These Terms of Service apply from 16 September 2025, taking effect immediately for new customers and on 1 October 2025 for existing customers.

1.1 We are Lightyear Europe AS, a private limited company incorporated in Estonia (company number 16235024) with its registered address at Tallinn, Volta tn 1, Estonia ("we", "us", “our” or "Lightyear").

1.2 Lightyear is authorised and regulated by the Estonian Financial Supervision and Resolution Authority as an investment firm ("EFSA").

2.1 This document (the “Agreement”) together with the Service Fees and Schedules and any other terms that you and we agree from time to time, create a legally binding agreement between you and Lightyear. We also provide you with other important information which relates to the services Lightyear provides to you (the “Services”).

2.2 You declare that you accept and understand that the official language of Lightyear is English. Lightyear will make available information and all documents, including the Lightyear mobile and web application (the “App”) and the Services, the website, key information documents, and customer communications including marketing materials available to you in English. If this Agreement and/or other documents are translated and made available to you in another language, the English version of this Agreement and other documents are considered as original versions and will prevail over the translated versions.

2.3 You understand and agree that using the App and the Services in any other language than English (if available) is optional and only the English version is always guaranteed to be available to you. If you wish to use the App and receive the Services in another language, you agree that the translation may not cover all the Services and customer communications we provide to you.

2.4 This Agreement relates only to the provision of investment services by us to you through the Lightyear App. Any other services will be governed by our other terms as appropriate. This Agreement will apply to you from the date that you accept it. You will receive a copy of this Agreement from us in a durable medium, i.e. via email that you signed up with.

2.5 We have disclosed certain important information in the Lightyear App and on our website. You need to read this information carefully before submitting any instruction via the Lightyear App (an “Order”). An Order is your instruction to carry out a transaction through the Lightyear App or any of the Services. Once executed, an Order constitutes a binding transaction (a “Transaction”).

Execution-only services (no advice)

3.1 We provide an execution-only (no advice) service with respect to your Orders in financial instruments available via the Lightyear App (the “Instruments”). You may submit Orders which we execute ourselves or transmit to a third-party broker we use to execute Orders for you (the “Third-Party Broker”). We do not assess whether any Instrument is suitable for you.

3.2 To use the Services, you must open an account with us in your name through the Lightyear App (the “Account”), which you will use to submit Orders and access the Services.

3.3 We don't provide personalised investment recommendations, investment advice or tax advice. Any explanation or information we give you as part of our Services is not intended, and should not be considered, to be advice. Any decision to acquire or sell an Instrument is solely yours and we are not responsible for such decisions.

Order execution process

3.4 We will execute your Order ourselves or transmit your Orders to a Third-Party Broker. The Third-Party Broker will then be responsible for execution (or onward transmission for execution).

3.5 When you submit an Order, you’re committing to a binding Transaction. You can only cancel an Order before the we or the Third-Party Broker send it to the relevant trading venue for execution or other third parties, as applicable (e.g. if the Instrument is not tradable). You can cancel Limit Orders before they execute.

3.6 We cannot control the execution of your Orders once we transmit them to a Third-Party Broker or the market, and there is no guarantee that either we, the Third-Party Broker, or the market will accept your Order. Your Order may be rejected if it poses excessive risk to us, the Third-Party Broker, or the market, or if trading is unavailable or suspended for the Instrument.

Your withdrawal rights

3.7 If you are a consumer (i.e., an individual acting for purposes which are outside your business, trade or profession), you have a period of fourteen (14) calendar days from your acceptance of this Agreement to withdraw from this Agreement without giving any reason. If you would like to withdraw from this Agreement, please let us know by email at support@lightyear.com.

3.8 You cannot withdraw from this Agreement once you have submitted an Order or otherwise in circumstances where the mandatory provisions of applicable law (meaning all laws, regulations, rules and official guidance we must follow, including anti-money laundering requirements) do not provide you with such right of withdrawal unless we explicitly accept your notice of withdrawal.

3.9 Your withdrawal from the Agreement shall not affect any Order already executed under this Agreement which has been affected by fluctuations in the financial markets which will thereafter remain binding upon you.

3.10 For the avoidance of doubt, the withdrawal provisions are separate from the right of termination covered in Clause 34 and you will always have the right to terminate this Agreement.

Appropriateness of complex Instruments

3.11 If we offer any complex Instruments through the Lightyear App — meaning financial instruments that are not considered “non-complex” under applicable law (for example, complex bonds, certain structured products, or other products requiring specialist knowledge) — we will assess whether they are appropriate for you based on your investment knowledge and experience, and whether you understand the risks involved. We will not carry out this assessment for non-complex instruments, such as listed shares, UCITS units, or money market instruments.

3.12 If you do not provide us with accurate and complete information about your knowledge and experience, we may be unable to assess whether a Service or Instrument is appropriate for you. If, based on the information you provide, we believe a Service or Instrument is not appropriate for you, we will warn you.

3.13 If you choose to proceed with a Service or Instrument despite such a warning, or if we cannot carry out the assessment because of missing or incomplete information, you may not fully understand the risks involved, and your interests may be less protected.

3.14 If we are required to do so by applicable law, or where we reasonably believe proceeding would be contrary to your best interests, we may refuse to execute an Order for a complex Instrument.

3.15 You remain responsible for all decisions about the Orders you place with us. If you are unsure whether an Instrument is appropriate for you, or if any part of this Agreement is unclear, you should seek independent professional advice.

Fees and charges

3.16 We may charge you fees and charges for using our Services (the “Service Fees”) which are set out and kept up to date on our website. See more on the Service Fees in Clause 25. Third-party charges, such as those applied by issuers, payment providers, custodians, or other service providers, may also apply and are covered further in Clause 26.

Availability of our Services

3.17 We offer our Services in select countries within the European Economic Area and the list may change in time. If you have opened an Account but thereafter decide to move to a country or region where our Services are not available, we may have to close your Account, pursuant to Clause 34 of this Agreement.

Customer classification

3.18 We are required by law to categorise you as one of three types of client under the Estonian Securities Market Act:

• a retail client (tavaklient) – a client who is not a professional client and benefits from the highest level of regulatory protection;
• a professional client (asjatundlik klient) – a client meeting the criteria in § 46(2) of the Estonian Securities Market Act; or
• an eligible counterparty (võrdne vastaspool) – as defined in § 461(2) of the Estonian Securities Market Act.

3.19 We will treat you as a retail client unless you ask to be classified otherwise and we agree in writing. If you are a professional client and ask to be treated as a retail client, or if you are an eligible counterparty and ask to be treated as a professional or retail client, we will treat you as such for all services, transactions, and instruments. If you are unsure about your classification, you should seek advice before making investment decisions.

3.20 If we classify you as a professional client or eligible counterparty, you will lose certain protections available to retail clients, including more detailed information disclosures, some best execution obligations, and, in some jurisdictions, access to investor compensation schemes. You may request a change to your classification at any time, but we may refuse.

4.1 By opening a Lightyear Account and using our Services, you agree that:

4.1.1 you will, at all times, behave reasonably and honestly towards us, our employees, and anyone acting on our behalf;

4.1.2 you will not engage in behaviour that is inappropriate, abusive, discriminatory, harassing, defamatory, or otherwise unfair when using our Services or interacting with us. This includes, but is not limited to, the use of offensive language, threats and spam;

4.1.3 if any of the information you have provided to us changes, you will update us as soon as reasonably possible;

4.1.4 you will cooperate fully with any requests we make for additional or updated information or documents at any time during your relationship with us, in order to satisfy our legal, regulatory, or internal risk management obligations. This may include, without limitation, proof of identity, proof of address, bank statements, and documents evidencing the source of funds or wealth. You must provide such information within the timeframe we specify;

4.1.5 you must not open or maintain a Lightyear Account if you are physically resident in, or become resident in, a jurisdiction where our Services are not offered, restricted, or prohibited. You must notify us immediately if your residency changes to such a jurisdiction. You are solely responsible for ensuring that you are legally permitted to access and use the Services from your jurisdiction, and we shall have no liability for any consequences arising from your failure to do so;

4.1.6 your use of the Lightyear App will always comply with this Agreement and applicable law;

4.1.7 you will not use any algorithms or electronic trading programs or systems to interact with the Lightyear App;

4.1.8 you must not use your account to trade on behalf of third parties, unless expressly permitted by us;

4.1.9 you will not, by any action or omission, deliberately, recklessly, or negligently engage in market abuse or market manipulation, nor encourage or require others to do so. If we suspect your Account is involved in market abuse or market manipulation, we reserve the right to take appropriate actions, including refusing to act on your instructions or taking actions outlined in Clause 34. We are not obligated to provide reasons for these actions or be liable for any resulting losses;

4.1.10 your use of market data related to Instruments and transactions executed via the Lightyear App provided through the Lightyear App (such as real-time or delayed prices, volumes, and other related data, collectively "Market Data") is strictly for purposes connected to our Services. You agree not to:

(a) use Market Data for commercial purposes, or

(b) publish or share Market Data with anyone else, whether or not they use our Services.

How you can contact us

5.1 If you have any questions about your Agreement with us or need to contact us about your Lightyear Account, you can contact us via the Lightyear App or by email at support@lightyear.com.

How we will contact you

5.2 By using our Services, you agree that we may contact you through any method, including email, phone, post, the Lightyear App, or other means, using any contact information you have provided or that is otherwise available, for any matters related to this Agreement.

5.3 This includes receiving transaction confirmations, which we will normally make available via the Lightyear App promptly after execution, and periodic account statements showing your instruments and funds, which we will make available at least once per month. You may also receive other reports, documents, or materials we are required or choose to provide to you under this Agreement.

5.4 We may use the email address you provide to us when creating your Account to contact you. You may still request hard copies if needed.

5.5 If we need to send or return to you any documents, statements, or notices, we will usually email you at the address you have given us and/or send you a notification via the Lightyear App.

5.6 Notices will be deemed received, if sent by email or via the Lightyear App, at 9:00 a.m. on the next business day after sending.

5.7 Our email address for formal notices is support@lightyear.com.

6.1 If you feel dissatisfied with any aspect of our Service, then firstly please contact us by emailing complaints@lightyear.com. We will immediately carry out an independent investigation of your complaint and will provide a written response. More details on the process can be found from our Complaints Policy which can be found on our website.

6.2 If we are unable to resolve your complaint to your satisfaction and you feel that the answer received from a us is not the one you expected from us, you may turn to the following authorities to obtain assistance and explanations:

6.2.1 The Consumer Protection and Technical Regulatory Authority (at Endla 10a, Tallinn 10142, www.ttja.ee/en).

6.2.2 EFSA (at Sakala 4, Tallinn, 15030, www.fi.ee).

6.2.3 Furthermore, in order to resolve a dispute you may contact the Consumer Disputes Committee operating at the Consumer Protection Board and Technical Regulatory Authority or turn to court.

6.2.4 You can find the self-service for the Consumer Disputes Committee at https://ttja.ee/en/consumer-disputes-committee. A complaint to EFSA can be submitted here: https://www.fi.ee/en/consumer/when-should-i-contact-finantsinspektsioon/making-complaint. Please note that EFSA does not resolve complaints or act as an ombudsman, but you may contact them for independent advice or clarification.

6.3 Customers, who reside in certain countries, can also contact their local consumer dispute resolution bodies or financial ombudsman with their complaints. List of such countries and dispute resolution bodies or financial ombudsmen can be found in Schedule 1 of this Agreement.

7.1 Your privacy is important to us. Our Privacy Policy, as updated from time to time, explains how we collect, use, store and transfer your personal information.

7.2 We will only use your personal information as detailed in our Privacy Policy. You will also receive a copy of the Privacy Policy from us in a durable medium (e.g., via the email you used to sign up).

7.3 You should review our Privacy Policy to ensure you understand and agree to our collection, use and disclosure of your personal information. If you have any questions about our Privacy Policy or wish to exercise your rights under data protection legislation, you can email us at dpo@lightyear.com.

7.4 We won’t disclose your personal information to anyone, other than as described in our Privacy Policy and as outlined below. When we may disclose information about you

7.5 We may disclose information to third parties about you or any of your Orders or Transactions you are making using the Services:

7.5.1 as permitted by applicable law;

7.5.2 where it is necessary or helpful for completing or correcting Transactions or resolving any claims regarding Transactions;

7.5.3 in order to comply with a valid request by a regulatory body, government agency, a court order, or other legal or administrative reporting requirements;

7.5.4 to our employees, auditors, affiliates (including employees of such affiliate), or lawyers as needed to assist or enable the proper performance of the Services;

7.5.5 in order to prevent, investigate or report possible illegal activity;

7.5.6 for any reason as necessary to fulfil our obligations under this Agreement or applicable to the Services you are using;

7.5.7 if it is in the public interest to disclose such information; and/or

7.5.8 at your request or with your consent.

7.6 In order to satisfy our own obligations in relation to the Orders you may submit and the positions you may maintain, you agree to provide us with all such information as we may reasonably request.

8.1 We may record telephone conversations we have with you and store electronic communications between you and us, in accordance with our obligations under applicable law. You specifically consent to this, and to such records being used in any arbitral or legal proceedings between us.

8.2 We will store these records according to our data retention policies and applicable law. You may request a copy of recordings at any time during the retention period. Where required by the EFSA, we may store them for up to seven (7) years.

9.1 To access the Services, you acknowledge and agree that:

9.1.1 you are at least 18 years old and reside in a country where we offer our Services;

9.1.2 you will provide any information we may reasonably request to verify your identity during the account setup and as required to meet legal obligations;

9.1.3 you recognise we are required by anti-money laundering laws to verify your identity. During onboarding, we may request certain information from you so that we can perform anti-money laundering checks, screen our users against “Politically Exposed Person” and international sanctions’ lists as well as comply with applicable law;

9.1.4 you authorise Lightyear or third parties to verify your identity and check for fraud. This includes checking public records, verifying account information associated with the bank, e-money or payment institution account that you link to the Account or qualifying debit cards (e.g., name or account balance), and taking actions if needed. If we suspect money laundering or illegal activity, we may stop providing Services without notice and report to authorities as required;

9.1.5 once your information is verified and onboarding is complete, you’ll receive access to your Account via the Lightyear App;

9.1.6 we may exercise our rights under this Clause both during onboarding and at any other time;

9.1.7 you agree to keep your information current, accurate, and complete, updating us with any changes.

10.1 Your Account must be in your name only and cannot be shared with anyone else.

10.2 You are fully responsible for keeping your Account password and security details safe. Lightyear is not liable if someone accesses your Account because these details weren’t protected by you. Do not share your passwords or security details with anyone. Unless you notify us, we will assume all actions taken in your Account are authorised by you.

10.3 If you know or suspect that someone else has your password or security details, contact us right away at support@lightyear.com.

11.1 We aim to keep the Lightyear App available 24/7, but we can’t guarantee it will always be accessible, meaning you may sometimes be unable to place Orders or view your positions.

11.2 We will take reasonable steps to minimise the disruption to the Lightyear App and the Services and to give you advance notice of any planned suspension.

11.3 You are responsible for ensuring that your device is capable of supporting and has an operating system which is compatible with the latest version of the Lightyear App. Keep in mind that your experience may vary depending on your internet connection; a weak connection could affect your ability to place Orders or check positions quickly.

11.4 You may also access your Account via a web app, but note that it may not have all the features of the mobile app. By using the web app, you understand that its functionality may be limited compared to the mobile app.

12.1 This Clause of the Agreement provides information about the Services we provide to you, the Orders you can make through the Lightyear App and how we will treat you for regulatory purposes.

12.2 Upon you completing the onboarding checks, we will:

12.2.1 provide functionality via the Lightyear App to allow you to submit an Order and display information about your holdings of funds and Instruments via the Lightyear App;

12.2.2 allow you to send and receive Orders for one or more Instruments;

12.2.3 offer foreign exchange services related to our Services;

12.2.4 safeguard your Instruments;

12.2.5 hold and control client money.

12.3 We are not a currency trading platform and you should not use our Services for this purpose. If we detect that you are using our Services for this purpose, we may, at our discretion, set a limit on the amount of money you can convert, restrict your ability to use this or other features, or suspend or close your Lightyear Account.

12.4 Our fee-free Services (if available) are designed to support long-term investing. They must not be used in a way that seeks primarily to take unfair advantage of fee-free trades — for example, such as frequent same-day buying and selling of Instruments without genuine investment intent. If we detect such use, we may, at our discretion, set reasonable limits on your activity, restrict access to certain features, or suspend or close your Lightyear Account.

13.1 The Services that we will provide to you under this Agreement are non-advised, meaning that we will not provide you with any advice as to the merits of a particular Instrument or whether any particular Instrument is suitable for you.

13.2 How your Orders are executed is described in our Order Handling and Best Execution Policy, and we will execute your Orders ourselves or will transmit the Order to a Third-Party Broker for execution (or onward transmission for execution). We will not provide you with any investment, legal, tax or other form of advice; nor can you request any such advice from us, and any decision to acquire or sell an Instrument is solely yours and we are not responsible for such decisions.

14.1 Safeguarding and administration means keeping your Instruments safe, recording your Instruments and Transactions in your Account, and carrying out related administration activities, such as paying out income and settling your Transactions.

14.2 When we safeguard Instruments for you, you remain the beneficial owner. These Instruments are kept separate from our own assets and will not be available to our creditors if we become insolvent.

14.3 We will act with the level of care expected from a professional custodian when safeguarding your Instruments. A "custodian" is a regulated entity that provides safekeeping, registration, settlement, and related services for financial instruments on our behalf. We may choose custodians and allow them to use other custodians.

14.4 By accepting this Agreement and its terms, you provide your explicit consent, for all of the following actions, to the extent they are applicable to your use of our Services. This consent is given at the time you accept this Agreement during the account opening process:

14.4.1 you consent to our use of custodians or sub-custodians outside the EU where necessary, recognizing that the laws in that country may give you different rights compared to EU law;

14.4.2 you consent to us holding your Instruments together with those of other clients in a pooled (nominee or omnibus) account in the name of Lightyear, in accordance with applicable securities law;

14.4.3 you consent to us pledging, charging, or placing a lien over your Instruments, and if necessary your funds, for the following purposes: (a) to secure any amounts you owe us under this Agreement that are due and payable; (b) to meet obligations arising from your use of the Services; and (c) to comply with legal or regulatory requirements in the jurisdiction of the custodian or sub-custodian.

14.5 If the type of Instrument or the Service you use means the method of safeguarding in Clause 14.4 is not available or not well regulated, we may hold your Instruments in:

14.5.1 an account in Lightyear’s name with Instruments belonging to Lightyear and other clients;

14.5.2 an account in Lightyear’s name kept separate from Instruments belonging to Lightyear and other clients;

14.5.3 a separate account in your own name, which only we can operate.

14.6 To keep your Instruments separate from those of others, we maintain registers, keep accounts, and store information in line with applicable law.

14.7 We may, in connection with safeguarding and administering your Instruments:

14.7.1 allow a custodian to place a lien, charge, or restriction on your Instruments only if required by the laws of the country where they are held. If we cannot avoid granting such a right, we will inform you of the associated risks and will ensure that our internal records clearly reflect your ownership rights;

14.7.2 use your Instruments (including those in pooled or equivalent accounts) for settlement of Transactions or to recover unpaid amounts you owe us, including by selling them on market terms without further instruction from you, in the amount needed to cover the debt;

14.7.3 delay making Instruments available where transfer or disposal is restricted by law, stock exchange rules, custodian agreements, or orders from authorities.

15.1 When we receive funds from you, we will promptly place them into a separate client money account. This account will be held with either with:

15.1.1 a central bank,

15.1.2 an authorised credit institution in a member state, or

15.1.3 an authorised credit institution in a third country.

15.2 Your money is held in pooled accounts, with records kept tracking your individual beneficial ownership.

15.3 We regularly check that our internal records match those of the institutions that hold your money and take steps to ensure that client money is always kept in accounts that are clearly separate from our own accounts.

15.4 By agreeing to these Terms, you give your consent for us to hold your money in shares or units of qualifying money market funds (QMMFs) that comply with EU rules and the rules of the country where Lightyear is established, or with equivalent standards in the country where the fund is based.

15.5 We will only use QMMFs that are high quality according to recognised rating agencies and confirmed by our own credit assessment.

15.6 If we hold your money in QMMFs, it will not be protected by the client money rules in this Clause but will instead be covered by the safeguarding rules that apply to Instruments.

15.7 You may select to opt-out of your money being held in QMMFs by contacting our Customer Support or in-App (if provided).

Adding money to your Account

15.8 You can send funds to us by transferring them to a cash account, with the account details provided in the Lightyear App. Transfers must come from an account where you are listed as an account holder, either individually or jointly.

15.9 Subject to the other Clauses of this Agreement, deposited money remains in your Account until you request a transfer or withdrawal or place an Order.

15.10 Any payments related to your Orders and positions will be credited or debited from your Account.

Interest on client money

15.11 We may, but are not obliged to, pay interest to you on cash you hold with us. If we do pay interest, the rate will be determined by us, taking into account the interest we earn on client money accounts (including QMMFs) and the costs of providing and administering your Account. Current rates, if any, will be published on our website. We retain any interest we earn above the rate we pay you.

Accrual and payment of interest

15.12 If we pay interest under Clause 15.11, it will accrue on your available daily balance and be credited to your Account on the first working day of the following month, at which point it becomes your cash. Interest will accrue up to the date your Account is closed. If your Account is closed between interest payment dates, accrued but unpaid interest will not be paid.

16.1 An Order is an instruction from you to carry out a Transaction involving a specific Instrument through the Lightyear App.

16.2 You may place the following types of Orders on the Lightyear App (subject to availability for the Instrument):

16.2.1 Market Order – an Order to buy or sell Instruments immediately during market hours at the best available price at that time. We may automatically convert a market buy Order into a Limit Order with a 5% collar to help cushion against significant upward price movements;

16.2.2 Repeat Order – a Market Order placed on a regular schedule over a time period you choose. Repeat Orders are always treated as Market Orders and subject to the same terms.

16.2.3 Limit Order – an Order to buy at a specified price or lower, or to sell at a specified price or higher. A Limit Order may not be executed at all. We are not liable for any loss arising from non-execution. By placing a Limit Order, you agree we will not disclose or publish details of unexecuted Limit Orders.

16.2.4 Stop Order – an Order to buy or sell at the market price once the Instrument has traded at or through a specified “stop” price. Once triggered, a Stop Order becomes a Market Order and is filled at the next available market price, which may differ from the stop price. If the instrument does not reach the stop price, the Order is not executed. We are not liable for any loss arising from this. By placing a Stop Order, you agree we will not disclose or publish details of unexecuted Stop Orders.

16.3 We determine which types of Orders are allowed, and some Instruments may have restricted Order options based on their characteristics.

16.4 Short-selling is not allowed. You cannot submit a sell Order to perform a Transaction for an Instrument that you do not own at the time of the sale and that is not held on your Account whether settled or unsettled at the time of the sale.

Instruments available

16.5 Your Orders may relate only to the Instruments that are available via the Lightyear App from time to time. We have complete sole discretion as to the Instruments that we make available to you via the Lightyear App and we may add or remove any Instrument at any time.

17.1 Orders may only be submitted via the Lightyear App. You must have sufficient cleared funds or Instruments in your Account to meet the Order value and any related fees, taxes, or charges.

17.2 You must act on your own behalf and for your own account. You cannot place Orders on behalf of others, unless permitted by us.

17.3 By submitting an Order, you enter into a binding commitment to buy or sell the relevant Instrument. Orders can only be cancelled before they are communicated to the trading venue, Third-Party Broker, or another counterparty we deal with for over-the-counter instruments (for example, the issuer or distributor of a money market fund). Cancellation requests must be submitted via the Lightyear App and may not always succeed due to market speed or operational constraints.

17.4 We may refuse, delay, or cancel an Order at our sole discretion, including but not limited to the following circumstances:

17.4.1 it breaches this Agreement, applicable law, market rules, or custodian/exchange requirements;

17.4.2 you fail to provide information or documents we reasonably request;

17.4.3 we reasonably believe you cannot meet settlement or payment obligations;

17.4.4 the market or other external conditions make execution impossible or impractical;

17.4.5 we suspect market abuse, fraud, or other harmful activity;

17.4.6 there is any other valid reason consistent with protecting clients, market integrity, or our own compliance obligations;

17.4.7 or where we determine it is necessary for our own responsibility to manage risk, including but not limited to settlement, credit, and operational risks to Lightyear.

17.5 We may, without liability, cancel, reverse or amend any Transaction that we reasonably believe was affected by a manifest error, technical failure, or pricing issue, or that breaches applicable laws or regulations.

17.6 Limit Orders can remain active for the period you select (subject to any maximum duration shown in-App). Unexecuted or uncancelled Orders will expire automatically at the end of that period.

17.7 From time-to-time, other restrictions may apply to submitting Orders dependent upon regulatory requirements, market conditions or our own risk and compliance considerations. These may include, but are not limited to situations such as:

17.7.1 trading restrictions imposed by regulators on certain Instruments;

17.7.2 trading restrictions imposed by regulators on us;

17.7.3 trading restrictions imposed by the trading venue or Third-Party Broker on us;

17.7.4 trading restrictions imposed by us where we reasonably believe such action is necessary to protect our customers or the integrity of the market (for example, in cases of suspected market abuse, fraud, or other harmful activity).

17.8 You can choose to automate your submission of Market Orders via Repeat Orders. Repeat Orders can only be placed as Market Orders to buy an Instrument of your choosing. Repeat Order is subject to following conditions:

17.8.1 you must choose the time period over which the Repeat Order is placed (available time periods are provided in the Lightyear App). In case of weekly and monthly (if available) Repeat Orders, you must choose a day/date upon which the Repeat Order is placed and carried out;

17.8.2 if you have chosen a day/date on which the market is closed, the Repeat Order shall be placed on the next day on which the market is open;

17.8.3 if you do not have enough money in your Account to place the Repeat Order, it will be skipped and not placed. This does not cancel the next scheduled Repeat Order;

17.8.4 you cannot place identical Repeat Orders regarding the same Instrument (for example to buy the same Instrument over the same time period on the same day or date).

17.9 We may change, restrict, or withdraw any Order types or features at any time.

17.10 If certain Instruments you own become unavailable due to legal, regulatory, or risk restrictions, you agree that we may sell such Instruments from your Account at prevailing market prices and credit the proceeds to you.

18.1 Lightyear has discretion over whether or not an Order submitted by you is communicated to the trading venue, Third-Party Broker or another counterparty we deal with for over-the-counter instruments (for example, the issuer or distributor of a money market fund). If we cannot accept your Order, we will let you know as soon as reasonably practicable. While we may not always be able to share full details, we will provide information where possible.

18.2 Third-Party Brokers, partners, and trading venues may also reject or cancel Orders based on their own rules, limits, or applicable laws.

18.3 Orders may be cancelled or amended if required by a market, custodian, or regulator.

19.1 If we accept your Order, we will execute it or transmit it to a Third-Party Broker (or onward for execution) in line with this Agreement. We generally aim to execute Orders on the same day we receive them, provided you have sufficient funds and the market is open. For certain Instruments (such as money market funds) that are not continuously tradable, execution may take place only at predetermined times, and Orders received after such times will be executed on the next eligible day.

19.2 All Orders are executed or transmitted in accordance with the rules, regulations, market practices and operational procedures of the relevant trading venue, clearing house, custodian, or other involved third party. We are not responsible for delays, failures, or other issues caused by these parties or the applicable market infrastructure.

19.3 You consent to your Orders being executed outside a regulated market, MTF, or OTF where relevant (e.g. for fractional trading).

19.4 We have a duty to act in your best interest when we execute your Order or transmit it for execution. Please refer to our Order Handling and Best Execution Policy for more information. By opening an Account, you are deemed to consent to our Order Handling and Best Execution Policy.

19.5 Please note that an Order placed outside of market hours will be executed once market hours commence. Market hours shall mean hours when the trading venues of Instruments available via Lightyear App are open for trading.

19.6 We will always allow you to sell back to us a fractional portion of the Instrument that you received from us acting as a counterparty to the Transaction.

20.1 When you wish to submit an Order to buy an Instrument, we will reserve cash in your Account equal to the estimated total value of the Order, including any applicable fees, charges, taxes, and, where we consider appropriate, a buffer to cover potential market movements before execution.

20.2 When you place an Order through the Lightyear App, we will show you the indicative price of the Instrument you are looking to buy or sell. This price is provided by third-party sources for information purposes only. The indicative price is not updated in real-time for every market movement and therefore may differ from the final execution price. The actual execution price is determined by the market at the time your Order is executed, and may be higher or lower than the indicative price you saw in the App.

20.3 In periods of exceptional market conditions — for example, when prices are moving very quickly, when there are very few buyers or sellers, or when markets experience outages or trading halts — the price at which your Order is executed may differ significantly from the indicative price shown in the App. In these situations, your Order may also be delayed, only partially filled, or rejected. The difference between the displayed price and the final execution price (“slippage”) may be larger than usual. To the maximum extent permitted by law, we are not responsible for any losses caused by such conditions.

20.4 We take all sufficient steps to achieve the best possible result for you in line with our Order Handling and Best Execution Policy. However:

20.4.1 for Market Orders, the final execution price may be higher or lower than the indicative price you saw when submitting your Order. This may happen because the market moves between the time you place the Order and the time it is executed (“slippage”). Such price movements can be in your favour or against you;

20.4.2 for Limit Orders, we will only execute at your specified limit price or better. If the market does not reach your limit price, your Order may not be executed in full or at all;

20.4.3 for Stop Orders, if the market price moves quickly through your stop level (for example, if the market opens below your stop price after being closed), the Order will trigger at the next available price, which may be significantly different from your stop price. Stop Orders are therefore not a guarantee that you will be able to sell or buy at your chosen stop level;

20.4.4 in some cases, your Order may be partially filled or rejected if there is insufficient liquidity at the relevant price level;

20.4.5 if the execution price is higher than the amount reserved in your Account (for example, because of slippage), your Order may be rejected or may result in a negative balance. You must top up any shortfall within the timeframe we notify you, or we may take corrective action, including liquidating positions in your Account or, where necessary, suspending or terminating your Account.

21.1 When you sell an Instrument, the money from the sale will be added to your Account. You can use this money to make new investments or ask us to transfer it to an account in your name.

21.2 In most markets, settlement (the final transfer of ownership and funds) takes one or two trading days. While the sale proceeds are generally available for reinvestment immediately, the timing of settlement determines when the money can be withdrawn or transferred out of your Account.

22.1 Market Data is provided “as is” and “as available.” We do not guarantee the accuracy, completeness, reliability, or timeliness of any Market Data. Market Data may be delayed, incomplete, inaccurate, or unavailable due to market conditions, third-party actions, or system issues.

22.2 We are not liable for any loss (including loss of profit, opportunity, or data) that you suffer because of relying on Market Data, whether arising from delays, errors, omissions, interruptions, or any other cause. Our liability in connection with Market Data is excluded to the maximum extent permitted by applicable law, as further set out in Clause 27.

22.3 We may change the source, content, or format of Market Data at any time, or withdraw access to Market Data altogether, without prior notice.

22.4 We may, at our sole discretion, restrict, suspend, or terminate your access to Market Data without notice if we reasonably believe you have breached these terms, misused Market Data, or if required by a third-party provider. We accept no liability for such restriction, suspension, or termination.

23.1 Corporate actions may include, but are not limited to, voting rights, dividends, interest payments, stock splits, mergers, spin-offs, rights issues, conversions, and takeovers relating to your Instruments.

23.2 We may decide, at our discretion, which corporate actions to support, for which Instruments, and under what conditions. We are under no obligation to facilitate all or any corporate actions, and may decline participation without liability, even if such corporate action is generally available in the market. We are not responsible for any loss of opportunity or benefit resulting from our decision not to support or participate. Availability depends on third-party arrangements, market rules, and operational capabilities, and we do not guarantee participation.

23.3 You do not have voting rights in respect of fractional holdings of Instruments.

23.4 If we enable participation, you must provide instructions in the form we accept and cover any expenses, damage, or loss we incur in executing them. If we cannot obtain your instructions, we may act without them if we reasonably believe it is in your best interests.

23.5 Where we facilitate a corporate action, we may sign documents and perform acts in your name as required to complete it.

23.6 We will use reasonable efforts to inform you about corporate actions, but we cannot guarantee the timeliness, completeness, or accuracy of any notice. We accept no liability for loss resulting from delays, changes, cancellations, or failures in communication.

23.7 We set cut-off times for participation in certain corporate actions, which may be earlier than those set by the issuer or market. If we do not receive your instructions before the cut-off, we may take no action or act in your best interests as we determine.

23.8 In some cases, including where fractional shares arise or where delivering securities is not possible, we may provide the cash equivalent instead. This may also apply after your Account is closed, in which case we will attempt to return the proceeds using your previous payment method.

23.9 Where we receive income from your positions through dividend payments, interest, or other corporate actions, we will reconcile and credit these amounts to your Account. If you have not enabled the multi-currency account functionality, we will convert such income to your Account’s default currency. Currency conversions will be carried out at the prevailing market rate, and we may waive FX fees for certain types of income (e.g. dividends). Withholding tax may apply; reclaiming such tax is your responsibility unless we agree otherwise.

24.1 We take all reasonable steps to prevent or manage conflicts of interest between us and you, and between our different clients. We maintain a Conflicts of Interest Policy that identifies situations where conflicts may arise and explains the steps we take to prevent or manage them. A summary is available on our website. If, despite these measures, a conflict remains that could harm your interests, we will, as a last resort, disclose to you the general nature and/or source of the conflict and the measures taken to reduce the risk.

24.2 We are not obliged to:

24.2.1 disclose to you, or take into account, any fact, matter, or information that would breach our duty of confidence to another person, or that comes to the attention of any of our directors, officers, employees, or agents if the person dealing with you is not actually aware of it; or

24.2.2 account to you for any profit, commission, or other benefit we receive in connection with a Transaction or situation where we have a material interest or where a conflict of interest exists.

25.1 Our Service Fees are published on our website and updated regularly. Translations into certain other languages are also available on our website. We will notify you of any changes as set out in Clause 30.

Currency conversion

25.2 Orders are executed in the currency in which the Instrument is traded on its market (or over-the-counter).

25.3 If you do not hold enough of that currency in your Account, we will convert funds from your Account to the required currency using the spot exchange rate available to us at the time of conversion. You can see the rate in the Lightyear App, and your transaction history will show the rate used.

25.4 If your Account supports multiple currencies, no conversion will be made if you have a sufficient balance in the required currency.

25.5 Please note that conversion (and charging any applicable Service Fees) takes place when the Order is placed, even if the Order is later rejected or cancelled. In that case, the converted money remains in your Account.

Charging of Service Fees

25.6 You are only charged execution fees for Orders that are executed. You agree to pay all fees and charges for the relevant Services. Fees for a Transaction will be deducted from your Account once the Order is executed.

25.7 In the event of non-payment or late payment of fees, you agree that we may use, sell, retain or set-off Instruments held in the Account.

25.8 If the execution fee is calculated on percentage basis, the applicable fee shall be rounded to the nearest cent. For example, if the fee is USD 1,239, the fee shall be rounded to USD 1,24.

25.9 We may in certain cases decrease or waive the fees we charge. Such actions cannot be construed as permanent changes in the pricing of our Services, unless we specifically communicate so, and thus provides no legitimate expectation to also pay decreased fees or no fees in the future.

26.1 You are solely responsible for ensuring you comply with all applicable tax laws, reporting and payment obligations in any jurisdiction, and for any taxes or duties (local or international) arising from your Transactions, your use of our Services, or any interest payments we make to you. These may be imposed at the time of purchase, while you hold the Instrument, or at a later date.

26.2 All payments by Lightyear under this Agreement will be made without withholding or deduction for taxes unless required by law. If withholding is required, we will not pay any additional amounts to cover it. You must promptly provide any information we request to enable proper withholding, deduction, or reporting.

26.3 You will be wholly responsible for any fees incurred in the transfer, deposit, withdrawal, or card payment related to your Account, including those charged by your bank, card issuer, e-money provider, or payment institution.

26.4 When you enter into a Transaction, hold an Instrument, or use a Service via the Lightyear App, you may be subject to fees, taxes, or charges imposed by third parties (“Third-Party Fees”). These are not set, controlled, or retained by Lightyear and are determined solely by external entities such as exchanges, issuers, custodians, clearing houses, depositories, or tax authorities.

26.5 Third-Party Fees may be charged at the time of the Transaction, while you hold the Instrument, or at a later date. They may include, for example:

26.5.1 transaction taxes (including stamp duty, financial transaction tax, or similar);

26.5.2 market access, clearing, settlement, or depository charges;

26.5.3 safekeeping, custody, or issuer-imposed fees;

26.5.4 charges in connection with corporate actions;

26.5.5 withholding taxes or other taxes applied by law.

26.6 You are solely responsible for paying any applicable Third-Party Fees. Where we are required or reasonably able to collect such fees , we will deduct these amounts from your Account either:

26.6.1 from the funds you use when placing a buy Order;

26.6.2 from the proceeds of a sell Order;

26.6.3 or from your Account balance if the fee is applied after the Transaction has been executed.

26.7 If we do not deduct Third-Party Fees from your Account pursuant to Clause 26.6, you remain responsible for payment directly to the relevant third party or authority.

26.8 If your Account has insufficient funds to cover a Third-Party Fee, you must immediately top up the shortfall, including any related fees, interest, or costs we incur. We may also recover the amount by selling your Instruments or taking other action under this Agreement.

26.9 Because Third-Party Fees are set by third parties, they may change without notice and it may not be possible to provide an exhaustive list in advance. Where reasonably practicable, we will inform you of any such fees before they are charged.

26.10 You authorise us to deduct any Third-Party Fees from your Account. Once such amounts become payable to a third party, they will no longer be treated as client money. You are responsible for any other taxes you may owe in connection with your investments and for making any required filings with tax authorities.

27.1 Lightyear together with its officers, directors, agents, partners, employees, licensors, distributors, and other representatives, limits its liability as much as the law allows:

27.1.1 death or personal injury;

27.1.2 breach of legal obligations under regulations; or

27.1.3 negligence (hooletus), fraud or intentional (tahtlus) wrongdoing.

27.2 Lightyear, and the people and organisations listed above, are not liable for any indirect or special damages related to your use of the Services or this Agreement, including lost revenue, data loss, or interruptions caused by issues outside their control.

28.1 If you think you may have breached this Agreement, you must let us know right away at support@lightyear.com.

28.2 If you breach this Agreement, you may be responsible for any damage, loss, or costs we incur as a result. If we learn about your breach, either from you or through other means, we may take any of the following actions:

28.2.1 suspend your access to the Services (temporarily or permanently), including immediate withdrawal of your right to use some or all of the Services pursuant to Clause 34;

28.2.2 terminate this Agreement pursuant to Clause 34, which will lead to closing your positions;

28.2.3 take legal action against you to recover all costs and expenses related to the breach, including all costs on an indemnity basis (such as reasonable administrative, enforcement, and legal costs);

28.2.4 pursue further legal action if necessary; and

28.2.5 report the breach to law enforcement if we believe it is necessary or required by law.

28.3 We are not liable for any actions we take in response to breaches of this Agreement. Our actions are not limited to those listed above, and we may pursue any other legal remedies available under the law.

28.4 Lightyear together with its officers, directors, agents, partners, employees, licensors, distributors, and other representatives, is not responsible for failing to provide Services or breaches of this Agreement due to uncontrollable events. Such events include, but are not limited to, market closures or suspensions, acts or omissions of custodians or brokers, changes in law or regulation, governmental actions, acts of terrorism, cyber-security incidents, failures of telecommunications or IT systems, or any other event beyond our reasonable control. We shall not be liable for any failure, delay, or inability to perform our obligations due to such events.

28.5 Our ability to provide the Services depends on the continued availability of services from third parties, including market data providers, custodians, payment processors, and brokers. We shall have no liability for any loss or damage arising from the suspension, withdrawal, or failure of such third-party services, provided we have taken reasonable steps in their selection.

28.6 If Lightyear incurs costs, including legal fees, while collecting payments or enforcing obligations related to your Account, you agree to pay those costs.

28.7 If you have breached this Agreement and we don't enforce our rights, or we delay enforcing them, this will not prevent us from enforcing those or any other rights at a later date.

29.1 The Investor Protection Sectoral Fund (investorikaitse osafond) guarantees and compensates investors under the Guarantee Fund Act (tagatisfondi seadus) for investments made through Estonian investment firms or Estonian branches of foreign firms. Compensation covers the value of investments as of the compensation date, up to a maximum of 20,000 euros per investor per institution.

29.2 Please note, you will not be entitled to compensation purely based on the financial performance of your Instruments. This means that losing capital as a result of your investment activities will not automatically qualify you to receive compensation.

30.1 We may amend this Agreement at any time by providing you with 14 calendar days’ notice unless no prior notice period is applied pursuant to Clause 30.3.

30.2 We will notify you of changes by sending an email to the address you have provided to us, and/or by making the updated Agreement available in the Lightyear App or on our website. Unless you notify us before the effective date that you wish to terminate this Agreement, you will be deemed to have accepted the changes. If you object to the amendments, you may terminate this Agreement with immediate effect before they come into force.

30.3 We may amend this Agreement immediately, without the prior notice period in Clause 30.1, if the change:

30.3.1 is more favourable to you;

30.3.2 is required by law or regulation;

30.3.3 introduces a new Service or additional functionality to existing Services; or

30.3.4 does not reduce your rights or increase your obligations under this Agreement. In these cases, the change will take effect immediately upon you being notified by email and/or the Agreement being made available in the Lightyear App or on our website.

30.4 Lightyear may discontinue or modify the Services or content of the Lightyear App, or any portion thereof, at any time. It is important that you keep your personal contact information up to date, so please let us know if any of your details change.

30.5 We may, at our discretion, discontinue, suspend, or modify any Service or the content of the Lightyear App, in whole or in part, at any time. We will give you reasonable notice where practicable, but we are not liable for any loss or damage arising from such discontinuation or modification, to the maximum extent permitted by law. You remain responsible for ensuring your contact information is kept up to date.

31.1 If we receive a notification that you have died, we will suspend your Account as soon as we can. The value of the Instruments in your Account, and any funds remaining in your Account, may form part of your estate and, subject to us receiving appropriate confirmation from an executor or appropriate representative responsible for the management of your estate, we may act on the instructions given to us by such representatives. Any actions we take based on instructions received under a power of attorney will be subject to our stated fees and charges.

31.2 You should be aware that we are not liable to you for any loss or damage incurred by you in relation to your positions whilst we await instructions from any of your representatives. This Agreement shall continue in full force and effect after your death, until such time as your Account is closed and the Agreement is terminated.

31.3 If you are deemed legally incapable of engaging with the Services, and we are provided with documentation to this effect, we will manage your Account in accordance with any instructions received under a power of attorney, until such time as the power of attorney is revoked or until the time of your death. Any actions we take based on instructions received under a power of attorney will be subject to our stated fees and charges.

32.1 Lightyear and you are the only parties to this Agreement. You cannot transfer any rights or obligations under this Agreement to any other person without our written consent.

32.2 We may assign, transfer, or delegate any of our rights or obligations under this Agreement to another entity at any time, provided we comply with our legal and regulatory obligations. Where required, we will give you prior notice before the transfer takes effect.

33.1 Any party who is not a party to this Agreement cannot enforce the rights or enjoy the benefits of any of its provisions.

34.1 You may terminate your Account at any time and for any reason by giving us notice via email at support@lightyear.com.

34.2 We may suspend, restrict, or terminate your Account, and/or any part of our Services to you, immediately or on notice, if any of the following apply:

34.2.1 you have breached this Agreement, including any obligation set out in Clause 4, or any other agreement with us;

34.2.2 you have provided false, misleading, or incomplete information to us;

34.2.3 you fail to provide complete, accurate, and up-to-date information, or you fail to respond to requests for additional or updated identification, verification, source-of-funds/wealth evidence, or other due diligence information within the timeframe specified by us;

34.2.4 we reasonably determine, based on applicable law, regulatory obligations, or our internal risk management policies (including risk appetite and sectoral risk limits), that maintaining your Account or providing Services to you creates unacceptable legal, regulatory, reputational, or operational risk;

34.2.5 we have reason to believe you, or someone connected with you, has engaged in fraud, attempted fraud, money laundering, terrorist financing, sanctions evasion, or any other unlawful conduct;

34.2.6 you, or your Account activity, are directly or indirectly connected with any person, business, territory, entity, or regime subject to sanctions, or acting on their behalf or for their benefit, as determined by us;

34.2.7 you are, or we reasonably believe you may be, trading using inside information or attempting to manipulate the market;

34.2.8 you use your Account for purposes inconsistent with the intended use of our Services, including on behalf of third parties, to conceal ownership of assets, or for commercial activity not permitted by us;

34.2.9 you know or suspect, or we are notified or we detect, that anyone other than you has access to or knowledge of your user identification code, password, or other account credentials;

34.2.10 your Account has a negative balance or you otherwise owe us money (including due to market movements, fees, taxes, system related faults or charges) and you fail to settle the amount in the timeframe determined by us;

34.2.11 you are, or become, resident in a jurisdiction where we do not offer our Services, as determined by us based on available data;

34.2.12 you engage in abusive, harassing, or threatening behaviour towards Lightyear, our employees, contractors, agents, or other customers;

34.2.13 you have not logged in to the Lightyear App for 365 calendar days;

34.2.14 you are declared insolvent, enter bankruptcy or similar proceedings, or in the event of your death;

34.2.15 we are required to do so by law, regulation, court Order, a competent authority, or due to restrictions imposed by a third party essential to providing our Services (including exchanges, custodians, or payment providers);

34.2.16 extraordinary market conditions, operational issues, or other events occur that make it impracticable for us to continue providing Services to you;

34.2.17 we otherwise decide to suspend or terminate your Account at our absolute discretion, in which case we will give you at least 30 calendar days’ prior notice unless immediate action is required under this Clause 34.

34.3 Suspension may be temporary or may lead to termination. We will notify you of any suspension or termination as soon as reasonably practicable unless prevented by law or security considerations.

34.4 During a suspension, we may block access to some or all Services, decline to process Orders or Transactions, and/or freeze deposits or withdrawals from your Account. Suspension does not affect your obligations to us, including paying any amounts owed.

34.5 We may terminate your Account for reasons other than those listed above, provided we give you at least 30 calendar days’ notice by email.

34.6 Upon termination:

34.6.1 you must close all open positions and withdraw any remaining funds within 30 calendar days or in another timeframe as determined and notified by us;

34.6.2 if you fail to close your positions, we may do so on your behalf and at our discretion, selling your Instruments at prevailing market prices. We are not liable for any loss arising from such sales, including losses caused by market conditions at the time of execution;

34.6.3 funds will be transferred to your Account and then paid out to you once all obligations to us are settled;

34.6.4 we will retain your information and related documents only to the extent and for the time necessary to comply with applicable law or to maintain the Services for other customers.

35.1 We own the Services, the Lightyear App, and all related documentation, materials, and content used for their installation, operation, or maintenance, including any updates, improvements, or derivative works. All associated intellectual property rights remain the exclusive property of Lightyear or our licensors. Unless this Agreement expressly states otherwise, you do not acquire any rights in the Services, the Lightyear App, or related materials.

35.2 You agree not to challenge our rights in the Services, the Lightyear App, or related materials, or the validity of those rights under the law. You also agree not to register, attempt to register, or claim any legal protection for them, or take any action that could harm our rights or interests.

36.1 This Agreement and any non-contractual obligations arising out of or in connection with them, and all Transactions will be governed by and construed in accordance with Estonian law. The laws of other countries applicable to the Instruments, the Third-Party Broker or a custodian and their services may affect and be also applicable to individual Transactions and safekeeping of Individual Instruments.

36.2 Without prejudice to any rights you may have to refer a complaint to the authorities, as set out in Clause 6, the courts of Estonia have exclusive jurisdiction to settle any dispute arising in connection with this Agreement and for such purposes we and you irrevocably submit to the jurisdiction of the Estonian courts.

37.1 If any court or relevant authority finds any part of the agreement between us to be invalid or unenforceable, the remaining parts of the agreement between us will remain in full force and effect

These Savings’ Vault terms apply from 20.05.2024. Savings’ Vault is available only in select countries.

1.1 These Savings’ Vault Terms (“Terms”) form a Schedule to the Agreement between you and Lightyear. Unless defined otherwise in these Terms, all definitions are adopted from Lightyear’s Terms of Service (“Agreement”).

1.2 In case there is any conflict or discrepancy between these Terms and the Agreement, the provisions in these Terms shall prevail. Otherwise, for matters not regulated in these Terms, the provisions of the Agreement shall apply.

1.3 Before opening the Savings’ Vault, please make sure to read and understand: 1.3.1 the Terms as well as the Agreement, Order Handling and Best Execution Policy and Risk Disclosures as provided here; 1.3.2 relevant FAQs, available here; 1.3.3 the key information document and the prospectus for the Vault Instrument.

2.1 Savings’ Vault allows you to invest in money market funds (“Vault Instruments”) made available by us on Lightyear's platform. All the money transferred into the Savings’ Vault will be invested in the Vault Instrument of your choosing.

2.2 You may open a separate Savings’ Vault for each supported currency, which may differ based on your jurisdiction.

2.3 You can see the available Vault Instruments in the App as well as on our webpage. In the future, we may extend or change the list of available financial instruments in addition to money market funds that you can invest in via the Savings’ Vault. We do not provide you investment advice or recommendations in respect to available Vault Instruments and we have not assessed if such Vault Instruments are suitable for you. You need to do your own research before opening a Savings’ Vault and selecting a Vault Instrument.

2.4 You understand and agree that transferring funds to the Savings’ Vault means we will invest them in a Vault Instrument of your choosing. This means that you are subject to the investment risk and any other risks associated with that Vault Instrument and asset class. Before using the Savings’ Vault, please carefully read our Risk Disclaimer including the Target Market Matrix (especially in regards to UCITS MMFs), available here.

3.1 The Savings’ Vault enables us to purchase and sell Vault Instrument units or shares on your behalf on an execution-only basis. We do not assess if the Vault Instrument is appropriate or suitable for you and if you are uncertain (in cases where we do not or cannot assess appropriateness or suitability) if the Vault Instrument is appropriate for you, you should seek independent professional advice as your interests may be otherwise less protected.

3.2 By confirming you wish to open and transfer funds to a Savings’ Vault, you are instructing us to execute buy Orders for the selected Vault Instrument with the entirety of the funds (that are not already invested) transferred to that Savings’ Vault. All subsequent transfers into the Savings’ Vault will be deemed as additional buy Orders for the selected Vault Instrument.

3.3 By withdrawing funds from the Savings’ Vault, you are instructing us to execute a sell Order for the selected Vault Instrument to the extent necessary to facilitate the withdrawal from the Savings Vault to your Account.

3.4 Orders for Vault Instruments shall be executed at least once per working day. Funds transferred to the Savings Vault before that time of execution will be executed on the same working day. The cut-off time is provided in the App. All fund transfers after that time will be executed on the subsequent working day when it's possible to execute the transaction. In some cases the Vault Instrument execution may also be instant.

3.5 Vault Instruments issue regular distribution (such as dividends or interest payments for example) (Distribution), usually once a month. Once automatic reinvestment is available, you may choose in-App to have such Distributions automatically reinvested within the Savings’ Vault or have them automatically paid out of the Savings’ Vault to your Account. By selecting to have the Distributions reinvested you instruct us to execute a buy Order in the size of each Distribution for the selected Vault Instrument.

3.6 You understand and acknowledge that execution of Orders is not guaranteed and in some cases Orders for Vault Instruments may not execute for operational, regulatory, third-party related or other reasons. More details are available in the Agreement and in our Order Handling and Best Execution Policy, available here.

4.1 You may only deposit funds to the Savings’ Vault from your Account held on the Lightyear platform. Similarly, you may only withdraw funds from the Savings’ Vault to your Account.

5.1 When using the Savings’ Vault, you are subject to Lightyear fees, as well as fees associated with the Vault Instrument that you invested your funds in, such as fund managers fund management fees for example. Lightyear fees for the Savings’ Vault are available on our webpage here in English, and certain translated versions are also available here. Information about fees associated with the Vault Instrument are available in-App as well as in Vault Instrument’s key information document, prospectus and on the fund manager’s website.

5.2 The fee for using the Savings’ Vault as specified on our website (Savings’ Vault Fee) shall be deducted automatically from your Distributions.

5.3 We will notify you of any changes in our fees as provided in the Agreement.

6.1 You may terminate this Savings’ Vault at any time and for any reason by withdrawing your funds from the Savings’ Vault and giving us notice via email at support@lightyear.com. If your Account is terminated, the Savings’ Vault is terminated automatically as well.

6.2 Using the Savings’ Vault and investing into Vault Instruments may have tax implications. Make sure to understand what taxes you may need to pay in connection to the Distributions from the Savings’ Vault before you start using it. We do not provide tax advice.

1.1 These Plans Terms (“Terms”) form a Schedule to the Agreement between you and Lightyear. Unless defined otherwise in these Terms, all definitions are adopted from Lightyear’s Terms of Service (“Agreement”).

1.2 In case there is any conflict or discrepancy between these Terms and the Agreement, the provisions in these Terms shall prevail. Otherwise, for matters not regulated in these Terms, the provisions of the Agreement shall apply.

2.1 A Plan is a feature in the Lightyear App that lets you set up and manage your own portfolio of eligible Instruments (your “Plan Instruments”). With a Plan you can, subject to the limitations set out in Clause 2.3 of these Terms: 2.1.1 choose which Instruments to include and how much of each you want to buy (your allocation); 2.1.2 decide how much you want to contribute and how often; and 2.1.3 have Lightyear automatically place buy Orders on your chosen schedule.

2.2 You can create more than one Plan, and each Plan will have its own allocations and schedule.

2.3 Only fractional Instruments available on the Lightyear platform are eligible for automatic investment with the Plans. You may include non-fractional instruments in a Plan, but these will not be automatically invested into.

2.4 Lightyear may set a cap on the number of Plan Instruments that can be included in a single Plan. The cap is determined by Lightyear and may change from time to time.

2.5 You can view the current list of eligible Plan Instruments in the Lightyear App.

3.1 You may fund contributions to your Plan from: 3.1.1 standing Order payments to your unique Lightyear payment reference; or 3.1.2 uninvested cash already in your Lightyear Account. We may add, change, or remove funding methods from time to time. The options shown in the Lightyear App are always the latest available

3.2 For automated investments, you can choose to contribute weekly, fortnightly (every two weeks), or monthly, and select the date for execution. If your chosen date falls on a day when the market for a Plan Instrument is closed, your Orders will be placed on the next available trading day. Orders for Plan Instruments whose markets are open will proceed as scheduled.

3.3 Orders for each Plan Instrument will be placed as Market Orders on the execution date, using your most recent allocation settings and the money available at that time. If there is not enough money in your Account, the contribution for that date will be skipped. Skipping a contribution does not cancel any future scheduled contributions.

3.4 If you set a regular contribution amount for your Plan in the Lightyear App but make a standing Order payment that is larger or smaller, the full amount of the standing Order received will be invested into your Plan according to your latest allocation settings. In this case, the standing Order amount prevails over the contribution amount set in the app.

3.5 Any proceeds from corporate actions relating to Instruments held in a Plan (including dividends, splits, mergers, rights issues, or other distributions) will be credited to your general Lightyear Account. Such proceeds will not automatically be reinvested into your Plan. If you want them reinvested, you will need to take action yourself.

4.1 Standing Orders 4.1.1 All standing Order contributions are received in your home market currency (the base currency linked to your country of residence, e.g. EUR for eurozone customers). 4.1.2 If a Plan Instrument is priced in another currency, your standing Order contribution will be converted into that currency at the prevailing FX rate, and the FX fee set out in our Service Fees will apply. 4.1.3 Where your home market currency is not one of our supported market currencies, your entire standing Order contribution will always be converted.

4.2 Cash balances 4.2.1 If you fund your Plan using cash already held in your Lightyear Account, we will first use any available balance in the same currency as the relevant Plan Instrument. 4.2.2 If no matching balance is available, we will convert from another balance in your Account at the prevailing FX rate, and the currency conversion fee set out in our Service Fees will apply.

5.1 Fees for Orders placed as part of a Plan are the same as for standard trading in the same instrument type, as set out in our Service Fees.

6.1 You may edit, pause or resume a Plan at any time. While a Plan is paused, no scheduled contributions or investments will be made. If you have set up a standing order with your bank, you are responsible for cancelling or amending it directly. Any payments received from a standing order while a Plan is paused will not be invested in the Plan but will instead be credited to the cash balance of the account in which the Plan is held.

6.2 You may delete a Plan at any time. When you do, the available options for what to do with the Instruments held in the Plan will be presented to you in the Lightyear App.

6.3 We may remove Plan Instruments from eligibility at any time. If a Plan Instrument is removed, it will not receive future contributions but will remain in your portfolio unless you choose to sell it. Its allocation will be automatically redistributed across your remaining Plan Instruments, unless you update your settings. We will notify you if this occurs.

6.4 If a Plan Instrument is delisted, becomes ineligible, or an Order otherwise fails (for example due to trading restrictions, market liquidity, or the instrument being unlisted), any resulting cash will be credited to your Lightyear Account in which the Plan is held. The allocation for that Instrument will not be automatically redistributed across your remaining Plan Instruments, and will remain as cash in your portfolio unless you adjust your Plan settings.

6.5 You are responsible for the allocations, instruments and schedules you set within your Plan. Lightyear is not liable for investment losses resulting from your selections or from market movements.

6.6 You are solely responsible for all tax consequences that may arise from using Plans, including but not limited to, the tax treatment of contributions, withdrawals, and investment gains or losses within your Account.