts about the accuracy of the User's personal data,

6. serious or repeated breach of the User's obligations. The Company always informs the User of the temporary blocking of the Profile and informs him/her of the conditions under which the Profile will be made available again and informs him/her of the possibility to object to the Company's procedure pursuant to Article 7 of the GTC.

7. Profile Cancellation

The Company cancels the User's Profile upon termination of the Framework Agreement pursuant to Article 8 of the GTC and upon termination of all Investments of the User by any of the methods pursuant to Article 6 of the GTCPL, payment of the Invested Amounts and settlement of fees. The Company will transfer the balance in the Wallet to the registered Bank Account designated by the User, otherwise to the Bank Account that the User registered on the Platform last, within five (5) working days of cancellation of the Profile. During the period from the termination of the Framework Agreement until the end of all Investments of the User, the User is not entitled to subscribe for new Investments or deposit funds into the Wallet. Deposits received in violation of this provision will be returned by the Company to the bank account from which they were received and the Company is entitled to charge a fee of EUR 10 for each deposit so received.

The Company may cancel the User's Profile if the Framework Agreement pursuant to Article 3 of the GTC has not been concluded within three (3) months of its creation.

8. Changes to the Platform Rules

The Company is entitled to unilaterally change the Platform Rules in accordance with the provisions of Section 1752 of the CC, but it is obliged to notify the User of such changes at least two (2) weeks before they take effect. If the User does not agree with the changes, the User is entitled to terminate the Framework Agreement until the effective date of the changes. The User acknowledges that unless the User terminates the Framework Agreement for the reasons set out in the preceding sentence, the changes are effective as of the date specified in the notice.