Terms of Service

§ 1 Scope and Provider

(1) These Terms of Service (hereinafter "Terms") govern the use of the mobile application "Copreo" (hereinafter "App") including all associated services (hereinafter collectively the "Service").

(2) The Service is provided by: SpuhlerLabs UG (haftungsbeschränkt), Rambacher Straße 79, 65193 Wiesbaden, Germany. Commercial register: Local Court (Amtsgericht) Wiesbaden, HRB 36825. Managing director: Tom Spuhler. E-mail: [email protected] (hereinafter the "Provider").

(3) The Service is directed exclusively at consumers within the meaning of Section 13 of the German Civil Code (BGB) who are resident in Germany and have reached the age of 18.

(4) Deviating terms of the user shall not apply, even if the Provider does not expressly object to them.

§ 2 Description of the Service

(1) Copreo is an application for personal finance management. In particular, the App enables connecting payment accounts, savings accounts, credit cards and securities accounts held with participating banks; an aggregated view of account balances, transactions and portfolio holdings; automatic and manual categorisation of transactions; budget management and spending analyses; detection of recurring payments and subscriptions; and notifications and summaries (recaps).

(2) Account access is not performed by the Provider itself but through BANKSapi Technology GmbH (hereinafter "BANKSapi"), an account information service registered with the German Federal Financial Supervisory Authority (BaFin) within the meaning of Section 1 (1) sentence 2 no. 8 of the German Payment Services Supervision Act (ZAG). The Provider itself does not provide payment services within the meaning of the ZAG and does not conduct banking business within the meaning of the German Banking Act (KWG).

(3) The Service is solely an information and organisation tool. The Provider does not provide investment advice, financial advice, tax advice or legal advice. All analyses, categorisations, forecasts and notices displayed in the App are non-binding, automatically generated information and do not constitute a recommendation to acquire or dispose of financial instruments or to make any other financial decisions.

(4) No payments can be initiated through the App. The App is purely an account information service client.

§ 3 Registration and User Account

(1) Use of the Service requires registration of a user account. Registration is performed with name, e-mail address and password or via "Sign in with Apple" or "Sign in with Google"; when signing in via Apple or Google, first and last name are also requested in the App. All information provided must be truthful and complete.

(2) The contract for the use of the Service is concluded upon completion of registration and confirmation of the e-mail address.

(3) Login credentials must be kept secret. The user must inform the Provider without undue delay if there are indications of misuse of the user account. A user account is not transferable.

(4) The user may additionally set up an app lock code (PIN) and biometric unlocking (Face ID / Touch ID / fingerprint). These features do not replace the user's duty of care in handling their own device.

§ 4 Bank Connection via BANKSapi

(1) To connect a bank account, the user is redirected to an environment provided by BANKSapi. There, the user enters their online banking credentials and authorises account access in accordance with the requirements of their account-holding bank — as a rule via PSD2 interfaces using strong customer authentication; for individual banks, access is performed via other access channels operated by BANKSapi (e.g. online banking interfaces).

(2) The user's online banking credentials are used vis-à-vis BANKSapi and the account-holding bank. In accordance with regulatory requirements, the user's consent to account access is limited in time and must be renewed periodically. The App indicates expiring consents.

(3) The user warrants to connect only accounts over which they have power of disposal.

(4) The availability of individual banks and account types depends on the banks' interfaces and the scope of services provided by BANKSapi. There is no entitlement to the connectability of any particular bank. Individual banks (e.g. American Express Germany) do not provide an interface usable by account information services and therefore cannot be connected, or only to a limited extent.

§ 5 Data Quality; No Warranty for Accuracy and Completeness of Account Data

(1) All account, transaction, balance and portfolio data displayed in the App is retrieved via BANKSapi from the account-holding banks or their interfaces and is displayed in the App exactly as transmitted.

(2) Neither BANKSapi nor the Provider verifies the data transmitted by the banks for accuracy, completeness or currency. The Provider therefore gives no warranty that the balances, transactions, portfolio values and other account data displayed in the App are accurate, complete or up to date. Discrepancies may arise in particular from delays or errors in data provision by the account-holding bank or its interface, time-delayed synchronisation (displayed data reflects the state of the last successful retrieval), transactions that are pending or not yet booked, technical disruptions at BANKSapi, at the bank or at the Provider, and price data of portfolio holdings that is not available in real time.

(3) The records and account statements of the respective account-holding bank are solely authoritative for the actual account and portfolio balance. Before making financial decisions, in particular before dispositions that require sufficient account coverage, the user must verify the authoritative account balance with the account-holding bank.

(4) Automatically generated categorisations, merchant assignments, budget analyses and the detection of recurring payments are based on algorithmic methods and may be erroneous. They are not suitable for tax, accounting or other legally relevant purposes and do not replace receipts or account statements.

§ 6 Prices, Subscription and Payment Processing

(1) Certain features of the Service can only be used under a paid subscription. Price, term and scope of services are displayed in the App or in the respective app store before the subscription is concluded. The current price is EUR 2.99 per month including statutory value added tax.

(2) Subscriptions are purchased exclusively via the Apple App Store or Google Play. Billing, payment processing, cancellation of the subscription and the exercise of any right of withdrawal are additionally governed by the terms of the respective store operator. Management and cancellation of the subscription are performed via the subscription management of the respective store.

(3) The subscription renews automatically for the booked term unless it is cancelled via the respective store before the end of the current period.

(4) After a subscription expires without renewal, the user account is placed in a read-only mode for a transitional period of 90 days; thereafter, access to the content is locked until a new subscription is concluded or the user deletes their account. The user's statutory rights, in particular to access and data portability, remain unaffected.

(5) The Provider grants new users a free trial month with the full range of features after registration. No payment method needs to be provided for the trial month; it does not automatically convert into a paid subscription. After the trial month expires, continued use of the features requires the conclusion of a subscription (para. 7).

(6) The Provider may offer temporary free trial campaigns (e.g. a test phase at market launch). Participation requirements, scope and termination of such campaigns are governed by separate terms of participation provided upon sign-up for the respective campaign. There is no entitlement to participation in, or continuation of, a trial campaign. Trial campaigns do not automatically convert into a paid subscription.

(7) If a trial month or a trial campaign under para. 6 ends without a subscription being concluded, access to the content and analyses is locked. The user's data remains stored; the user may at any time delete their account including all data (§ 12) or restore full access by concluding a subscription.

§ 7 Right of Withdrawal for Consumers

(1) Consumers have a statutory right of withdrawal for distance contracts in accordance with the following instructions on withdrawal. These apply to contracts concluded by the user directly with the Provider (registration/user agreement and subscriptions, insofar as the Provider is the contracting party).

(2) When purchasing subscriptions via the Apple App Store, Apple Distribution International Ltd. is, under the store's terms of use, the contracting party for the purchase transaction; refunds in this respect are governed by Apple's refund process (reportaproblem.apple.com). For purchases via Google Play, payment is processed via Google; the right of withdrawal vis-à-vis the Provider remains unaffected and may additionally be asserted via the Google Play refund process.

Instructions on Withdrawal

Right of withdrawal

You have the right to withdraw from this contract within fourteen days without giving any reason. The withdrawal period is fourteen days from the day of the conclusion of the contract.

To exercise the right of withdrawal, you must inform us — SpuhlerLabs UG (haftungsbeschränkt), Rambacher Straße 79, 65193 Wiesbaden, Germany, e-mail: [email protected] — of your decision to withdraw from this contract by an unequivocal statement (e.g. a letter sent by post or an e-mail). You may use the attached model withdrawal form, but it is not obligatory.

To meet the withdrawal deadline, it is sufficient for you to send your communication concerning your exercise of the right of withdrawal before the withdrawal period has expired.

Effects of withdrawal

If you withdraw from this contract, we shall reimburse to you all payments received from you without undue delay and in any event not later than fourteen days from the day on which we are informed about your decision to withdraw from this contract. We will carry out such reimbursement using the same means of payment as you used for the initial transaction, unless you have expressly agreed otherwise; in any event, you will not incur any fees as a result of such reimbursement.

If you requested that the services begin during the withdrawal period, you shall pay us an amount which is in proportion to what has been provided until you have communicated to us your withdrawal from this contract, in comparison with the full coverage of the contract.

— End of the instructions on withdrawal —

§ 7 (3) — Early Expiry

The right of withdrawal expires, in the case of a contract for the provision of services, if the Provider has fully performed the service and began performing the service only after the consumer gave their express consent thereto and simultaneously confirmed their knowledge that they lose their right of withdrawal upon full performance of the contract by the Provider (Section 356 (4) BGB).

Model Withdrawal Form

(If you wish to withdraw from the contract, please fill out this form and return it to us.)

To: SpuhlerLabs UG (haftungsbeschränkt), Rambacher Straße 79, 65193 Wiesbaden, Germany, e-mail: [email protected]

I/We (*) hereby withdraw from the contract concluded by me/us (*) for the purchase of the following goods (*)/the provision of the following service (*)

Ordered on (*)/received on (*)

Name of consumer(s)

Address of consumer(s)

Signature of consumer(s) (only if this form is notified on paper)

Date

(*) Delete as appropriate.

§ 8 Obligations of the User; Prohibited Use

(1) The user undertakes to use the Service only for their own private purposes; not to use third-party credentials and not to connect third-party accounts without power of disposal; not to take any actions that impair the functionality of the Service (in particular no reverse engineering, no automated bulk queries, no circumvention of security mechanisms); and not to post unlawful content in free-text fields (e.g. notes, feedback).

(2) In the event of serious or repeated violations, the Provider may temporarily suspend the user account or terminate the contract for cause. The user's interests will be given appropriate consideration when selecting the measure.

§ 9 Availability; Changes to the Service

(1) The Provider endeavours to achieve high availability of the Service but does not owe uninterrupted availability. Maintenance work, further development, disruptions at third-party providers (in particular BANKSapi, account-holding banks, app store infrastructure, push services) and events of force majeure may lead to temporary restrictions.

(2) The Provider may further develop or change the Service or discontinue individual features to the extent this is reasonable for the user, taking into account the interests of both parties. Modifications of digital products going beyond what is necessary to maintain conformity are made in accordance with Section 327r BGB.

§ 10 Rights of Use

(1) For the duration of the contract, the Provider grants the user a simple, non-transferable, non-sublicensable right to use the App on their own devices for private purposes.

(2) All further rights in the App, its content, trademarks and signs remain with the Provider or the respective rights holders. Names and logos of merchants and banks displayed in the App are signs of their respective owners and serve solely to identify transactions and accounts.

§ 11 Liability

(1) The Provider is liable without limitation for intent and gross negligence, for damage resulting from injury to life, body or health, under the German Product Liability Act, and to the extent of any guarantee assumed.

(2) In cases of slight negligence, the Provider is liable only for damage resulting from the breach of essential contractual obligations (cardinal obligations), i.e. obligations whose fulfilment makes the proper performance of the contract possible in the first place and on whose observance the user may regularly rely. In such cases, liability is limited to the foreseeable damage typical for this type of contract.

(3) Any further liability of the Provider is excluded. This applies in particular to damage incurred by the user as a result of making financial decisions solely on the basis of the data displayed in the App without verifying the authoritative balance with the account-holding bank (§ 5).

(4) The above limitations of liability also apply in favour of the legal representatives, employees and vicarious agents of the Provider.

(5) For loss of data, in cases of slight negligence the Provider is liable only to the extent that such loss would also have occurred if the user had performed proper and regular data backups, insofar as the data can be reconstructed with reasonable effort from material kept available by the user.

§ 12 Term; Termination; Account Deletion

(1) The user agreement runs for an indefinite period and may be terminated by the user at any time by deleting the user account. Use of the App's features requires an active trial month, participation in a trial campaign (§ 6 para. 6) or an active subscription (§ 6). Paid subscriptions end in accordance with § 6.

(2) Account deletion can be requested in the App or via the form at copreo.com/delete-account. Upon receipt of the request, access to the account is locked. A grace period of seven days applies during which the user may cancel the deletion. After the grace period expires, the user account and the associated data are deleted; details, in particular regarding the revocation of the access authorisations at the banks, statutory retention obligations and pseudonymised evidence records, are governed by the Privacy Policy.

(3) The right of both parties to terminate for cause remains unaffected.

(4) A subscription concluded via an app store is not in every case automatically terminated by the account deletion; the user must additionally cancel their subscription via the subscription management of the respective store, unless the app-side cancellation is expressly confirmed in the deletion process.

§ 13 Changes to these Terms

(1) The Provider may amend these Terms with effect for the future, provided the amendment is reasonable for the user taking into account the Provider's interests and does not concern essential contractual obligations (subject matter of performance, remuneration). Amendments to essential contract terms require the user's consent.

(2) Amendments will be communicated to the user in text form (e.g. e-mail or in-app notice) at least six weeks before they take effect. If the user does not object within the period stated in the notification and continues to use the Service, the amended Terms are deemed accepted, provided the Provider has pointed out this legal consequence and the right to object in the notification. In the event of an objection, the Provider is entitled to ordinary termination.

§ 14 Final Provisions

(1) The law of the Federal Republic of Germany applies. Vis-à-vis consumers, this choice of law applies only insofar as it does not deprive the user of the protection of mandatory provisions of the law of the state of their habitual residence.

(2) The Provider is neither willing nor obliged to participate in dispute resolution proceedings before a consumer arbitration board.

(3) These Terms are provided in German and English. Only the German version is authoritative and legally binding; the English version is provided for information purposes only.

(4) Should individual provisions of these Terms be or become invalid, the validity of the remaining provisions shall remain unaffected.