Eigen Fintech Terms and Conditions Agreement

These terms of use (“Terms of Use”) constitute a legal agreement between you and 14872525 Canada Inc. (DBA as Eigen Fintech) (“we”, “us”, “our”) and govern your subscription to access to and use of the Eigen FinTech (website located at https://eigenfintech.com and/or any mobile application or any other applications or website as and when available (collectively referred to as, the “Website”), and any tools, features, functionalities or content provided via or in connection with our services (“Services”). Each of you and Eigen FinTech shall hereinafter be referred to as a “Party”, and collectively, you and Eigen FinTech shall hereinafter be referred to as the “Parties”.

We offer a suite of services, tools and data that are designed to assist and support you manage your investments and help you make better financial decisions. We do not offer financial advice or specific recommendations tailored to your situation, and the use of our services is for information purposes only.

After you click on [‘Sign up’, ‘Register’ or ‘I Agree’] or when you use the Eigen FinTech’s Services provided through the Platform, a legally binding agreement on these Terms is concluded between you and us. Your continued use of the Platform and receipt of our Services shall be governed by these Terms.

By accepting these Terms, you agree that our Privacy Policy, as it exists at any relevant time, shall be applicable to you.

IF YOU DO NOT AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS AGREEMENT, DO NOT USE OR ACCESS OUR SERVICES AND INFORM US IN WRITING IMMEDIATELY.

1. Definitions

1.1.“Confidential Information” has the meaning set out in Section 6.1.

1.2. “Documentation” has the meaning set out in Section 2.3.

1.3. “Fees” means such amounts payable by you in connection with the service plan that you have selected to receive from time to time as as well as other fees we may charge from time to time;

1.4. “Data” means information and data provide to you through the Platform pertaining to financial instruments, currencies, crypto-assets and market performance, that includes, without limitation, any and all data, analysis, insights, visualizations, educational content.

1.5.“Initial Subscription Term” means the monthly or yearly subscription you have selected when signing up to receive subscription access to the Platform and receive the Services.

1.6. “Notice” has the meaning set forth in Section 11.2.

1.7. “IP" means any intellectual property rights in the Services, the Documentation, and any and all intellectual property provided to you in connection with the foregoing.

1.8. “Platform” means the Website or other web-based or application-based platform, SaaS software and our proprietary technology for receiving tools, research signals and other market trading data and functionality we may provide from time to time or any other online website or mobile application provided by us, through which our Services and Documentation are available and provide Data are made available.

1.9. “Privacy Policy” means our privacy policy as made available to you on the Website.

1.10. “Renewal Period” has the meaning set forth in Section 4.1.

1.11. “Services” means any and all functionality and services provided to you though the Platform including without limitation the ability to build portfolios, to receive and use Data we may provide, to conduct paper trading, to use risk management tools, to receive trading insight and analysis, to use performance reporting tools and analysis tools, and to perform back testing, as well as any other services which we may offer from time to time through the Platform.

1.12. “Terms of Use” means these Terms of Use governing your relationship with us and your use of the Platform and receipt of the Services.

1.13. “Term” has the meaning set forth in Section 4.1.

1.14. “User”, “you” means a person or a company using the Platform and the Services as a user and licensee of Platform.

2. Access and Use

2.1. Provision of Access. Subject to these Terms of Use, we hereby grant you a non- exclusive, non-transferable right to access the Platform and use the Services during the Term, solely for personal use. We shall provide to you with the necessary username and passwords to allow you to access the Services. You agree to keep such access credentials confidential. The Platform may be used and accessed for lawful purposes only. You understand that it is your obligation alone to ensure that you fully comply with any law, regulation or directive, relevant to your country of residency with regards to the use of the Platform and the Services. The ability to access the Platform does not necessarily mean that the Services and/or your activities are legal under the laws, regulations or directives relevant to your country of residency.

2.2. Use Restrictions. You shall only use the Platform and Services for personal use, and not use for any purposes beyond the scope of the access granted under these Terms of Use. You shall not at any time, directly or indirectly; (i) copy, modify, or create derivative works of the Services, Data or Documentation, in whole or in part; (ii) rent, lease, lend, sell, license, sublicense, assign, distribute, publish, transfer, or otherwise make available the Services, Data or Documentation; (iii) reverse engineer, disassemble, decompile, decode, adapt, or otherwise attempt to derive or gain access to any software component of the Services or Platform, in whole or in part; (iv) remove any proprietary notices from the Services, Data or Documentation; (v) distribute, re-transmit, encumber, sell, rent, lease, sublicense, assign or otherwise transfer any of the content, data or information provided by us or our licensors, including Data, or trade insights in any form or by any medium, (vi) use the Services or Documentation in any manner or for any purpose that infringes, misappropriates, or otherwise violates any intellectual property right or other right of any person, or that violates any applicable law; or (vii) use the Platform or Services in a manner which constitutes a violation of applicable law.

2.3. Updates and Support. At our discretion, we may make updates or upgrades available for the Platform and/or the Services. On a case-by-case basis and at our sole discretion we may offer support relating to the use of the Platform and Services consisting of online FAQ, online documentation, user manuals or tutorials (“Documentation”), live chat and support over email. Support inquiries can be addressed to support@eigenfintech.com.

2.4. Reservation of Rights. We reserve all rights not expressly granted to you under these Terms of Use. Except for the limited rights and licenses expressly granted under these Terms of Use, nothing in these Terms of Use grants, by implication, waiver, estoppel, or otherwise, to you or any third party any intellectual property rights or other right, title, or interest in or to our intellectual property.

2.5. Suspension. Notwithstanding anything to the contrary, we may temporarily or permanently suspend your access to any portion or all of the Services if: (i) we reasonably determine that (A) there is a threat or attack on any of our intellectual property rights, (B) your use of the Services disrupts or poses a security risk to the Platform or to any of our other customers or vendors, (C) you have made an assignment for the benefit of your creditors or similar disposition of your assets, or become the subject of any bankruptcy, reorganization, liquidation, dissolution, or similar proceeding, or (D) our provision of the Services to you is prohibited by applicable law; (ii) any of our vendors has suspended or terminated our access to or use of any third-party services, data or products required to enable us to provide the Platform or the Services.

3. Customer representations and responsibilities

3.1. General. You are solely responsible and liable for all uses of the Services and Documentation resulting from access provided by you, directly or indirectly, whether such access or use is permitted by or in violation of these Terms of Use. Without limiting the generality of the foregoing, you are responsible for all acts and omissions made in connection with your use of the Platform and Services.

3.2. Personal use only. You represent that your use of the Platform and Services is for your personal use only. You agree to not provide access to the Platform or Services to any other person or assist others to do so. You agree to immediately inform us in the event that the foregoing representation is no longer accurate.

3.3. No Advice or Solicitation. The Platform and Service are for informational purposes only. You acknowledge that we are not registered under applicable securities laws, and therefore not authorised to provide investment advice or conduct registrable activities. You furthermore acknowledge and agree that the Platform and Services are (i) designed solely to provide you with data, tools and functionality to facilitate your investment decisions, and (ii) not intended to supply investment or financial advice or a recommendation to trade using any specific strategy or otherwise a recommendation to purchase an investment product. We offer no advice regarding the nature, potential value, or suitability or any particular currency, transaction, investment product or investment strategy. As such no appropriateness assessment or suitability assessment will be conducted by us in connection with your financial situation, investment knowledge or objectives, or in connection with any investment decision you make. You should not construe any Data or information provided by us, the Platform or the Services as legal, tax, investment, financial or other advice. Nothing in the Platform or Services is a solicitation to buy, sell or hold foreign currencies or other investments or financial instruments.

3.4. Your representations. Each time you access the Platform or use the Service, you represent and acknowledge to us that:

3.4.1. any decisions to buy, sell, hold or trade in securities, currencies, crypto-assets and other investments involve risk and are best made based on the advice of qualified financial professionals. Any trading in investments involves a risk of substantial losses;

3.4.2. any decision on whether or not to use the Platform and Service is at your own risks, and that the use of the Platform and Service is not customized to your personal situation;

3.4.3. any use of any Platform, Data (including trading insight or signals), or information developed using the Platform, the Services or any Data, or any other information, products or services provided by or through the Platform and the Services, including trade insights, does not and cannot guarantee that you will make profits, increase profits or minimize losses;

3.4.4. trading results based upon hypothetical or historically-tested trading strategies or systems do not necessarily compare to results of actual trading. No hypothetical or historical trading record can account for the level of risk present in actual trading;

3.4.5. there is no guarantee that your hypothetical trading results, even if tested against historical data, will produce comparable actual trading results. In fact, there are frequently sharp differences between hypothetical or historically tested performance results and the actual results subsequently achieved by any particular trading system or strategy;

3.4.6. before undertaking any actual trades or trading program, strategy or acting further to signals provided as part of the Services, you should consult a qualified financial professional. Please consider carefully whether trading or investing is suitable for you in light of your financial condition, financial objectives and ability to bear financial risks;

3.4.7. no representation is being made that you will or are likely to achieve profits or any specific result using the Platform and Services. Your attempt to implement strategies or trade on the basis of Data may be hindered by the inherent delay in receiving and executing a trade; market liquidity, and your own trading issues, including, but not limited to slippage, commissions, trading software, and internet outages. The actual results experienced by you using the Platform and Services will vary depending on many factors, including, but not limited to: the settings you have selected, your personal financial situation and risk tolerance, market behavior, and the implementation of your strategies.

4. Term and Termination.

4.1. Subscription term. Your subscription and license shall, unless otherwise terminated as provided in this Section 4, commences on the day you agree to be bound by these Terms of Use, and shall continue for the Initial Subscription Term (e.g., whether monthly for Monthly Plans, or yearly for Annual Plans) and, thereafter, your subscription and license shall automatically renew for successive periods equal to the Initial Subscription Term (each a “Renewal Period”, and together with the Initial Subscription Term, the “Term”). Either party may terminate this subscription and license upon ten (10) written notice. Termination is effective as of the end of the then current subscription period. We do not provide you a refund if you terminate your subscription before the end of the Term. Any termination shall be effective at the end of the then current billing period.

4.2. Immediate termination. Without affecting any other right or remedy available to us, we may terminate your right to access and use the Platform with immediate effect by giving written notice to you if:

4.2.1. you commit a material breach of these Terms of Use which breach is irremediable or (if such breach is remediable) fails to remedy that breach within a period of five (5) days after you being notified in writing to do so;

4.2.2. you fail to pay any amount due under these Terms of Use on the due date for payment and remains in default not less than five (5) days after you are notified in writing to make such payment;

4.2.3. you repeatedly breach these Terms of Use;

4.2.4. you suspend, or threaten to suspend, payment of your debts or are unable to pay your debts as they fall due or admit inability to pay its debts or are deemed unable to pay your debts.

5. Fees and Payment.

5.1. Fees. You agree to pay us the fees ("Fees") charged in connection with the subscription plan you have selected without off-set or deduction. You shall make all payments in Canadian dollars on or before the due date in accordance with our billing policy and procedure, and those of our payment service providers. You agree that we may change our billing policy and procedure upon notice to you. You also agree that we may change our fees for Services upon notice to you. Without limitations to our other rights, we may suspend your access to any portion or all of the Platform where you fail to pay overdue amount to us until such amounts are paid in full.

5.2. Billing information. You acknowledge that you have provided us with valid, up-to-date and complete payment details and any other relevant valid, up-to-date and complete contact and billing details.

5.3. Taxes. All Fees and other amounts payable by you under these Terms of Use are exclusive of taxes and similar assessments. You are solely responsible for all harmonized sales tax (HST), provincial sales tax (PST), goods and services tax (GST), value added tax, use and excise taxes, and any other similar taxes, duties, and charges of any kind imposed by any federal, provincial, territorial, or local governmental entity on any amounts payable by you hereunder, other than any taxes imposed on our income.

6. Confidential Information and Privacy.

6.1. Confidential information. From time to time during the Term, we or you may disclose or make available to the other information about its business affairs, products, confidential intellectual property, Documentation, trade secrets, third-party confidential information, and other sensitive or proprietary information, whether orally or in written, electronic, or other form or media, whether or not marked, designated, or otherwise identified as "confidential" (collectively, "Confidential Information"). Confidential Information does not include information that, at the time of disclosure is: (a) in the public domain; (b) known to the receiving Party at the time of disclosure; (c) rightfully obtained by the receiving Party on a non-confidential basis from a third party; or (d) independently developed by the receiving Party. The receiving Party shall not disclose the disclosing Party's Confidential Information to any person or entity, except to the receiving Party's employees who have a need to know the Confidential Information for the receiving Party to exercise its rights or perform its obligations hereunder. Notwithstanding the foregoing, each Party may disclose Confidential Information to the limited extent required (i) in order to comply with the order of a court or other governmental body, or as otherwise necessary to comply with applicable law, provided that the Party making the disclosure pursuant to the order shall first have given written notice to the other Party (if legally permitted) and made a reasonable effort to obtain a protective order; or (ii) to establish a Party's rights under this Agreement, including to make required court filings. Each Party's obligations of non- disclosure with regard to Confidential Information are effective as of the Effective Date and will expire two (2) years from the date first disclosed to the receiving Party.

6.2. Privacy policy. Any personal data or information which you provide to us is also subject to the latest version of our privacy policy available on our Website (“Privacy Policy”), which is incorporated by reference into these Terms of Use.

7. Intellectual Property Ownership.

7.1. IP Ownership. You acknowledge that, as between us and you, we own all right, title, and interest, including all intellectual property rights, in and to our IP, the Platform and the Services and, with respect to third-party products, the applicable third-party providers own all right, title, and interest, including all intellectual property rights, in and to such third- party products.

8. Limited Warranty and Warranty Disclaimer.

8.1. WE DO NOT MAKE ANY REPRESENTATIONS OR GUARANTEES REGARDING UPTIME, ACCURACY OR AVAILABILITY OF THE SERVICES. THE SERVICES, PLATFORM AND DATA ARE PROVIDED "AS IS" AND WE HEREBY DISCLAIMS ALL WARRANTIES AND CONDITIONS, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE. WE SPECIFICALLY DISCLAIM ALL IMPLIED WARRANTIES AND CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT, AND ALL WARRANTIES ARISING FROM COURSE OF DEALING, USAGE, OR TRADE PRACTICE. WE MAKES NO WARRANTY OF ANY KIND THAT OUR IP, OR ANY PRODUCTS OR RESULTS OF THE USE THEREOF OR OF THE SERVICES, WILL MEET YOUR REQUIREMENTS, OPERATE WITHOUT INTERRUPTION, ACHIEVE ANY INTENDED RESULT, BE COMPATIBLE OR WORK WITH ANY SOFTWARE, SYSTEM, OR OTHER SERVICES, OR BE SECURE, ACCURATE, COMPLETE, FREE OF HARMFUL CODE, OR ERROR FREE.

9. Limitation of Liability

9.1. You acknowledge and agree that: (i) You alone assume sole responsibility for any investments or decisions you make based on your use of the Services, information, products or services provided by or through the Platform, including Data and trade insights; (ii) You understand that there can be no guarantee that your use of the Services or the information disseminated through the Platform will result in profits, and you furthermore understand that such your use may result in substantial losses; (iii) the provision of the Platform, Data and Services is made with equipment, communications devices, and/or leased lines not owned or operated solely by us; (iv) neither we, nor any of our directors, officers, employees or agents, guarantees the sequence, accuracy or completeness of the Data or the Services, nor shall any of them be liable to you or any other person for any delays, inaccuracies, errors or omissions in Data, or in the transmission thereof, or for any other damages arising in connection with your use of the Platform, Data, or Services whether or not resulting from negligence on their part, a Force Majeure Event or any other cause beyond their reasonable control; and (v) if the foregoing disclaimer and limitation of liability should be deemed invalid or ineffective by a court of competent jurisdiction, neither we or our licensors, nor their respective directors, officers, employees or agents shall be liable to you for any of the foregoing beyond the actual fees paid by you in the six (6) month period preceding the date of any actual loss.

9.2. IN NO EVENT WILL WE, OUR OFFICERS, DIRECTORS, EMPLOYEES OR AGENTS, BE LIABLE TO YOU FOR ANY DAMAGES WHATSOEVER, INCLUDING WITHOUT LIMITATION, INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE OR CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE PLATFORM AND THE SERVICES WHETHER THE DAMAGES ARE FORESEEABLE AND WHETHER OR NOT WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT WILL WE BE LIABLE TO YOU FOR ANY DAMAGES WHATSOEVER, INCLUDING WITHOUT LIMITATION, INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE OR CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE PLATFORM AND THE SERVICES.

9.3. WITHOUT LIMITING THE FOREGOING, UNDER NO CIRCUMSTANCES SHALL WE BE LIABLE FOR ANY LOSS OR DAMAGE YOU OR ANYONE ELSE INCURS AS A RESULT OF ANY TRADING OR INVESTMENT ACTIVITY THAT YOU OR ANYONE ELSE ENGAGES IN BASED ON ANY INFORMATION, DATA OR MATERIAL YOU RECEIVE THROUGH THE PLATFORM, OR SERVICES.

10. Indemnification

10.1. You agree to defend, indemnify, and hold us, our shareholders, subsidiaries, affiliates, customers, vendors, and their respective officers, directors, employees and agents, harmless from and against any claims, liabilities, damages, losses, and expenses, including without limitation reasonable attorney’s fees and costs, arising out of or in any way connected with:

10.1.1. Your access to or use of the Platform and the Services;

10.1.2. Your violation of these Terms of Use;

10.1.3. Your violation of any applicable law, rule or regulation;

10.1.4. Your violation of any third party right, including without limitation any intellectual property right, publicity, confidentiality, property or privacy right.

11. Miscellaneous.

11.1. Entire Agreement. These Terms of Use, together with any other documents incorporated herein by reference (including without limitation any other operating rules, policies and procedures which we may issue or publish on our Website from time to time), constitutes the sole and entire agreement of the Parties with respect to the subject matter of this Agreement and supersedes all prior and contemporaneous understandings, agreements, and representations and warranties, both written and oral, with respect to such subject matter.

11.2. Notices. Each Party shall deliver all notices, requests, consents, claims, demands, waivers, and other communications under this Agreement (other than routine communications having no legal effect) (each, a "Notice") in writing and addressed to the other Party at the email addresses provided by the other party. Notice to us shall be provided to the following address(i) support@eigenfintech.com, or through a support function provided within the Platform. We may provide you notice to the email address provided by you when you open your account with us, or as otherwise notified by you in writing.

11.3. Force Majeure. In no event shall we be liable to you, or be deemed to have breached this Agreement, for any failure or delay in performing our obligations, if and to the extent such failure or delay is caused by any circumstances beyond our reasonable control, including but not limited to acts of God, epidemics, pandemics, flood, fire, earthquake, explosion, war, terrorism, invasion, riot or other civil unrest, strikes, labour stoppages or slowdowns or other industrial disturbances, or passage of law or any action taken by a governmental or public authority, including imposing an embargo.

11.4. Changes to this Agreement. From time to time, and at our sole and absolute discretion, we may change or amend these Terms of Use by providing notice to you to the email address that we have on file at least thirty (30) days in advance of such amendment becoming effective. By continuing to use the Platform or Services after the changes to the Agreement come into effect you agree to be bound by these changes. If you do not agree with the changes to this Agreement then you can choose to discontinue using the MogoTrade services and close your Account before the changes become effective.

11.5. Change in Services. We may at any time, without notice or liability, decide to alter, amend, restrict, modify, or terminate the Services or any functionality or aspect of the Platform, all in our sole discretion, and you understand that there is no guarantee that the services or any portion or functionality thereof will continue to operate or be available for any particular period of time, including as a result of the removal, addition, modification, or change of or in the availability of the Services, or any restriction in access thereto, or any imposition of limits on any or all features of, or links to, the Services.

11.6. Waiver. No waiver by any Party of any of the provisions hereof will be effective unless explicitly set forth in writing and signed by the Party so waiving. Except as otherwise set forth in this Agreement, (i) no failure to exercise, or delay in exercising, any rights, remedy, power, or privilege arising from this Agreement will operate or be construed as a waiver thereof, and (ii) no single or partial exercise of any right, remedy, power, or privilege hereunder will preclude any other or further exercise thereof or the exercise of any other right, remedy, power, or privilege.

11.7. Severability. If any provision of this Agreement is invalid, illegal, or unenforceable in any jurisdiction, such invalidity, illegality, or unenforceability will not affect any other term or provision of this Agreement or invalidate or render unenforceable such term or provision in any other jurisdiction.

11.8. Governing Law. This Agreement shall be governed by and construed in accordance with the laws of the province of Quebec and the federal laws of Canada applicable therein, without giving effect to their conflict of law provisions. You agree that you will bring any claim or cause of action arising out of this Agreement, your use of Services in the courts located within Montreal, Quebec. Furthermore, you agree to submit to the personal, non- exclusive jurisdiction of any such court or arbitrator, as the case may be.

11.9. Assignment. This Agreement, or your rights and obligations hereunder, may not be transferred or assigned by you, but may be assigned by us without restriction. Any attempted transfer or assignment by you in violation hereof shall be null and void. This Agreement shall be binding and inure to the benefit of the parties hereto, our successors, and permitted assigns. This Agreement is binding on your heirs, executors, administrators, and successors.

11.10. Quebec Residents. It is the express wish of the parties that this Agreement and all documents, notices and other communications relating to the operation of your Account be in English. Il est de la volonté expresse des parties que la présente convention et tous les documents, avis et autres communications qui concernent la tenue du compte soient rédigés en langue anglaise.

Eigen Fintech Privacy Policy

Policy relating to the Collection, Use and Disclosure of Personal Information

14872525 Canada Inc. operating and doing business as Eigen Fintech Inc. (“Eigen”) is committed to maintaining the privacy and confidentiality of all personal information under our care. In the course of providing data, analytics and trading tools to you as part of our SaaS subscription offering, Eigen is obligated to collect, use and store personal information about individuals. The purpose of this Policy is to answer questions about what personal information we hold and may transfer, the purposes for which we collect it, how we protect it, who it may be disclosed to, and how it can be accessed or modified. This policy applies to all customers of Eigen and is in addition to the Terms of Use agreements governing the services we render for our customer. By subscribing to receive our subscription-based services via our platform, you signify your consent to the terms of this Privacy Policy. This Privacy Policy also serves to govern the conduct of all Eigen employees with regard to personal information.

1. TYPES OF PERSONAL INFORMATION UNDER OUR CARE

When we open and maintain an account, we are obligated to collect the following types of information out of necessity or legal obligation:

2. PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL INFORMATION

We collect and use the personal information we obtain during the account opening and and in the course of providing services to you for the following purposes:

3. PROTECTION OF INFORMATION

We use physical security measures that are technological and administrative to protect the Information we collect from you. We take all useful precautions to preserve the security, integrity and confidentiality of your Information and in particular, to prevent them from being distorted, damaged or accessed by unauthorized third parties. We ensure our employees and partners handle your Information with care at all times and we require them to maintain their obligations of confidentiality even after the end of their contract with us.

We may transfer Information to outside agents or service providers that perform services on our behalf, for example, mailing, call center, billing, collections, skip-tracing, marketing, analytics, information technology and/or data hosting or processing services or similar services, or otherwise to collect, use, disclose, store or process your information on our behalf for the purposes described in this Policy. Some of these service providers may be located outside of Canada, including in the United States, and as a result, your Information may be processed and stored on servers outside of Canada for the purposes described in this Policy. Contractual clauses and other measures we may take to protect your Information while processed, stored or handled by these service providers are subject to applicable Canadian and foreign legal requirements, including lawful requirements to disclose personal information to government and national security authorities in certain circumstances.

We use Google Analytics to collect information about how visitors interact with our platform. This data helps us understand user behavior, track site performance, and improve our services. Google Analytics collects information such as your IP address, device type, browser type, and pages visited on our platform. This information is used to generate reports and analyze trends but does not identify individual users. By using our platform, you consent to the collection and processing of data by Google Analytics. For more information on how Google processes your data, please refer to theGoogle Privacy Policy.

In all cases, we require outside agents, service providers, and partners to protect your Information at the same high level that we have committed to.

4. DISCLOSURE OF INFORMATION

Eigen does not sell personal information to third parties. Eigen does not disclose personal information to third parties other than in the following circumstances and for the following purposes:

(1) In the normal course of business operations to open or service client accounts, including, without limitation, for purposes of facilitating the account opening process and the provision of customer service and processing customer payments (including services rendered by third party processors), and for internal audit and accounting purposes;
(2) To specific Eigen employees in order to offer services to clients, to engage in surveillance of the Eigen platform and/or to ensure disaster recovery services relating to such information (which may include trans-border transfers of information);
(3) To other suppliers or service providers who assist us in serving our clients. Our service providers may at times be responsible for processing payment information, including personal information. Such service providers are provided only with the information necessary for them to perform their services. In addition, we require them to protect the information in a manner that is consistent with our privacy policies and customary security practices. In the event our service provider is located in a foreign jurisdiction they are bound by the laws of the jurisdiction in which they are located and may disclose personal information in accordance with those laws;
(4) To legal counsel for the purpose of obtaining legal advice;
(5) Where we are required or permitted to do so by law.

We will limit our disclosure of your Personal Information to such third parties to that which is reasonably necessary for the purpose or service for which the third-party service provider is engaged. We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, including limiting such providers to using your Personal Information solely to provide Eigen with the specific service for which those providers were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by contacting us at the addresses provided under “Access to Information”.

By opening or maintaining an account with Eigen, clients consent to the disclosure of personal information to a third party in the circumstances or for the purposes described above. Eigen’ clients must understand, acknowledge and agree that their consent to the disclosure of personal information in connection with a matter referred to above is not a condition of Eigen for transacting with its clients, including the relevant offer or service to be provided, unless the disclosure of the information is necessary in respect of the particular service or required by law. Subject to this qualification, consent to Eigen’ collection, use or disclosure of personal information may be revoked or withdrawn, at any time on reasonable notice, by contacting Eigen’ Support Department by email at support@eigenfintech.com. If consent were to be revoked or withdrawn, Eigen may be unable to provide certain services. Our Support Department personnel will be happy to explain any consequences of revoking or withdrawing consent.

5. ACCESS TO INFORMATION

Eigen makes every reasonable effort to ensure that personal information is accurate and up-to- date. Individuals can also request rectifications, a withdrawal or the destruction of all personal information, that we collect at any time by contacting our Support Department by email at support@eigenfintech.com.

Individuals may also consult and access the personal information Eigen maintains by contacting Eigen’ Support Department by email at support@eigenfintech.com and scheduling an appointment. In your request, please include the relevant account number(s), and the information which you would like to have updated or modified.

6. INQUIRIES OR COMPLAINTS

Eigen’s Chief Regulatory Officer (CRO) is responsible for the monitoring compliance with this Privacy Policy. Inquiries or complaints regarding this Privacy Policy should be directed to support@eigenfintech.com by email support@eigenfintech.com.

7. POLICY UPDATE

We may revise this Privacy Policy from time to time, in response to legal developments, as new technologies become available, or as we introduce new features, products or services.

When we make changes to this Privacy Policy we will revise the “last updated” date at the bottom of the page. You should check back here periodically to find out if any changes have been made. If we make substantial changes we will, as appropriate, prominently post these changes to our website or notify you directly.

If you disagree with any change to the Privacy Policy, you may close your account and refrain from using our services, or in some cases, by opting out. Continuing to use our services, including our websites, after we post or communicate a change signifies that you consent to the revised terms of the Privacy Policy.

On occasion, we may also identify new purposes for the collection or use of Personal Information, such as in connection with a new promotion or service. We will describe such uses in separate notices or other communications.

Last Update: August 2, 2024