General Conditions of Personal Financial Assistant (PFA) Terms

  1. Definitions And References

    1. Terms used in the General Conditions of the PFA Terms have the respective meanings as defined in the Terms of Use of the Company, which shall apply to the PFA-Terms unless otherwise stated herein:
      1. Account Information Services or AIS – a service that provides consolidated information on one or more payment accounts held by a payment service user with one or more other payment service providers.
      2. API – Application Programming Interface - a set of functions and procedures that allow the creation of applications which access the features or data, or content of an operating system, application, or other service provided by a 3rd party.
      3. App – the GG app
      4. App Store – an app store platform allowing users to browse and download apps including the App, e.g., Apple Store, Google Play, or HUAWEI AppGallery.
      5. Content – means anything that is to be expressed in an App, the Website, or other media such as speech, writing, a film, clip, video or any other various art. Content can be created by the Company or by the User.
      6. Contract – means an agreement on using an App and/or providing the Services according to these Terms entered into between the Company and the User.
      7. Service or Services – a set of features which allow Users to track and analyze their financial situation or Account Information Services (as described in section Account Information Services provided by the Company of these Terms). Services may be different for Users of different platforms App (Android, iOS). Company has the right to add or limit scope of Services at any time.
      8. User or you – a person who uses an App, the Services, and other applications, websites or reads content created or made available by the Company.
      9. PFA(Personal Financial Assistant) – a program (application) PFA which was created by the Company to record the Users’ income and expenses as well as other financial or nonfinancial records or content by User’s choice. The PFA is designated to be used by natural persons for their personal use only. PFA service is available for devices running on Android and iOS systems as a App and as a desktop internet platform available at the Website. The purpose of the PFA is to track the expenses and incomes of the User. Through PFA you may grant the Company a consent to require information about your payment account from a third party, which maintains your payment account. Use of PFA is defined in these Terms, which were issued by the Company and accepted by the User.
      10. PFA-Account or you – a type of a GG-Account by which the User has consented to use PFA Services under the PFA-Terms.
  2. Entry Into Pfa-Terms

    1. The PFA-Terms are legally binding and shall be considered concluded between the Company and the GG-User as of the date when the respective PFA-Terms are digitally approved by the GG-User.
    2. These Terms of Services (the “Terms”) apply to users of the mobile applications and to visitors of the portal, and to users of any other Service, product or content made available in connection with the Company.
    3. By using or accessing either via a computer, mobile phone or other electronic device either App or the Website (including the mobile version of the Website) or any product, content or other service made available by the Company, you hereby agree to be bound by these Terms as well as additional third-party terms and conditions as indicated in these Terms or in other documents provided in the App or on the Website.
  3. Services And Prices

    1. The Service is designed to Users for tracking their transactions in the App interface and based on those records, the PFA provides charts, overviews of information based on mathematical models.
    2. Users can enter their data by automatic synchronization with their bank account. This automated functionality allows its Users to import their transactions from their bank accounts by giving consent for the App to provide relevant credentials to their bank account by PFA Services. This connection is read-only and any data from User’s bank account cannot be modified or changed.
    3. Based on the imported data, the Service provides automated categorization of transactions, including historical overviews, summaries and predictions for future expenses. Company only provides estimated average predictions based on PFA User’s transaction data.
    4. The PFA Service is free to use.
  4. Account Information Services Provided By The Company (Payment Account Synchronization)

    1. This section (Account Information Services) applies whenever a User request that Company provides Account Information Services (AIS) as defined in more detail in respective payment regulations, in particular, but not limited to, the PSD2 and all laws or regulations in force from time to time in jurisdiction giving effect to PSD2, regardless of via what application you have requested Company to provide you with the AIS, i.e. the App or other third party.
    2. The AIS provided by PFA is designed to be able to connect a User’s bank account and receive automated imports of data and transactions performed by the user through their bank account or multiple bank accounts. This functionality is designed as read-only, and the users cannot modify data (amounts, dates) which are retrieved from this source.
    3. Company can only provide the AIS based on your explicit consent confirming your approval of Company accessing your respective payment account. You will be asked to provide the consent. You can revoke this consent at any time within the App. You can also notify Company of your consent revocation by an email to the email address provided below. You hereby acknowledge that the revocation/expiration of consent does not affect the actions of Company prior to the revocation/expiration.
    4. By using PFA, you hereby confirm that you (i) are the legal holder of the the respective payment account and have the legal right to use the associated payment account data, or (ii) are duly authorized by the legal holder to access the payment account and use the personalized security credentials and associated payment account data. You must immediately notify Company and your respective account service Provider if you become aware of any loss, theft or unauthorized use or disclosure of your personalized security credentials or any payment account data. Company reserves the right to deny you access to the AIS if Company reasonably believes that any loss, theft, or unauthorized use or disclosure of the foregoing information has occurred.
  5. Term And Termination

    1. The PFA-Terms have been concluded for an indefinite period.
    2. The User may cancel (in Estonian: üles ütlema) the PFA-Terms by giving the Company notice via the respective application available at the Portal. The PFA-User is considered to have cancelled the PFA-Terms in case the User does not renew consents for the Service;
    3. The Company may at any time restrict access to the PFA-Account and the services related thereto at its discretion. The Company may also cancel the PFA-Terms partially or in full by giving the User notice of at least 7 calendar days in advance via the Portal, in case, among other:
      1. the User is in breach of the Terms of Use or the PFA-Terms;
      2. the Company discontinues its services.
  6. Third-Party Services

    1. Users acknowledge that the Company could use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the App and PFA.
    2. By accepting these Terms, the User acknowledges that there may be terms and conditions or privacy policies which apply for the use of third-party services. The Company holds no or limited control over the malfunction or disruption of third-party services and does not guarantee them. The Company is not liable for any third-party services or any third-party content.
    3. Please note that a third party, which maintains your payment account, enables the Company to use its API in order for the Company to be able to access information about your payment account.
  7. Amendment Of Pfa-Terms

    1. For the purposes of development of services and their better and securer use, the Company has the right to unilaterally amend and modify the General Conditions of the PFA-Terms.
    2. The Users shall be informed of amendment of the General Conditions of the PFA-Terms via the Portal. Amendments and modifications shall enter into force within 4 weeks as of the disclosure of the notification in the Portal (unless a shorter notification period is prescribed herein for specific amendments) or when the User accepts the General Conditions of the PFA Terms by clicking the respective box when the User logs in to the Portal, whichever occurs earlier.
    3. Upon disagreement with the amendments and modifications, the User shall terminate the PFA- Terms in full as prescribed herein.
  8. The App’S Stability And Consistency

    The Service is provided on “as is” and “as available” basis.

    The Company does not warrant that (a) the Service will meet your specific requirements, (b) the Service will be uninterrupted, timely, secure, or error-free, (c) the results that may be obtained from the use of the Service will be accurate or reliable, (d) the quality of any Services, information, or other material purchased or obtained by you through the Service will meet your expectations, or that (e) any errors in the App will be corrected.

    There may be situations when the PFA Services may be temporarily unavailable in some of its parts or the Service will be interrupted due to technical reasons. The stability and consistency of the Service or the App is not guaranteed.

  9. Support And Maintenance

    If you have any queries, you can reach the Company via contacts provided in the Contacts section. Please consider that the support to the PFA may be constrained due to the limited capacity of the Company.

  10. Permissions And Privacy Policy

    1. To access the App features such as taking or storing your pictures, geolocation services, payment account synchronization, identity, contacts, wi-fi connection or others, you must grant the Company access permissions required by the App, respectively by Google or Apple or 3rd party Company. This access will be used only for the activities related to the functionality of the App; Some other information is scanned on your mobile device. You can manage your consent to permissions inside the App and in your mobile device settings. Further information can be found in the Privacy Policy. Your disagreement to those permissions will prevent the App from displaying requested functionality, where the permission is required. Disagreement to these Terms can be expressed by deleting your account at any time.
    2. We only process your personal data in order to provide you with the Service. For details of processing personal data please refer to our Privacy Policy.
  11. Limitation Of Liability

    1. You hereby acknowledge and agree that the content of the Service do not constitute and is not intended to be financial, accounting, tax or any other professional advice and should not be relied upon as such.
  12. Final Provisions

    1. No security. The PFA-Terms cannot be construed to create any type of a security. The PFA-Terms, any part or any rights arising hereof cannot be assigned to a third party without prior written agreement between the Parties. However, the Company may assign a part or all of the PFA-Terms (including rights and/or obligations hereof) to its subsidiaries or the group companies. The PFA-User hereby gives its irrevocable consent for such transfer. In such case the Company will remain severally liable for obligations that have been created and are callable at the moment of assignment.
    2. Confirmation of understanding. By confirming the PFA-Terms each Party (and its representative) confirms that he/she has in full read the PFA-Terms, received detailed information concerning the rights and obligations arising from the PFA-Terms, and that he/she fully understands and agrees with the terms and conditions of the PFA-Terms.
    3. No waiver. No delay in performing an obligation or in exercising any right under the PFA-Terms shall mean exemption of such obligation or waiver of such right, nor will separate or partial performance of any obligation or exercise of any right to exclude further performance of such obligation or further exercise of such right.
    4. Applicability of the Terms of Use. To the extent that the relationships between the parties to the PFA-Terms have not been regulated by the PFA-Terms, they shall be governed by the provisions of the Terms of Use in force, which constitute an inseparable part of the PFA-Terms. In case of discrepancies between the PFA-Terms and Terms of Use or any other document applicable between respective parties, the PFA-Terms shall prevail.
    5. Governing law and dispute resolution. The PFA-Terms shall be subject to the legislation of the Republic of Estonia. To the extent permitted under applicable law, the courts of the Republic of Estonia shall have exclusive jurisdiction to solve any disputes related to the PFA-Terms. Harju County Courtn shall be the court of first instance.
    6. The PFA-Terms have been drawn up in English.
  13. Contact Information

    All question, complains or claims with respect to the App or other Services should be addressed to the Company using the following contact details:

These Terms came into force and effect on May 25, 2022.

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