Terms of Use

The Terms of Use apply to any and all legal relationships between the User and the Company and other Users.

  1. Definitions

    Assignment Agreement – an agreement concluded through the Portal and entered into upon the assignment of the Claim with which the Company assigns the Claim to the Buyer.

    Borrower – a person who has entered into the Loan Agreement as a borrower or a person who has submitted an application for taking the Loan.

    Banking Day – a business day, i.e., any day, except Saturday, Sunday, a national or a public holiday in the Republic of Estonia.

    Buyer – the User who has bought or has made an offer to buy the Claim from the Company or the Seller.

    Claim – a monetary claim deriving from the Loan Agreement against the Borrower. The exact composition of the Claim is provided in the Portal.

    Company – Bondora Capital OÜ, incorporated under the laws of the Republic of Estonia, registry code 12831506.

    Company's Postal Address – A.H. Tammsaare tee 47, 11316 Tallinn, Republic of Estonia.

    Current Account of Portal - the current or deposit account of the Company in a bank where the money transferred by the Users, pursuant to the User Agreement or any other agreement, shall be held.

    Debt Servicing Cost – a fixed rate determined by the Company for compensating the costs related to debt collection and legal recovery process of the specific Borrower by the Buyer to the Company. These costs include all direct and actual costs related to debt collection (reminders, debt collection agency fees, the fee for collection, etc.) and legal recovery (court fees, lawyer fees, etc.).

    Default - the cancellation of the respective Loan Agreement in the event where the Borrower has failed to make scheduled payments in full under the Loan Agreement and more than one month have passed from the due date of the second repayment (which was not paid duly), and if an additional term of two weeks has been granted to the Borrower for the payment of unpaid amount borrowed (without due payment), if not agreed differently in the Loan Agreement or required by law in force. In case of Default, the payment of the whole debt (i.e., the Loan together with accrued interest, interest on arrears and fees) shall be claimed from the Borrower.

    GG-Account – a type of a Portal Account designated solely for use under the GG-Terms.

    GG-Buyer – the GG-User specified in the particular GG-Terms.

    GG-Claims – the Claims acquired by any GG-User or the Company under the GG-Terms or allocated as such under the GG-Terms.

    GG-Price – the aggregate Purchase Price to be paid by the Company to the GG-Buyer for the acquisition of all or a particular portion of the GG-Buyer's GG-Claims.

    GG-Terms – the Terms of Use of Go & Grow concluded between the Company and the User including the General Conditions of Go & Grow Terms.

    GG-User – the User who has a valid agreement with the Company under the GG-Terms.

    Loan – the principal amount lent by a credit provider to the Borrower in accordance with the Loan Agreement and the subject of repayment by the Borrower.

    Loan Agreement – a loan agreement concluded through the Portal between the Borrower and credit provider.

    Portal – an e-service environment located at www.bondora.com on the Internet and administered by the Company, through which Users can sell and purchase Claims.

    Portal's Mailbox – application of the Portal through which the Users can receive important personal messages when using the Portal and through which the Users are able to send personal messages to other Users, the Company or other persons operating in the Portal.

    Portfolio Manager – an application of the Portal that automatically submits transaction orders according to the terms and conditions determined by the Buyer.

    Portfolio Pro – an application of the Portal that automatically submits transaction orders according to the terms and conditions determined by the Buyer.

    Portal Account – User’s or the Company’s separate virtual account in the Portal regarding the settlements and transactions with the Company and other Users arising from the User Agreement, the Assignment Agreement, the Resale Agreement and other agreements. The User can also access all the agreements through the Portal Account concluded with the Company.

    Purchase Price – a price of the Claim agreed between the Buyer and the Company in the Assignment Agreement or between the Buyer and the Seller in the Resale Agreement.

    Reference Number – a personalzsed number for each User by which a User can be identified.

    Resale Agreement – an agreement concluded through the Portal in the Secondary Market between the Seller and the Buyer upon resale of a Claim.

    Seller – the User who sells the Claim belonging to him/her/itself via the Secondary Market managed by the Portal.

    Tender Management Process – a process of the Company under which the Company (a) determines the match between a Claim and the Tender Offer and (b) takes all the necessary steps to prepare the assignment of the Claim in accordance with the Assignment Agreement.

    Tender Offer – a non-binding offer of the Buyer that determines the criteria a Claim needs to meet in order for the Buyer to be willing to purchase a Claim from the Company or the Seller.

    Terms of Use – these Terms of Use, which are a part of the User Agreement.

    Trial Offer - from time to time the Company may offer free cash to the User for buying Claims through the Portal. The Company reserves the right to reclaim the Trial Offer in full if the respective User has received such a Trial Offer and has not purchased Claims in the amount of at least 10 euros within the 30 days of the receipt of such a Trial Offer. In case the Trial Offer has been used for purchasing the Claim by the respective User, the Company has a right to sell the Claim and transfer the funds received from such a sale to the account of the Company, or transfer the ownership of the respective Claim to the Company on behalf of the respective User. The Company is not obligated to notify the respective User of such reclaim of the Trial Offer or a sale of the Claim.

    User – a natural or a legal person who has entered into the User Agreement with the Company and has been registered as the user of the Portal.

    User Agreement – an agreement based on the Terms of Use concluded between the User and the Company under which the Company provides services to the User via the Portal. The User Agreement is concluded the moment when the User accepts the Terms of Use.

  2. General Duties and Obligations of User

    1. The User shall:
      1. not use the Portal for illegal transactions or operations, including fraud;
      2. submit only true information upon subscription, when purchasing a Claim, as well as when communicating with other Users;
      3. keep the tools required for logging into the Portal, including the ID card, passwords, and usernames or other tools, in such a manner that third parties do not gain possession thereof;
      4. inform the Company immediately, but no later than within five (5) days
        1. of changes in their submitted data;
        2. if third parties have gained possession of the data and tools specified in article 2.1.3;
        3. of changes or expiry of the legal entity User's representative's right of representation. The new representative must notify the Company of the expiration or change in the representation rights and present all necessary documents;
      5. submit additional documents and/or information to the Company if it is needed for the performance of the User Agreement or any other agreement concluded between the User and the Company;
      6. act prudently when using the Portal. Be polite and respectful when communicating with other Users or with the Company.
    2. The Company has the right to restrict or cancel the User's right to use the Portal and refuse to perform its duties or obligations under the User Agreement, the GG-Terms, the Assignment Agreement or any other agreement and/or retain the income earned through the Portal if it becomes evident that:
      1. the User is in a breach of the User Agreement or the User's duties or obligations under any agreement concluded via the Portal;
      2. the User has given to the Company or other Users false, misleading and/or inaccurate information;
      3. the User acts vulgarly or disregards the moral standards generally accepted in society when using the Portal or communicating with other Users or with the Company;
      4. the User has not identified itself/himself/herself in accordance with the Company's policies.
      5. the User refuses to provide requested information and/or documents specified in this User Agreement to the Company.
    3. The User confirms that it has/they have a bank account opened in his/her/its name at a bank operating in the European Economic Area or in Switzerland, or in other countries the Company has specifically approved, and is:
      1. a permanent resident of the European Economic Area or Switzerland and at least 18 years of age; or
      2. a legal person entered in the respective register in a Member State of the European Economic Area or Switzerland; or
      3. a natural or a legal person who has been separately approved by the Company to use the Portal; or
      4. an accredited investor that is registered in a country that is separately approved by the Company.
  3. Portal Account

    1. The money transferred to the Current Account of Portal will be reflected as receipts on the User's Portal Account whose Reference Number was referred on the transfer order. Such money transferred, on the basis of the User Agreement and other agreements may only be used by the Company, pursuant to the terms and conditions of and for performing the obligations of the User Agreement, the GG-Terms, the Assignment Agreement, the Resale Agreement and other relevant agreements.
    2. The money transferred by the User is thereby property handed over for the performance of the mandate for the purposes of § 626 of the Estonian Law of Obligations Act. The respective amount of money in the bank is, by its nature, a claim (against the bank) that the Company has acquired in its name but on behalf of the User and only with the purpose of using it for the performance of the mandate. The respective money does not belong to the bankruptcy estate of the Company and a claim for payment cannot be made for the money in enforcement proceedings against the Company, and it shall likewise not be reflected in the balance sheet of the Company. For the User, this above all means that by transferring money to the Current Account of Portal and thereby to the User's Portal Account, he/she/it does not completely transfer it to the assets of the Company, but instead retains the necessary rights concerning the money in order to recover it fully in case of bankruptcy of the Company. The Company shall not pay the User any interest for the money held on the Current Account of Portal.
    3. The Company shall have the right and obligation to make deductions from and inclusions to the User's Portal Account in order to perform the obligations of the User arising from the User Agreement, the GG-Terms, the Assignment Agreement, the Resale Agreement and other agreements entered into by the User. The User hereby irrevocably authorizes the Company to debit and credit the User's Portal Account as set forth in the Terms of Use, or any other agreement concluded via the Portal.
  4. Assignment of Claim

    1. The Company shall have the right to assign the Claims belonging to it to the Users or third parties.
    2. The Buyer has a right to place a Tender Offer to the Company through the user interface, application programming interface, Portfolio Manager, Portfolio Pro, or in accordance with the GG-Terms.
    3. The Tender Offer is valid for a maximum of three ( 3) Banking Days. The Buyer has the right to cancel the Tender Offer at any time through the User interface or application programming interface until the Company has started the Tender Management Process. In case the Tender Management Process takes longer than three (3) Banking Days to complete (i.e., to allocate a Claim that matches the Tender Offer) the Tender Offer shall be deemed to be void. For the sake of clarity, this article 4.3 does not apply to Tender Offers made under the GG-Terms.
    4. After the completion of the Tender Management Process, the binding Assignment Agreement will be generated and executed between the Buyer and the Company.
    5. Following the conclusion of the Assignment Agreement, the Buyer's Portal Account shall be automatically debited by the Company and the Company's Portal Account shall be automatically credited in the amount of the Purchase Price. The Claim shall be considered to be assigned from the Company to the Buyer the moment when the Buyer's Portal Account has been debited in the full amount of the Purchase Price.
    6. The Company or the Buyer shall not inform the Borrower concerning the assignment of the Claim, and the Company, or a person authorized by the Company, shall continue to service the Loan unless required otherwise by the Company.
    7. The terms stipulated in articles 5.6, 5.7, and 5.11 shall apply also to assignment of the Claim under the Assignment Agreement. Article 5.6 applies to the acquisition of the GG-Claims by the GG-User.
    8. The exact terms and conditions of the procedures related to assignment of a Claim are stipulated in the Assignment Agreement or, in case of acquisition of the GG-Claims, in the GG-Terms.
  5. Resale of Claims

    1. The User shall have the right to resell a Claim belonging to him/her/it to other Users.
    2. Resale of the Claims shall take place through the Portal.
    3. The Seller shall have the right to resell Claims at discount or mark-up. Discount and mark-up shall be calculated on the remainder of the Loan which forms a part of the Claim. Upon offering the Claims for resale, the Seller shall, when required, note the discount or mark-up rate for the Claim marked for resale.
    4. The Purchase Price shall be the remainder of the Loan which forms a part of the Claim to be resold along with the discount or mark-up, if any.
    5. Offering the Claims for resale shall be deemed to constitute a binding offer to all Users. The named offer shall be deemed to have been made when the Seller has verified the Claims to be assigned and signed or confirmed the respective offer. The offered Claims shall become visible to all the identified Users and all the identified Users shall be able to purchase the offered Claims at the price established by the Seller.
    6. Upon offering the Claims, the Portal shall not disclose the name, personal identification code, specific place of residence (the local government shall be disclosed), data concerning the employer, or the bank statement of the Borrower to the Users. Upon offering the Claims for sale, the Portal may disclose the data disclosed by the Borrowers themselves to all the Users, except for the data specified in this article.
    7. The Portal shall indicate the credit score of the Loan Agreement, however, the Company, the Seller, or any person involved in the credit-scoring, shall not be liable for the validity or correctness of credit-scoring of the Loan Agreement. The credit-scoring does not provide any assurances about the borrowing power of the Borrower or the fulfilment of the Loan Agreement by the Borrower. The Buyer hereby confirms that he/she/it understands the process and method of credit-scoring and that the credit-scoring is meant only for the internal processes of issuing credit by the credit provider, and does not provide any assurances about the borrowing power of the Borrower, or the fulfilment of the Loan Agreement by the Borrower. The credit-scoring done by any person does not replace or release the Buyer from carrying out its/their own risk assessments.
    8. The User shall only be able to purchase the offered Claims to the extent of the unreserved amount on the User's Portal Account.
    9. The Seller and the Buyer shall enter into a Resale Agreement in order to purchase the Claims from the Secondary Market through the Portal.
    10. Following the conclusion of the Resale Agreement, the Buyer's Portal Account shall be automatically debited by the Company and the Seller's Portal Account shall be automatically credited by the Company in the amount of the Purchase Price.
    11. Upon the assignment of a Claim, the rights of the Seller to the repayment of the unpaid Loan, which forms a part of the Claim and payment of the payable interest and interest on arrears, including debts related to interest and interest on arrears, shall also be transferred to the Buyer. Following the assignment of a Claim, all the payments made by the Borrower shall be transferred directly to the Buyer, except for the Debt Servicing Costs.
    12. This article 5 does not apply to the GG-Claims, unless otherwise specifically prescribed in the Terms of Use.
  6. Servicing of Claim

    1. The Company (or any person authorized by the Company), the Buyer or the Seller, shall not inform the Borrower concerning the assignment of the Claim in case of concluding an Assignment Agreement or a Resale Agreement. The Company, or any person authorized by the Company (including but not limited to the person from whom the Claim was acquired), shall remain the creditor in relation to the Borrower, unless required otherwise by the Company.
    2. By virtue of entering into GG-Terms, an Assignment Agreement or a Resale Agreement, the Buyer gives an irrevocable authorization to the Company to:
      1. service the Claim and the Loan Agreement of which the Claim arises for the benefit of the Buyer of the Claim in accordance with the Terms of Use. The Loan Agreement shall be serviced in the name of the Company or the person the Company has delegated the servicing of the Loan Agreement to. The servicing shall include:
        • (a) holding all documentation related to the Loan Agreement;
        • (b) communication with the Borrower and authorities;
        • (c) administration of the Loan Agreement's performance, including outstanding amounts;
        • (d) negotiations and litigation with the Borrower;
        • (e) debt collection;
        • (f) reclaiming the Claim in court; and
        • (g) enforcement of court judgments.
      2. enter into agreements to amend the Loan Agreement serving as the basis for the Claim in accordance with the applicable local regulations, consumer credit directives, responsible lending guidelines and market practices (including, but not limited to assigning the Claim to third parties, and reducing the Claim in the amount of Debt Servicing Costs) as well as exercising the right set forth in article 6.2.3. This includes but is not limited to:
        1. assigning the Claim to third party;
        2. reducing the Claim in the amount of Debt Servicing Costs;
        3. determining a new payment schedule, provided that:
          • (a) the payment schedule that has been valid under the Loan Agreement so far is thereby replaced; and
          • (b) the number of instalments to be paid is not over 120.
        4. granting a payment holiday, provided that:
          • (a) in such case, the payment schedule is extended by the period of the payment holiday but all together not over 120 instalments; and
          • (b) during the payment holiday, interest shall be calculated for the respective period of time, unless the law provides otherwise.
      3. assign or sell the Claim to a third party if the amount in debt has not been fully paid by the day of Default by the Borrower, and a new payment schedule has not been agreed with the Borrower. However, prior to application of assignment or sale of the Claim, the Company must take into consideration:
        1. the financial situation of the Borrower;
        2. the amount of the Claim and other circumstances; and
        3. collection expenses of the Claim.
      4. assign the Buyer's Claim to any person authorized by the Company (including, but not limited to the person from whom the Claim was acquired) in case of ongoing indebtedness or incipient court proceedings with the Borrower or if the creditor would have the right to terminate the Loan Agreement under the respective Loan Agreement. The Company has the right to conclude the respective assignment agreement on behalf of the Buyer.
    3. In the event that the Seller has, prior to entry into the Resale Agreement, transferred the Claim to the Company for collection pursuant to the general terms and conditions of the respective Loan Agreement, Assignment Agreement and other agreements, all claims that the Seller acquired against the Company upon transfer of the Claim to the Company shall be transferred to the Buyer instead of the initial Claim upon entry into the Resale Agreement.
    4. The Company shall transfer any funds collected as fulfilment of the Claim from the Borrower to the Buyer's Portal Account, except for any funds collected as fulfilment of the GG-Claim. However, the fees (e.g., contract fee and annual management fee) paid by the Borrower to the initial credit provider (which are not assigned to the User as a part of the Claim) and Debt Servicing Costs shall not be transferred to the Buyer.
    5. All authorizations by the Buyer to the Company set forth herein are with an unlimited right of delegation, i.e., the Company may delegate the authorizations (together with any rights and obligations hereby attached) to any person (including but not limited to persons under the same control as the Company and such delegation shall not be considered to constitute a conflict of interest). All authorizations by the Buyer to the Company set forth herein shall remain in force until the performance of all the obligations related to the Loan Agreement that serves as the basis for the Buyer's Claim. If the Buyer revokes any of the authorizations given by these Terms of Use, the Company may refuse to collect the debt from the Borrower and service the Claim.
    6. Notwithstanding the rights and obligations prescribed in this article (6), the Buyer alone shall bear the responsibility for any risks related or due to the acquisition of the Claim, including risks related to the fulfilment of the Loan Agreement and credit, repayment, and bankruptcy of the Borrower. The Buyer hereby represents that he/she/it understands that even by using the best endeavors neither the Company (nor the third party the Company has delegated the servicing of the Claim to) cannot guarantee or ensure the repayment of money lent under Loan Agreement and fulfillment of the Claim.
  7. User's Data and Exchange of Information

    1. Upon entry into the User Agreement or when expressing an intention to enter into a legal transaction by the mediation of the Portal, the User gives his/her/its consent to the Company to process his/her personal data according to the provisions of these Terms of Use and the Privacy Policy.
    2. The Company is entitled to record all User's data received by means of communication (e.g. postal mail, telephone, email, the Portal, etc.,).
    3. Upon entry into a User Agreement and expression of declarations of intention through the Portal, including signing the Assignment Agreement, the User shall present correct and accurate data. Deliberate submission of false and incomplete information is forbidden and a breach of the User Agreement. Upon entry into the User Agreement, every User certifies that the data submitted by them through the Portal, including data submitted in the Assignment Agreement, is correct.
    4. The contact information provided by the User is deemed to be correct if the User has failed to notify the Company about its changes. The persons representing the User are deemed to be rightful representatives until the User has informed the Company about termination of the right to represent.
    5. All notifications by the User to the Company shall be submitted in writing via the technical solution of the Portal. Failure to provide any notifications deriving from this User Agreement shall constitute a fundamental violation of this User Agreement. The User shall bear the risks of not duly notifying the Company.
    6. The Company's contact details are published at www.bondora.com. The Company shall not notify the User about the change of the Company's contact details unless it is specifically required by law or it is deriving from the User Agreement.
    7. Communication sent to the other party by using correct contact data shall be deemed to have been received by the receiving party: 1) if delivered personally when delivered against the signature; 2) if sent through the Portal, by email, or by other technical devices, three (3) days after being sent; 3) if sent by mail to a destination within the country of dispatch, five (5) days after being deposited by registered mail; and 4) if sent by mail to a destination outside the country of dispatch, seven (7) days after being deposited by registered mail.
  8. Accessing Portal, Identification, and Approval of Transaction

    1. The User must identify himself/herself/itself after registration as the User and before signing the first Assignment Agreement or the verification of the first transaction of purchase and sale of the Claim. If the transaction parameters determine a respective obligation arising from legislation, the person(s) of the respective Users shall be identified again. The User cannot start investing before the identification process is completed.
    2. Legal person User can access the Portal through the individual representative who has been registered as the User on the basis of his/her username and password. If the representative of the legal person User changes or a new representative is added, the new representative can (if an inquiry confirms their right of representation) bind the respective legal person User to his or her personal User. If the legal person User's representative's right of representation has expired, the new representative must notify the Company of the expiration.
    3. The User shall among all verify his/her/its identity by making a bank transfer to the User's Portal Account from a private bank account opened in his/her/its name at a bank operating in the European Economic Area or in Switzerland, or in other countries the Company has specifically approved. The linked private account shall be specified on the User's settings page in the User's Portal Account. For the avoidance of doubt – when the User uses any other alternative payment options for payment (such as credit card, debit card, third party payment options), he/she/it is obligated to make a payment as described in the first sentence of this Section in order to verify his/her/its identity.
    4. Additionally to verifying their/its identity through a bank transfer, the User (or, in case of a legal person User, the representative of the User) is obliged to submit a copy of a valid identity document, issued in the country of residence, such as a passport or national ID card to the Company. The copy has to be in color and, in case of the ID card, double-sided. All the User's information received through the identification process, such as given names, surname, business name, personal ID code, registration code, bank account number, residential address etc., will be collected at the end of the registration process and stored.
    5. The Company is entitled to request an overview of the User, the persons related to them (including the ultimate beneficiary and cooperation partners), and also the activities (including economic activities) and the origin of the assets of the User ("Know Your Customer" principle). The Company can restrict the User's access to the Portal or cancel it, and/or refuse to conclude the Assignment Agreement before the User has submitted the requested documents and/or information to the Company.
    6. The Company is entitled to return the money to the User if the User has not identified himself/herself/itself in accordance with article 8.1.
    7. If the User has identified him/her/itself in accordance with article 8.1 but has not invested the transferred money to any of the Company's products and/or services, the Company is entitled to automatically add the money to the User's GG-Account after 30 days from receiving the transfer.
    8. If the User's or Buyer's personal identification has not been completed in accordance with article 8.1, the identification must be completed before a withdrawal has been made from the User's Portal Account.
    9. The Company shall not be limited by articles 8.3, 8.4 and 8.5 when identifying a User and shall have the right to alter the process of User identification and use any other means for identification of a User as the Company sees fit at any time.
    10. When logging into the Portal, the User has to enter their username and password. Any person logging into the Portal with the User's tools required for logging in are deemed to be rightful representatives of the User unless the User has informed the Company duly according to article 2.1.4.2.
    11. If additional identification is not required by legislation, entering into the User Agreement, the Assignment Agreement or the Resale Agreement can be executed merely by approving it in one of the manners presented below at the discretion of the User:
      1. approval with the Portal's password;
      2. mobile approval (for this purpose, the User shall have to disclose their mobile phone number to which a new PIN shall be sent every time; the PIN shall have to be entered in the system to certify the declaration of intention);
      3. approval by any other means that are considered to be sufficient by the Company and are thus in accordance with the legislation.
    12. The Company may ask the User to undergo the identification process again and/or submit additional documents related to identification, complying with "Know Your Customer" principle or funds used in the transaction if
      1. there are grounds for suspecting the validity of the identification of the User;
      2. the documents and/or information provided by the User are not sufficient;
      3. the Company has other suspicions regarding the provided documents and/or information of the User.
    13. Refusal to identify or provide requested documents and/or information specified in this User Agreement to the Company by the User shall constitute a fundamental violation of this User Agreement.
  9. Fees

    1. The Company shall have a right to receive, and the User shall be obliged to pay fees for the rendered services pursuant to the Price List, User Agreement or other agreements he/she/it has concluded with the Company.
  10. The Bankruptcy of the Company

    1. In the event of bankruptcy of the Company, entry into new Assignment Agreements and Resale Agreements, as well as acquisition of the GG-Claims, shall be terminated immediately. The money held on the User's Portal Account shall be returned to the User.
    2. The User shall be given all the information on the Portal's database regarding the Claims it owns. Irrespective of the GG-Terms, in the event of bankruptcy of the Company, the User shall be given all the information on the Portal's database also regarding the GG-Claims the User owns.
    3. Bankruptcy of the Company shall not affect the validity of the Loan Agreements, the Assignment Agreements, or the Resale Agreements. However, the GG-Price shall become immediately payable upon the bankruptcy of the Company.
    4. In the event of bankruptcy, the Company will take reasonable steps to enter into an arrangement with another firm to transfer the management and administration of the Loan Agreements between the Users. After a suitable firm has been chosen, the Company will notify the Buyers of the identity of the firm with which the arrangements have been made and how that firm will continue to administrate the Portal, including the Assignment Agreements, the Resale Agreements, and the Portal Accounts.
  11. Liability

    1. The User who has submitted false information shall be liable for the damage caused to the Company and other Users by such submission of false information, above all if the Company or other Users have concluded a transaction with the User who submitted false information by assuming the accuracy of the submitted false information.
    2. The User is liable for the damage and loss arising from the fact that third parties have gained possession of the data and tools specified in article 2.1.3 and the User is aware of the fact and accepts that third parties, misusing the data, may assume legally binding obligations for the User and the User is obligated to perform them.
    3. The User is liable for using correct payment details (including reference number) when making payments to the Current Account of Portal. The Company is not liable for any potential damage and loss arising from the fact that the User has used incorrect payment details. The User shall inform the Company immediately, if the made payment has not reached his/her/its Portal Account, as well as when the User receives wrong payment to his/her/its Portal Account. The User is not entitled to use the amounts on his/her/its Portal Account, that can be subject to the disputes or return claims of other persons (e.g., in case of wrong payments).
    4. The Company shall in no manner be liable for the accuracy and correctness of the information submitted to it by the User or any other person (including but not limited to the person from whom the Claim was acquired).
    5. The Company shall not be liable for:
      1. the truthfulness of the data given by the User;
      2. a breach of the Agreement or unlawful behavior by the User;
      3. the performance of the Borrower's duties and obligations under the Loan Agreement, including, but not limited to delay in payment under the Loan Agreement;
      4. the performance of obligations arising from the GG-Terms, the Assignment Agreements or the Resale Agreements by the Users or any other acts or omissions of the Users;
      5. the existence of the right of representation of the representative of the User who is a legal entity;
    6. The Company is entitled to restrict access to the Portal for the duration of maintenance and repairs of the Portal. The Company is not responsible for possible damages caused by the interruption of Portal services.
    7. The User is liable for the lawfulness of the transactions made through the Portal.
    8. The User shall enter into transactions in the Portal directly and at his/her/its own liability, being a party to the transactions themselves; the agreement templates suggested in the Portal can be used by the User at his/her/its own liability and risk. The Company is not liable for possible obligations that may arise for the User according to the law as a result of concluding or executing the GG-Terms, the Assignment Agreement, the Resale Agreement, or using the Portal.
    9. Nothing in these Terms of Use limits the liability in case of a willful breach of obligations.
    10. Neither party is responsible for any failure to perform its obligations under this User Agreement, if it is prevented or delayed in performing those obligations by an event of force majeure.
  12. Amendment of Terms and the Price List

    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 Terms of Use.
    2. The Users shall be informed of amendment of the Terms of Use via the Portal. Amendments and modifications shall enter into force within four weeks as of the disclosure of the notification in the Portal or when the User accepts the Terms of Use by clicking the respective box when the User logs in to the Portal, whichever occurs earlier.
    3. The Company is entitled to amend the price list at its discretion. The Company notifies the Users about the amendments in the Price List through the Portal at least four weeks in advance. The Company shall not notify the Users in advance if the Price List is becoming more favourable for the User (e.g. decreasing of price).
    4. Upon disagreement with the amendments and modifications in the Terms of Use or in the Price List, the User has the right to terminate the User Agreement within four weeks as of the notification of the amendment via the Portal.
    5. The term of advanced notice specified in article 12.2 is not applied and the User is notified about the amendments through the Portal, if
      1. the applicable legislation or standards regulating the relations arising from the Terms of Use change and amendment of the Terms of Use is required to comply with the new legislation and/or standards;
      2. the amendments of the Terms of Use do not change the rights and obligations of the Parties (e.g. grammatical adjustments or improvements).
  13. Termination of User Agreement

    1. The User may terminate the User Agreement only if the duties and obligations towards other Users and the Company, which arise from the agreements signed via the Portal, have been fulfilled, and the GG-Terms, the Assignment Agreements and Resale Agreements signed by the User via the Portal have ended (as a result of due performance) and the User's account balance is zero. This article 13.1 also applies in case the User uses his/her/its rights deriving from article 12.4.
    2. The User Agreement can be terminated by the User by way of sending a respective notice to the Company through the Portal.
    3. The User has the right to withdraw from the User Agreement within 14 days as of the entry into the agreement, provided that the terms and conditions set out in article 13.1 have been fulfilled.
    4. The Company may terminate the User Agreement at any time with or without giving the User advance notice if the User violates the terms and conditions of the User Agreement or if the User who is a natural person withdraws its consent for processing its personal data partially or fully or uses any other right set forth in the Privacy Policy.
    5. The Company may terminate the User Agreement (including disabling or restricting the User's access to the Portal) without providing advance notice if the User has used or is using without the Company's written consent any automated means (which access means are not provided by the Company) to access the Portal and collect any data from the Portal through automated means (included but not limited to harvesting bots, robots, spiders, scrapers or other automatic devices or programs) or if the User is using framing techniques to enclose any of the data or content to the Portal or otherwise affect the Portal.
  14. Final Provisions

    1. Upon registration of the User by the Company as a user of the Portal, the User Agreement (which shall include these Terms of Use) between the Company and the User shall be considered as concluded.
    2. The income earned from using the Portal shall be declared and taxed pursuant to the legislation of the country of residence or country of location of the Buyer. The Company is not responsible for providing tax advice or for declaring the income.
    3. These Terms of Use are applicable to all User Agreements concluded with the Company and to all other legal transactions and agreements concluded between the Users and between Users and the Company when using the Portal.
    4. The Portal, Portal's website and the copyright of the contents thereof belong to the Company. The User does not have the right to save, copy, change, transfer, forward or disclose the pages of the Portal for a purpose other than personal use.
    5. The legislation of the Republic of Estonia taking account of applicable compulsory provisions arising from European Union law and the legislation of other Member States, shall govern the legal relationships arising from the use of the Portal.
    6. The Users and the Company shall resolve their conflicts by way of negotiations. Failing agreement, the dispute regarding this User Agreement shall be resolved in the User's competent court in case the User is a natural person. If the User is a legal person or in case the dispute relates to any other agreement concluded between the User and the Company besides this User Agreement, the dispute shall be resolved in the Harju County Court in the Republic of Estonia.
    7. The Terms of Use shall apply upon their acceptance by the User and shall be applicable during the term of the legal relationships between the User and the Company regulated in the User Agreement.
    8. This agreement has been drawn up in English.
    9. These Terms of Use were last updated as at February 8, 2021.

Bondora.com Privacy Policy

This Privacy Policy provides an overview of what personal data of the bondora.com Portal User (hereinafter also You) the company (hereinafter Bondora or us) processes when providing services via the Portal, how and for which purposes it does this, and what Your rights are regarding Your personal data. As personal data means any information relating to an identified or identifiable natural person, this Privacy Policy applies exclusively to Users who are natural persons and not to Users who are legal entities.

We follow very strict rules established for the processing of Your personal data, which derive from the European Union and Estonian legislation on the protection of personal data, including the European Union General Data Protection Regulation (hereinafter General Regulation). The terms contained in this Privacy Policy have the same meaning as described in the Bondora.com Terms of Use and General Regulation.

Controller and Contact Details

The controller of Your personal data is Bondora Capital OÜ (Estonian registry code 12831506; postal address A. H. Tammsaare tee 47, Tallinn 11316, Estonia). You can find the form required to contact us here.

Collection of Personal Data

We generally collect personal data necessary to enter into an Agreement with You and perform it. Given our field of activity, it also includes collecting various background information to fulfill our various statutory obligations.

We collect personal data from the following sources:

  • Yourself (e.g., data submitted and shared by You); and
  • third parties (e.g., public sources, cooperation partners (for identification purposes), and companies belonging to the same group as us).

We collect personal data from third parties that allow us to apply due diligence measures to prevent money laundering and terrorism financing.

We may also collect personal data automatically (e.g., the way You use the Platform, digital devices You use, and cookies) for statistical purposes.

Use of Your Personal Data

To provide services to You through the Platform, You may be required to provide our partners or us with the information necessary to provide the services. If You do not provide this information, we are not able to provide services to You. Such information is always marked accordingly.

We use Your personal data for the following purposes and on the following legal bases:

Personal Data
Purposes of Processing
Legal Basis
  • Data that allows us to identify You (e.g., name, personal identification code, date of birth, identity card data)
  • Contact details (e.g., email address, mobile phone number, postal address)
  • Financial data (e.g., current bank account number)
  • Your user account information (e.g., email address or other social media account information if preferred)
  • Data that allows us to verify Your reliability (e.g., the origin of assets, area of activity, whether named in the lists of PEPs or sanctioned persons, etc.)
  • Information about Your identity document (incl. copy of identity document, document number)
  • Other information (e.g., the language of communication)
  • Conclusion of the Agreement (incl. identification, and verification of Your reliability)
  • Preparation for the conclusion of the Agreement (point (b) of Article 6(1) of General Regulation)
  • Our legitimate interest in ensuring Your reliability, incl. for excluding involvement in money laundering or terrorism financing (point (f) of Article 6(1) of General Regulation)
  • We will only process Your personal data if we are satisfied that our legitimate interests do not outweigh Your interests or fundamental rights and freedoms for which personal data must be protected. As the sources and types of personal data are known to You and as it is objectively important in our area of activity to ensure the reliability of our contractual partners, we consider it justified.
  • Data that allows us to identify You (e.g., name, personal identification code, date of birth, identity card data)
  • Contact details (e.g., email address, mobile phone number, postal address)
  • Financial data (e.g., current bank account number)
  • Data of transactions made on the Platform (e.g., services used on the Platform, concluded agreements, the fulfillment of obligations, communication)
  • Other information (e.g., the language of communication)
  • Conclusion and performance of the Agreement (incl. contacting You in connection with the Agreement)
  • Conclusion and performance of the Agreement (point (b) of Article 6(1) of General Regulation)
  • Contact details (e.g., email address, mobile phone number, postal address)
  • Sending direct marketing
  • Your consent (point (a) of Article 6(1) of General Regulation)
  • Contact details (email address)
  • Information on the performance of the Agreement
  • Sending of surveys for feedback to develop and improve the quality of our Platform and services
  • Our legitimate interest in ensuring the quality, development, and competitiveness of our Platform and services (point (f) of Article 6(1) of General Regulation)
  • We will only process Your personal data if we are satisfied that our legitimate interests do not outweigh Your interests or fundamental rights and freedoms for which personal data must be protected. As such processing takes place with personal data that is not particularly sensitive, and as we use this data for foreseeable purposes, we consider it justified.
  • Feedback
  • Development and improvement of the quality of our Platform and services
  • Your consent (point (a) of Article 6(1) of General Regulation)
  • Data on transactions made on the Platform and browsing data (e.g., services used on the Platform, agreements concluded, the fulfillment of obligations, IP-address, type of browser, preferences, habits, satisfaction, investment objectives, inflows, communication, data on participation in consumer games, and campaigns organized by the company)
  • Developing and improving the quality of our Platform and services (e.g., analyzing how and with which devices Users typically navigate our Platform to make it more user-friendly; analyzing which products and services are popular to develop these as a priority; and analyzing the profile of the Users that do not perform their responsibilities to improve our systems, etc.)
  • Our legitimate interest in ensuring the quality, development, and competitiveness of our Platform and services (point (f) of Article 6(1) of General Regulation)
  • We will only process Your personal data if we are satisfied that our legitimate interests do not outweigh Your interests or fundamental rights and freedoms for which personal data must be protected. As such processing takes place with personal data that is not particularly sensitive, and as we use this on an aggregate basis, i.e., not in relation to You individually, we consider it justified.
  • All Your relevant personal data
  • Fulfillment of our statutory obligations
  • Fulfillment of our statutory obligations (point (c) of Article 6(1) of General Regulation)
  • All Your relevant personal data
  • Protecting our rights and interests (e.g., if You do not fulfill the Agreement or there appears such suspicion)
  • Our legitimate interest in protecting our rights and interests (point (f) of Article 6(1) of General Regulation)
  • We will only process Your personal data if we are satisfied that our legitimate interests do not outweigh Your interests or fundamental rights and freedoms for which personal data must be protected. As we generally process Your personal data only when it is essential to protect our rights and interests (i.e., if there has been a breach or a suspected breach by You), we consider it justified.

We do not process any special categories of Your personal data or data about criminal convictions and offenses.

We may also process Your personal data for other purposes with Your consent. The purpose of the processing and other details, in this case, are described in the consent.

If the legal basis for the processing of Your personal data is our or a third party's legitimate interest, You have the right to obtain additional information and to object to such processing at any time. To do so, please contact us using the contact details mentioned above.

Transfer of Personal Data

When we process Your personal data, we also transfer Your personal data to our processors or third parties. Such transmission shall take place only under the following conditions:

Processors. We use carefully selected service providers (processors) to process Your personal data. In doing so, we remain fully responsible for processing Your personal data.

We use the following processors: marketing and survey service providers and tools, money laundering and terrorism financing risk mitigation searching service providers, identification service providers, customer support service providers, accounting service providers, server management and server hosting providers, IT service providers, and other companies belonging to the same group as us, who provide services to us.

If You would like more detailed information about our processors (e.g., their names and locations), please contact us using the contact details mentioned above.

Third Parties. We will only share Your personal data with third parties if set out in this Privacy Policy if required by applicable law (e.g., if we are required to share personal data with authorities) or under Your consent or order.

We may share Your personal data with the following third parties:

  • to make transactions selected by You via the Portal, with other Users. In this case, the legal basis for the transfer of personal data is the conclusion or performance of the Agreement (point (b) of Article 6(1) of General Regulation);
  • to perform the Agreement, with payment service providers. In this case, the legal basis for the transfer of personal data is the performance of the Agreement between us (point (b) of Article 6(1) of General Regulation);
  • for the purposes of our internal administration, with companies belonging to the same group as us. In this case, the legal basis for the transfer of personal data is our legitimate interest in sharing the data with companies belonging to the same group as us for internal administration purposes (point (f) of Article 6(1) of General Regulation);
  • for the purposes of direct marketing, with companies belonging to the same group as us. In this case, the legal basis for the transfer of personal data is Your consent (point (a) of Article 6(1) of General Regulation);
  • to fulfill our statutory obligations, with authorities and law enforcement agencies. In this case, the legal basis for the transfer of personal data is fulfilling our statutory obligations (point (c) of Article 6(1) of General Regulation);
  • to protect our rights and interests, with collection agencies, attorneys, bailiffs, and other persons concerned. In this case, the legal basis for the transfer of personal data is our legitimate interest in protecting our rights and interests (point (f) of Article 6(1) of General Regulation). We will only transfer Your personal data if we are sure that our legitimate interests do not outweigh Your interests or fundamental rights and freedoms for which personal data must be protected. As we generally transfer Your personal data only when it is essential to protect our rights and interests (i.e., if there has been a breach or a suspected breach by You), we consider it justified.
  • to fulfill our statutory obligations, with auditors. In this case, the legal basis for the transfer of personal data is fulfillment of our statutory obligations (point (c) of Article 6(1) of General Regulation and the Auditors Activities Act);
  • to fulfill our statutory obligations or in the legitimate interests of us or our counterparty, if such transfer is necessary to transfer our activities or assets due to a transaction, or to assess the potential of such a transaction. In this case, the legal basis for the transfer of personal data is the fulfillment of our statutory obligations (point (c) of Article 6(1) of General Regulation and the Law of Obligations Act), or the legitimate interest of us or our counterparty in concluding the transaction or assessing its potential (point (f) of Article 6(1) of General Regulation). We will only transfer Your personal data if we are sure that our or our counterparty's legitimate interests do not outweigh Your interests or fundamental rights and freedoms for which personal data must be protected.

If the legal basis for the processing of Your personal data is our or a third party's legitimate interest, You have the right to obtain additional information and to object to such processing at any time. To do so, please contact us using the contact details mentioned above.

Transfer of Personal Data outside the European Union

In general, we do not transfer Your personal data outside the European Union, but our processors and third parties to whom we transfer the personal data may process Your personal data outside the European Union. Where necessary, the transfer will only take place if we have a legal basis for such action, including, in particular, if the recipient: (i) is located in a country that the European Commission considers having an adequate level of protection of personal data, or (ii) is acting under an agreement that meets the requirements of the European Union for the transfer of personal data to processors outside the European Union.

If You would like more detailed information about the transfer of Your personal data outside the European Union (e.g., the recipients' names and the legal basis for the transfer), please contact us using the contact details mentioned above.

Retention of Personal Data

We retain Your personal data for as long as we are required by law to do so (e.g., under the Accounting Act we must retain accounting source documents for seven years from the end of the respective financial year) or until we have a legitimate interest in doing so (e.g., until the end of the limitation period of claims to protect our interests and rights if necessary).

Generally, we retain personal data for up to 10 years after the client relationship between us has ended.

If no client relationship is created between us, we retain Your personal data to a limited extent for up to 10 years from the collection of the personal data.

Security of Personal Data

We ensure that Users' personal data is only available to such employees who, due to their duties, need to have access to such data. All Bondora employees are required to maintain the confidentiality of the data and may not share the information with third parties, except for the purposes set forth above.

Personal data is stored and archived on a secure server that only a few people have access to. Security is guaranteed by strict privacy standards met by conscientious third-party partners.

We use several Internet security measures to ensure the secure processing, transmission, and archiving of personal data.

The servers are located in a data center in Frankfurt, Germany, and are operated by Telehouse, one of the world's 200 leading companies. A separate agreement has been concluded with Virtion GmbH for server management. These companies allow us to offer better availability and growth potential of our IT resources and greater flexibility.

All their activities comply with a number of standards, including ISO 27001:2005 (Information security management), BS25999-2:2007 (Business continuity management), PCI-DSS (Payment card industry), ISO 9001:2008 quality standards, and ISO 14001:2004 (Environmental management system standard).

The companies have established round-the-clock physical and virtual surveillance of the system. All movements in the data center are monitored by short-range card readers and infrared sensors that detect unauthorized persons. In Bondora, security breaches are detected, monitored, and repelled by software and hardware security walls.

Your Rights

You have all the rights of the data subject with regard to Your personal data to the extent required by the applicable data protection legislation, including:

  • the right to receive relevant information on the processing of personal data;
  • the right to receive a confirmation of whether personal data is being processed;
  • the right to receive a copy of personal data;
  • the right to request that we rectify inaccurate personal data or supplement incomplete personal data;
  • the right to request deletion of personal data if: (i) the personal data is no longer necessary for the purpose for which it was collected or otherwise processed; (ii) You withdraw Your consent for processing Your personal data, and there is no other legal basis for processing the personal data; (iii) You object to the processing of personal data, and there are no overriding legitimate reasons for the processing; (iv) You object to the processing of Your personal data for direct marketing purposes; (v) personal data has been processed unlawfully; or (vi) personal data must be deleted to fulfill our statutory obligation. Notwithstanding the above, You do not have the right to request the deletion of personal data if the processing is necessary: (a) for the fulfillment of our statutory obligation; or (b) for the establishment, exercise or defense of legal claims;
  • the right to request a restriction on the processing of personal data if: (i) You challenge the accuracy of the personal data for a period of time that allows us to verify the accuracy of the personal data; (ii) the processing of personal data is unlawful, whereas You do not request the deletion of personal data, but the restriction of use; (iii) we no longer need personal data for processing purposes, but the data is necessary for You for the establishment, exercise or defense of legal claims; or (iv) You have objected to the processing of Your personal data, while we check whether our legitimate reasons outweigh Your reasons. If the processing of personal data is restricted, we may nevertheless process it: (a) with Your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest;
  • the right to portability of data, i.e., the right to receive personal data that You have provided to us in a structured, commonly used and machine-readable format, and the right to transmit this data to another controller if: (i) the processing is with Your consent or for the purposes of conclusion or performance of the Agreement; and (ii) processed automatically. If technically feasible, You have the right to request that we transmit the data directly to another controller. In exercising Your right, we cannot infringe on the rights and freedoms of others;
  • the right to object, depending on Your particular situation, at any time to the processing of personal data in the legitimate interest of us or a third party. In this case, we will not further process personal data unless we prove that the processing is for a valid legitimate reason that outweighs Your interests, rights, and freedoms, or for the establishment, exercise or defense of legal claims. If Your objection concerns the processing of Your personal data for the purposes of direct marketing, we do not have the right to process Your personal data further;
  • the right to withdraw consent at any time. To do so, You may contact us using the contact details mentioned above or use other options described in obtaining Your consent.

To exercise Your rights, please contact us using the contact details mentioned above. We will respond to Your request within one month at the latest. In some instances (taking into account the complexity and number of the requests), we have the right to extend the due date for replying by two months. In this case, we will notify You.

If You believe that Your rights have been violated, please contact us immediately to resolve the situation. However, You have the right to complain to the Member State's supervisory authority where You have Your permanent residence or place of work, or to the Data Protection Inspectorate (www.aki.ee; [email protected]; Tatari 39, 10134 Tallinn, Estonia).

Cookies

We use cookies, which are small text files that a website server stores on Your hard drive. This allows us to collect certain information from Your web browser. You can find further information in our cookie policy.

Links to Third-Party Websites

Links to third-party websites from the Platform or any other Bondora website, or vice versa, are only quick links to services or topics useful to our Platform Users. Please note that third-party websites may have different privacy policies and/or security standards, which we recommend You review.

Amendments to the Privacy Policy

Suppose our personal data processing practices are changed, or we need to amend this Privacy Policy due to applicable law, judicial or competent supervisory authorities' practices, or competent supervisory authorities' guidelines, we have the right to change this Privacy Policy at any time unilaterally. In this case, we will notify You via the Portal or email at a reasonable time before the changes take effect.

Applicable Law

As Bondora is a company registered in the Republic of Estonia, Estonian law applies to the processing of Your personal data.

This Privacy Policy was last updated as at February 8, 2021.

What is a Cookie?

A cookie is a small morsel of text that a website asks your browser to store. All cookies have expiration dates in them that determine how long they stay in your browser. Cookies can be removed in two ways: automatically, when they expire, or when you manually delete them. We've included more details below to help you understand what kinds of cookies we use.

Please remember that by deleting existing cookies or disabling future cookies you may not be able to access certain areas or features of our website.

What Cookies Does the Company Use?

We use cookies across our website to improve the performance and enhance the user experience. Please be advised that when you visit our website you agree that we use the following cookies:

Essential cookies that are only set or retrieved by the website while you are visiting which allow us to identify you as a subscriber and ensure that you can access the subscription only pages. We can ensure that no one is making changes to your profile, acquiring or selling the Claims on your behalf.

Functionality cookies are used to allow us to remember your preferences on the website, such as language or username to customize your user experience.

Performance cookies allow us to collect information how you use the website. All of the information collected is anonymous and is only used to help us improve the way our website works and measure the effectiveness of our advertising campaigns.

Third party cookies are behaviourally targeted advertising cookies (e.g. Google Analytics) that allow us to record pages that are visited and the links that are followed. The information collected in non-identified.

Secure cookies are used to ensure that any data in the cookie will be encrypted as it passes between the website and the browser. It helps us to protect the security of your account.

How to Change Cookies' Settings?

In case you want to change your preferences about the cookies that we use, please change your browser settings. For more information you may wish to visit http://www.aboutcookies.org/

Procedure for processing complaints

We want you to be happy with the services Bondora provides. However, if this is not the case and you are dissatisfied with the service requested by or provided to you, or its terms and conditions or quality, we want to know about it. In order to process your complaint as quickly and efficiently as possible, please read this procedure before filing a complaint.

How do I file a complaint?

Bondora’s customer support is fully digital. This means we can handle and solve complaints quickly and securely online. You can file a complaint via the feedback form on our FAQ page.

What information should I include in the complaint?

Please provide all the relevant information so we can review your complaint as quickly and efficiently as possible. Describe and specify the problem as clearly as you can. Also state the claim or request that you want Bondora to solve.

Please include any relevant documents in your complaint if they are not easily available to Bondora.

If your representative is filing a complaint on your behalf, please attach a document that proves their rights of representation. This can be a power of attorney letter, or another relevant document(s).

How will Bondora process the complaint?

Bondora treats all customers with respect and without prejudice. We will determine the specific circumstances regarding your complaint and determine the root cause of the problem. If necessary, we may ask you for additional information or documents to help our process.

If the complaint is valid, we will immediately do what we can to fix the problem or offer another solution. If, however, we do not agree with your complaint (either partially or entirely), we will explain our reasons when we reply to you.

When can I expect a reply?

Once we receive your complaint, you will receive an automated email notification (Usually within one business day).

Normally, we settle complaints within five business days after receiving it, but it may take up to 15 days. If we can't settle your complaint within 15 days, we will inform you why it's taking longer and set a new date for when you can expect a reply.

What should I do if I’m not happy with the solution you provided?

We will do our best to give a solution that you are happy with. However, if you are unhappy with our suggestion, answers, or explanations, you can appeal the decision by contacting us again.

If you are still dissatisfied with the solution we offered, you are entitled to turn to following authorities to protect your rights:

  • Consumer Protection and Technical Regulatory Authority (complaints related to the User Agreement, https://www.ttja.ee/en; located at: Endla 10a, 10142 Tallinn, Estonia; email: [email protected]; phone: 620 1707);
  • Court (according to the jurisdiction specified in the User Agreement or other agreements concluded with Bondora);
  • Consumer Complaint Committee (complaints related to the User Agreement, www.komisjon.ee; located at Endla 10a, 10142 Tallinn, Estonia; email: [email protected]; phone: 620 1707). Since the User Agreement is concluded via electronic means, it is also possible to seek an out-of-court settlement by submitting the complaint online via the ODR platform at ec.europa.eu/odr;
  • Data Protection Inspectorate (personal data related complaints, www.aki.ee; located at Tatari 39, 10134 Tallinn, Estonia; email [email protected]; phone: 627 4135).

Conflicts Policy

Introduction

Any conflicts of interest, which may arise in relation to the Company, shall be identified and managed by the Company. We will maintain and manage all arrangements necessary to prevent a conflict from escalating to causing material damage to the interests of our Users. The given document states our conflicts of interest policy (herein further referred to as "Conflicts Policy") in as much as it applies to our activities.

We are fully committed to complying with our regulatory and legal obligations and maintaining ethical standards. We require that all of our employees are contractually bound to comply with our Conflicts Policy, and any breach of such may lead to disciplinary proceedings, not excluding discharge of services.

Potential or Actual Conflicts Indication

A conflict of interest may take place if any of the Company directors, employees, outsource partners or otherwise "relevant persons" linked to the Company by control is providing a service to the Users or engaging in activities on their own account, which may cause a material risk or damage to the Users; interests, for example where any of the mentioned above-mentioned persons:

  • could either make a financial gain or avoid a financial loss, on account of a User;
  • has an interest in the outcome of a rendered service, which is different from the interest of a User;
  • is incentivized to offer the privilege to one of the Company's clients on account of another User;
  • receives an incentive in any form (financial/goods/services) other than the standard commission fee, from a person other than the User, for a service rendered to a User.

Potential or Actual Conflicts of Interest We Have Identified

We may make payments to third parties for referring the Users to us; however an appropriate disclosure shall be made for such instances.

We may also offer preferred access to the Portal and additional non-standard advisory services to institutional investors.

Employees

A conflict of interest may occur if the Company's employee (or the employee's family) is somehow associated with the other party of any given transaction, especially if such a party is a User. This association may include being a director, a significant shareholder or a consultant to any User. The Company's employees are required to disclose any connection, which could compromise their judgment, or involve any material interests.

Managing Conflicts of Interest and Disclosure

The Company will take all possible and reasonable efforts to mediate any conflict of interest.

Should there be a considerable risk of damage to any User, we will issue an appropriate disclosure.

We will carry out all necessary procedures, including employee training, to ensure that circumstances at which conflict of interest may arise are identified and properly managed.

All conflicts, which may arise, shall be closely monitored.

Further Information

The given document shall be reviewed and updated, as necessary. In case of any questions in regards to this policy, please contact us via the Portal.

Capitalized terms bear the meaning outlined in the Terms of Use, unless defined otherwise.

Noklikšķinot "Reģistrēties", jūs piekrītat mūsu Lietošanas noteikumiem.
Noklikšķinot "Pieteikties", jūs piekrītat mūsu Lietošanas noteikumiem.