Financial Intelligence Terminal

Terms of Use & Sale

Preamble

This document is an English translation provided for convenience. In the event of any discrepancy or conflict between the French version and this English translation, the French version shall prevail.

Art. 1Purpose and scope

These Terms of Use (the "Terms") govern access to and use of the Ad Viternam platform (the "Platform"), a financial intelligence terminal published by Ad Viternam, a French simplified joint-stock company (SAS) with share capital of €100, registered with the Paris Trade and Companies Register under SIREN number 990 909 996, whose registered office is at 60 rue François 1er, 75008 Paris, France ("Ad Viternam" or the "Company").

The Platform enables users to view market data, aggregate and visualise their wealth, manage budgets, track financial goals, connect bank and brokerage accounts, and access geopolitical intelligence and open-source intelligence (OSINT) tools, all for information purposes only.

⚠️ Ad Viternam does not provide any investment advice within the meaning of the French Monetary and Financial Code. The final decision on any action affecting the user's financial life rests exclusively with the user. See Article 9 for the full regulatory disclaimer.

Art. 2Definitions

"Platform" means all digital services accessible through the iOS and Android mobile applications and through the web or desktop terminal made available by Ad Viternam.

"User" means any legally capable adult natural person, or legal entity represented by an authorised representative, who has created an account on the Platform.

"Account" means the personal space created by the User to access the services.

"Free Plan" means permanent free access to the core features described in Article 3.2.

"Duo Plan" means the paid subscription allowing two user accounts to be linked within a shared household, as described in Article 3.3.

"Early Pro Plan" means the paid subscription providing access to the Market module and advanced features described in Article 3.4.

"AVI Plan" means the paid subscription providing access to the AEGIS geopolitical and OSINT intelligence module, as described in Article 3.5.

"AEGIS Module" means the geopolitical intelligence and open-source intelligence (OSINT) platform included in the AVI Plan.

"Market Data" means prices, indices, quotes and market information displayed on the Platform, supplied by third-party providers.

"Open Banking" means the bank account aggregation feature based on APIs compliant with Directive (EU) 2015/2366 (PSD2).

"Aggregated Data" means irreversibly anonymised financial data used for statistical purposes.

"GDPR" means Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data.

Art. 3Available plans

3.1 General access conditions

Access to the Platform is reserved for legally capable adult natural persons or legal entities acting through an authorised representative. Registration requires a valid email address and the User's country of residence.

3.2 Free Plan (permanent free access)

The Free Plan provides permanent, free access to the Ad Viternam terminal including: budget management (KPI view, income vs. expenses, net savings, expense breakdown), financial goal tracking, debt tracking, wealth aggregation through the banking and brokerage connection providers, unlimited connected accounts, and bank data refresh four times per day.

3.3 Duo Plan

The Duo Plan includes all Free Plan features, plus: access to the shared household allowing two user accounts to be linked, a consolidated household financial view, and shared financial goals.

3.4 Early Pro Plan

The Early Pro Plan includes all Duo Plan features, plus: access to the Market module (real-time quotes across 75 markets — equities, crypto-assets, currencies, commodities), detailed asset views, financial ratios, smart notifications, and real-time financial news.

3.5 AVI Plan

The AVI Plan includes all Early Pro Plan features, plus: access to the AEGIS Module, a real-time geopolitical and OSINT intelligence platform including conflict and tension-zone data, screening against the SDN sanctions list published by OFAC (US Treasury), and nine open-source investigation commands (DNS, WHOIS, SSL, CHAIN, CVE, MAC, OFAC, PHONE, GITHUB), under the conditions set out in Article 7.

The features of each plan are those available at the time of subscription. Pricing terms are set out in the Terms of Sale.

Art. 4Account creation and User obligations

4.1 Account creation

Creating an account requires a valid email address, the User's country of residence and acceptance of these Terms. The User either chooses a password upon registration or signs in with their Apple or Google account ("Sign in with Apple", "Sign in with Google"). In the latter case, no Ad Viternam password is created: sensitive actions (account deletion, email address change, disabling two-factor authentication, leaving read-only mode) are confirmed by signing in again with the same provider. The User is solely responsible for the confidentiality of their credentials and for any activity carried out from their account.

Additional information may be provided on an optional basis to personalise the experience: socio-professional status, estimated annual income, estimated wealth, year of birth, preferred language and currency. This information is never mandatory.

4.2 User obligations

Use the Platform in accordance with these Terms and applicable law;

Not attempt to circumvent security measures or access restrictions;

Not use the Platform for unlawful purposes, including market manipulation;

Not scrape, copy, reproduce or redistribute Market Data, news content or AEGIS Module data without express written authorisation;

Not use robots, scripts or automated systems to access the Platform;

Immediately report to Ad Viternam any unauthorised access to their account.

Art. 5Description of services

5.1 Market data

Market Data displayed on the Platform is supplied by Twelve Data and is provided "as is". Ad Viternam does not warrant its accuracy, completeness or availability. Market Data is protected by intellectual property rights belonging to its providers; any redistribution, resale or commercial exploitation by the User is strictly prohibited.

5.2 Financial news

Financial news is aggregated from RSS feeds made publicly available by press publishers. The Platform displays only the headline and source of each news item, together with a link redirecting the User to the original source. Ad Viternam does not redistribute, reproduce or store the full content of articles. Full content is accessed on the original publisher's website, under that publisher's terms.

5.3 Wealth aggregation and portfolio tracking

The User may manually enter or import their financial positions (equities, bonds, ETFs, crypto-assets, real estate, currencies, liabilities and debts) to track their evolution. Automated imports are performed through the providers referred to in Article 6. Displayed valuations are calculated from available market data and are indicative only.

5.4 Service availability

Ad Viternam uses reasonable efforts to keep the Platform available 24/7. Temporary interruptions may occur for maintenance or due to failures of data or infrastructure providers. Users will be informed of planned maintenance with reasonable notice.

5.5 External links

The Platform contains hyperlinks redirecting to third-party websites and content (news sources, press publishers, public sources of the AEGIS Module, provider websites). These links are provided for convenience only. Ad Viternam exercises no control over such third-party websites and content and disclaims all liability for their availability, accuracy, lawfulness, content, personal data practices, or any damage resulting from their consultation. Access to third-party websites is at the User's sole responsibility, under each website's own terms.

Art. 6Bank and brokerage connections

6.1 Open Banking — Enable Banking

Bank account aggregation is provided by Enable Banking, an authorised Account Information Service Provider (AISP), through APIs compliant with Directive (EU) 2015/2366 (PSD2). By using this service, the User accepts Enable Banking's terms of use and privacy policy, available on the provider's website.

Ad Viternam never has access to the User's banking credentials or login codes. This information passes exclusively between the User and their bank through the AISP's secure interface. Ad Viternam retains only the last 8 digits of the IBAN so that the User can identify their account. No full IBAN, banking credential or login code is stored by or known to Ad Viternam.

Access to banking data is subject to the User's explicit consent, collected for each connected bank. Access is strictly read-only. In accordance with PSD2, consent is renewed every 180 days. The User may revoke access at any time from their personal space or directly with their bank; revocation immediately stops synchronisation.

6.2 Brokerage connections — SnapTrade

Brokerage account connections are provided by SnapTrade. Access is strictly limited to reading positions and transactions; no order may be initiated, modified or executed through the Platform. By using this service, the User accepts SnapTrade's terms of use and privacy policy, available on the provider's website.

6.3 Liability for imported data

Ad Viternam disclaims all liability for the truthfulness, accuracy or completeness of data transmitted by Enable Banking, SnapTrade or any other connection provider. Imported data is displayed as received from the providers.

Art. 7AEGIS Module (AVI Plan)

7.1 Nature of the module

The AEGIS Module is a geopolitical and open-source intelligence (OSINT) platform aggregating exclusively data from public, freely accessible sources: conflict and tension-zone data, the SDN sanctions list published by the Office of Foreign Assets Control (OFAC) of the US Treasury, infrastructure data and public registries. The module comprises nine investigation commands, divided into three categories that structure Ad Viternam's personal-data commitments:

Infrastructure commands (DNS, WHOIS, SSL, CHAIN, CVE, MAC): they operate exclusively on domain names, network addresses, routing chains, vulnerability registries and hardware prefixes. No data relating to an identified person is processed;
Personal-identifier commands with local processing (OFAC, PHONE): they accept a name or telephone number as input, processed exclusively in memory on Ad Viternam's infrastructure, with no transmission to any third party and no retention;
Personal-identifier command with external processing (GITHUB): the submitted identifier (username or email address) is transmitted to GitHub, Inc.'s public API for the sole purpose of the lookup, without retention (see Articles 14.8, 16 and 17).

This minimisation architecture is a contractual commitment by Ad Viternam: only one command in the module transmits a personal identifier to a third party, and none retains it.

The only exception is at the User's own initiative: the AEGIS Module watchlist, in which the User may choose to save an entity, including a natural person, in order to be alerted of a change in its sanctions status. Such an entry is kept until the User removes it or deletes their account (see Article 14.8).

The AEGIS Module incorporates components from the OSIRIS open-source project, distributed under the MIT licence.

7.2 Module limitations

The AEGIS Module contains no intrusion tools, port scanners, vulnerability scanners, or any functionality enabling unauthorised access to an information system. Network analysis tools are limited to consulting publicly accessible information.

7.3 User obligations

The User undertakes to use the AEGIS Module in strict compliance with applicable law, and in particular not to use it for unlawful surveillance of individuals, harassment, invasion of privacy, or fraudulent access to an automated data processing system within the meaning of Articles 323-1 et seq. of the French Criminal Code.

The User may only submit to the personal-identifier commands (OFAC, PHONE, GITHUB) identifiers that they own, or for which they have the data subject's authorisation or a documented legitimate interest under a due-diligence obligation of their own.

Acceptance of this clause, required upon first access to the AEGIS Module, is recorded as evidence (user identifier, timestamp, version of the accepted text), on the basis of Ad Viternam's legitimate interest (Art. 6(1)(f) GDPR), for the duration of the account plus five years.

7.4 Informational purpose

AEGIS Module data, including sanctions-list search results, is provided for information purposes only. It constitutes neither legal compliance advice nor certification of the presence or absence of any person or entity on a sanctions list. The User remains responsible for verifying information with official sources before making any decision.

Art. 8Machine learning and aggregated data

8.1 Improvement of automatic categorisation

Ad Viternam uses an internally developed machine-learning system, hosted on its own servers, to continuously improve the automatic classification of banking transactions. This processing uses transaction data and User-validated categorisations as a learning signal. It is based on the User's explicit consent (Art. 6(1)(a) GDPR), collected when connecting their bank accounts. The User may withdraw this consent at any time from their account settings, without affecting the other features of the Platform.

8.2 Anonymised aggregated statistics

Users' financial data (budgets, expense categories, assets, liabilities, financial ratios, goals) may be used in aggregated and irreversibly anonymised form to produce economic and financial statistics: consumption trends and household behaviour, construction of reference indices or ratios, macroeconomic analyses.

These statistics are produced from aggregated and irreversibly anonymised data. They can in no way re-identify an individual User, in accordance with the European Data Protection Board (EDPB) guidelines on anonymisation. Such anonymised data falls outside the scope of the GDPR.

Art. 9No investment advice — Regulatory disclaimer

⚠️ ESSENTIAL REGULATORY DISCLAIMERAd Viternam is a financial intelligence terminal. All information, analyses, charts, tools and content made available on the Platform are provided for information and educational purposes only, enabling the User to understand and manage their financial life in full autonomy.They do not under any circumstances constitute:• Investment advice within the meaning of Directive 2014/65/EU (MiFID II) or the French Monetary and Financial Code;• Personalised recommendations to buy, sell or hold financial instruments;• An offer or solicitation to buy or sell securities or any other financial asset.Ad Viternam is not licensed as a Financial Investment Adviser (CIF), an Investment Services Provider (PSI), or under any other regulated status with the French AMF or ACPR. No order on financial instruments can be placed or executed through the Platform.THE FINAL DECISION ON ANY ACTION AFFECTING THE USER'S FINANCIAL LIFE RESTS EXCLUSIVELY WITH THE USER. PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS. ALL INVESTMENT CARRIES A RISK OF CAPITAL LOSS.Ad Viternam disclaims all liability for financial losses resulting from decisions made on the basis of information available on the Platform.

Art. 10Intellectual property

The Platform, its software components, architecture, interfaces, algorithms and all content produced by Ad Viternam are protected by intellectual property law. "Ad Viternam" (INPI No. 26 5217672, classes 9 and 42) and "Ad Viternam Intelligence" (INPI No. 25 5212164, classes 35 and 41) are registered word marks. Any unauthorised reproduction, representation, modification or exploitation is strictly prohibited.

The User retains full ownership of their personal data and manually entered data. The User grants Ad Viternam a licence limited to the sole purpose of providing the service, ending upon account closure.

The AEGIS Module also incorporates open-data datasets used in accordance with their respective licences: the us_ofac_sdn dataset normalised by OpenSanctions (CC-BY 4.0 licence), whose upstream source is the SDN list published by the Office of Foreign Assets Control (OFAC) of the US Treasury; the IEEE OUI registry for hardware prefix identification; and the CVE vulnerability registries (MITRE Corporation, CIRCL). Data provenance is displayed on the module's result screens.

Art. 11Liability and limitations

To the fullest extent permitted by applicable law, Ad Viternam shall not be liable for financial losses resulting from investment decisions, for the inaccuracy of data supplied by third parties (Twelve Data, press publishers' RSS feeds, Enable Banking, SnapTrade, OSINT sources), or for service interruptions caused by events beyond its control.

For Users on paid plans, Ad Viternam's total liability is capped at the amounts paid during the twelve months preceding the event giving rise to the claim. These limitations do not apply in the event of intentional or gross misconduct, or personal injury.

Art. 12Account suspension and termination

12.1 Termination by the User

The User may close their account at any time from their personal space settings. All of the User's personal data is destroyed within 72 hours of confirmed closure, except data whose retention is required by a legal obligation, and subject to the encrypted backups described in Article 14.7.

12.2 Termination by Ad Viternam

Ad Viternam reserves the right to suspend or terminate an account in the event of breach of these Terms, fraudulent or unlawful conduct, misuse of the AEGIS Module, or non-payment of amounts due.

PART II — PERSONAL DATA PROTECTION

Art. 13Data controller and data protection referent

Ad Viternam, SAS, 60 rue François 1er, 75008 Paris (SIREN 990 909 996), acts as data controller within the meaning of Article 4(7) GDPR. The data protection referent is Valentin Soulages, reachable at [email protected] or by post at the registered office.

Users' data is never sold, exchanged or transferred to third parties for commercial purposes.

Art. 14Data collected, purposes and retention periods

14.1 Identification and account data

Mandatory data: email address (AES-256-GCM encrypted in the database), country of residence.

Optional data: socio-professional status, estimated annual income, estimated wealth, year of birth, language, preferred currency.

Purpose: account creation and management, personalisation of the experience.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR) for mandatory data; consent (Art. 6(1)(a) GDPR) for optional data.

Retention: duration of the account. An account inactive for 3 years (no sign-in or use of the Platform) is deleted; the User is notified by email one week beforehand and may keep it by signing in before that date. An ongoing paid subscription suspends this rule.

Sign in with Apple or Google: Ad Viternam receives the technical identifier of the Apple or Google account and the associated email address (for Apple, where applicable, a private relay address). The name provided at first sign-in is not kept. Legal basis: performance of the contract (Art. 6(1)(b) GDPR). Retention: duration of the account.

14.2 Connection logs

Data: IP address, connection timestamp, session identifier.

Purpose: security, fraud and unauthorised access detection.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR).

Retention: 90 days, then automatic purge.

14.3 Portfolio and budget data

Data: financial positions (equities, bonds, ETFs, crypto-assets, real estate, currencies), liabilities, debts, financial goals, ratios, budgets and expense categories.

Purpose: provision of the wealth and budget tracking service.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Retention: duration of the account. Full purge within 72 hours of closure.

14.4 Banking and brokerage data (Enable Banking / SnapTrade)

Data: account information, balances, transaction history, categorisations, brokerage positions. Partial account identifier: last 8 digits of the IBAN, retained for display and identification by the User.

Exclusions: no full IBAN, login credential, access code or contract number is stored by or known to Ad Viternam.

Purpose: provision of the aggregation service and improvement of categorisation through machine learning.

Legal basis: explicit consent (Art. 6(1)(a) GDPR), collected granularly, renewed every 180 days (PSD2). A separate consent is collected for the use of transactions to improve automatic categorisation (machine learning), revocable at any time.

Retention: duration of the account. The history of transactions already imported is kept as long as the account exists, for wealth and budget tracking; withdrawing consent immediately stops any further synchronisation. Full purge within 72 hours of closure.

14.5 Aggregated and anonymised data

Nature: irreversibly anonymised data, outside the scope of the GDPR.

Use: economic statistics, consumption indices, behavioural trends.

This data can in no way re-identify an individual User.

14.6 Enterprise requests (website contact form)

Data: name, business email address, company, role, company size, description of the need.

Purpose: responding to the request and presenting the Enterprise offer.

Legal basis: pre-contractual steps taken at the person's request (Art. 6(1)(b) GDPR).

Retention: 3 years from the last exchange.

Recipients: the request is sent by email, via Resend, to Ad Viternam's mailbox; it is not stored in the Platform's database.

The former early-access lists are closed; the data collected through them is deleted no later than 24 months after the last interaction.

14.7 Account deletion

Upon the User's account deletion request, or at the end of the inactivity period set out in Article 14.1, all of their personal data is destroyed within 72 hours, except data whose retention is required by a legal obligation. An anonymised record of the account's existence is kept for internal statistical purposes.

Backups: the database is backed up every night and encrypted before any transfer. Deleted data remains only in these encrypted backups, which are not accessible to day-to-day operations, until they are automatically erased no later than 100 days after the backup. They are used solely to restore the service after an incident.

14.8 AEGIS Module queries

Data processed: the identifier submitted by the User to the relevant commands (name for OFAC, telephone number for PHONE, username or email address for GITHUB).

Purpose: one-off verification of an identifier's exposure or status in open sources.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR), based on the User verifying their own exposure or performing a due-diligence obligation of their own. The balancing test is recorded in the processing register.

Retention: none. Submitted identifiers are processed in memory for the duration of the query and are not recorded, logged or retained in any form whatsoever.

Search history: for searches on non-nominative entities only (companies, organisations, domain names, wallet addresses, vessels, aircraft), a history limited to a summary (counters and flags, never the raw result) is kept for 30 days in the User's space. No search on a natural person, an email address or a telephone number is ever recorded there.

Watchlist: the entities the User chooses to add to it, including a natural person, are kept until the User removes them or deletes their account, in order to alert the User of a change in sanctions status.

Recipients: none for the OFAC and PHONE commands (processing exclusively local on Ad Viternam's infrastructure); GitHub, Inc. for the GITHUB command only (see Articles 16 and 17).

Art. 15Data security

Encryption in transit: TLS 1.3 via Cloudflare on all communications, then an encrypted tunnel between Cloudflare and Ad Viternam's servers.

Encryption at rest: AES-256-GCM with random initialisation vector for sensitive data.

Authentication: JWT (JSON Web Token) on all API endpoints.

Data isolation: Logical isolation per user in the database.

Logging: Full traceability of access and security events, 90-day retention then automatic purge. Express exclusion: identifiers submitted to AEGIS Module commands are never logged or retained, including in technical security logs (see Article 14.8). Connection logging (Article 14.2) covers the User's session, not the content of their queries.

Off-server backups and logs: the database is backed up every night and technical logs every 15 minutes, encrypted before transfer to storage located in the European Union and protected against deletion; backups are kept for at most 100 days, logs for at most 35 days.

Anti-intrusion protection: Detection and blocking of repeated login attempts, SSH key-only access, Cloudflare Web Application Firewall (WAF), immediate alerting on any administrative login and integrity monitoring of server files.

Hosting: Infomaniak Network SA servers, Geneva, Switzerland — ISO 27001 certified infrastructure.

In the event of a personal data breach, Ad Viternam will notify the French supervisory authority (CNIL) within 72 hours in accordance with Article 33 GDPR, and affected Users without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

Art. 16Processors

In accordance with Article 28 GDPR, Ad Viternam has entered into or undertakes to enter into a data processing agreement (DPA) with each of the following processors:

Infomaniak Network SA — Hosting & data storage — Geneva, Switzerland 🇨🇭 — DPA signed

Stripe, Inc. — Web/desktop payment processing — United States 🇺🇸 — DPA available at stripe.com/legal/dpa

Apple Inc. — In-App Purchase (iOS), "Sign in with Apple", push notifications (APNs), email (Apple Mail) — United States 🇺🇸 — DPA available at apple.com/legal/privacy

Google LLC — In-App Purchase (Android), "Sign in with Google", push notifications (FCM) — United States 🇺🇸 — DPA available at cloud.google.com/terms/data-processing-addendum

Microsoft Corporation — Email (Outlook) — United States 🇺🇸 — DPA available at microsoft.com/licensing/docs

Cloudflare, Inc. — CDN, WAF, TLS, aggregated audience analytics, object storage (R2) of technical logs and backups, encrypted before upload and located in the European Union — United States 🇺🇸 — DPA available at cloudflare.com/gdpr/introduction

Resend, Inc. — Transactional email delivery (account confirmation, security, alerts) — United States 🇺🇸 — DPA available at resend.com/legal/dpa

RevenueCat, Inc. — Technical management of in-app subscriptions — United States 🇺🇸 — DPA available at revenuecat.com/dpa

650 Industries, Inc. (Expo) — Delivery of push notifications to the mobile apps and distribution of app updates — United States 🇺🇸 — Legal information available at expo.dev

Enable Banking — Bank aggregation (AISP, PSD2) — European Union 🇪🇺 — Legal information available at enablebanking.com

SnapTrade — Brokerage connections (read-only) — Legal information available at snaptrade.com

GitHub, Inc. — Recipient of the AEGIS Module GITHUB command (public API lookup) — United States 🇺🇸 — EU-US Data Privacy Framework certified

Meta Platforms Ireland Limited — Advertising-audience measurement via the Conversions API (CAPI) on the marketing website, ONLY subject to the visitor's consent — Ireland 🇮🇪 (US transfers covered) — EU-US Data Privacy Framework certified — joint controller for this measurement

GitHub, Inc. does not act as a processor within the meaning of Article 28 GDPR but as a mere recipient: Ad Viternam does not entrust any processing to GitHub on its behalf; it consults a public API service. The other AEGIS Module sources (DNS resolvers, RDAP registries, certificate transparency logs, BGP routing data, CVE registries, OUI registry) receive only technical data relating to no identified person.

Users' personal data is not sold, exchanged or transferred to third parties.

Art. 17International data transfers

Several of Ad Viternam's processors are established in the United States. Transfers to these entities are governed by the European Commission's Standard Contractual Clauses (Decision 2021/914), the EU-US Data Privacy Framework (DPF) for certified entities, and a transfer impact assessment (TIA) for each processor concerned.

The transmission of identifiers to GitHub, Inc. under the AEGIS Module GITHUB command falls under the same framework: GitHub, Inc. is certified under the EU-US Data Privacy Framework, and no additional transfer instrument is required.

Data is hosted in Switzerland with Infomaniak. Switzerland benefits from a European Commission adequacy decision. The Swiss Federal Act on Data Protection (nFADP), in force since 1 September 2023, is aligned with the GDPR. Backups and technical logs, encrypted before transfer, are stored in the European Union.

For users residing outside the European Union, the United Kingdom, Switzerland and North America, use of the Platform is at their sole responsibility. Such users must ensure compliance with their applicable local law.

Art. 18Cookies and trackers

The Platform does not use tracking cookies. Audience analytics are performed through Cloudflare Analytics, a server-side aggregated analytics tool that uses no cookies, does not track individual users and does not fingerprint devices; this audience measurement requires no consent. Advertising-effectiveness measurement via Meta's Conversions API (Meta Platforms Ireland Limited), however, is subject to your prior consent, collected via a dedicated banner on the marketing website, and may be refused or withdrawn at any time (see Article 16 and the legal notice).

The web app sets a single strictly necessary cookie, inaccessible to scripts (httpOnly), which keeps the signed-in User's session. It requires no consent and is removed on sign-out.

Art. 19Rights of data subjects

Right of access (Art. 15): Obtain a copy of their processed personal data.

Right to rectification (Art. 16): Have inaccurate or incomplete data corrected.

Right to erasure (Art. 17): Obtain deletion of their data (purge within 72 hours — Article 14.7).

Right to restriction (Art. 18): Obtain restriction of processing in the cases provided for.

Right to portability (Art. 20): Receive their data in a structured, machine-readable format.

Right to object (Art. 21): Object to processing based on legitimate interest.

Right to withdraw consent: Withdraw consent at any time, including for bank connections and the use of transactions for machine-learning purposes.

Right to post-mortem directives: In accordance with the French Data Protection Act.

Profile data rectification, consent withdrawal and account deletion are performed directly from the User's personal space. The rights of access and portability, as well as the other rights, are exercised by email to [email protected]; a copy of the data is then sent in a structured, machine-readable format. Ad Viternam undertakes to respond within one month. If unsatisfied, the User may lodge a complaint with the CNIL (www.cnil.fr) or the competent authority in their country of residence.

PART III — COMMON PROVISIONS

Art. 20Geographic scope

These Terms are drafted under French law and cover the following markets: the European Union and European Economic Area (GDPR), Switzerland (nFADP), the United Kingdom (UK GDPR), and North America (CCPA for California, PIPEDA/Law 25 for Canada). As the Platform is available on worldwide app stores, users in other territories use it at their sole responsibility and must ensure compliance with their local law.

Art. 21Amendments to the Terms

Ad Viternam reserves the right to amend these Terms to reflect legislative, regulatory or service developments. Any substantial amendment is notified by email with at least 30 days' notice. Absent objection within that period, the new Terms are deemed accepted. In the event of objection, the User may close their account as described in Article 12.

Art. 22Governing law and jurisdiction

These Terms are governed by French law, subject to mandatory provisions of the law applicable in the consumer's country of habitual residence. Failing amicable resolution, any dispute shall be submitted to the competent courts of the place of Ad Viternam's registered office, subject to mandatory jurisdiction rules applicable to consumers residing in an EU Member State.

Art. 23Severability — Entire agreement

If any provision of these Terms is held invalid, the remaining provisions shall remain in full force. These Terms, together with the Terms of Sale and the Legal Notice, constitute the entire agreement between the parties.

Art. 24Contact

Customer service, complaints & GDPR rights requests: [email protected]

Postal address: Ad Viternam, 60 rue François 1er, 75008 Paris, France

© Ad Viternam, SAS — SIREN 990 909 996 — Version 1.4 — 04/10/2026"Ad Viternam" (INPI No. 26 5217672) and "Ad Viternam Intelligence" (INPI No. 25 5212164) are registered word marks — All rights reserved

Terms of Sale (CGV)

Art. 1Purpose and scope

These Terms of Sale govern subscription to the paid plans of the Ad Viternam platform by any User. They supplement the Terms of Use, which remain applicable to all services. In the event of conflict, these Terms of Sale prevail over the Terms of Use with respect to pricing and contractual aspects of the sale.

Art. 2Plans and pricing

2.1 Free — Free of charge

Permanent, free access to the Ad Viternam terminal including: budget management (KPI view, income vs. expenses, net savings, expense breakdown), financial goal tracking, debt tracking, wealth aggregation via SnapTrade and Enable Banking, unlimited connected accounts, bank data refresh four times per day.

2.2 Duo — €6.99/month or €69.99/year

Includes all Free features, plus: shared household access linking two user accounts, consolidated household financial view, shared financial goals.

2.3 Early Pro — €15.99/month or €154.99/year

Includes all Duo features, plus: access to the Market module (real-time quotes across 75 markets — equities, crypto-assets, currencies, commodities), detailed asset views, financial ratios, smart notifications, real-time financial news.

2.4 AVI — €59.99/month or €599.99/year

Includes all Early Pro features, plus: access to the AEGIS Module, a real-time geopolitical and OSINT intelligence platform including conflict and tension-zone data, screening against the OFAC SDN sanctions list (US Treasury), and open-source investigation commands (DNS, WHOIS, SSL, CHAIN, CVE, MAC, OFAC, PHONE, GITHUB).

2.5 General provisions

Prices are expressed in euros, inclusive of all taxes (TTC), and include VAT at the rate applicable in the User's country of residence, in accordance with EU rules on digital services. For Users outside the European Union, no EU VAT is charged; any local taxes remain their responsibility. Prices displayed on the app stores (Apple App Store, Google Play) may differ slightly according to the stores' pricing policies and local currencies. The features of each plan are those available at the time of subscription.

Art. 3Free trial period

Paid plans (Duo, Early Pro, AVI) include a 14-day free trial. No charge is made during this period. The User may cancel free of charge before the end of the trial; otherwise, the subscription automatically begins at the selected plan's rate.

Art. 4Payment terms

4.1 Payment channels

iOS apps (App Store): Payment is handled entirely by Apple Inc. through In-App Purchase. Ad Viternam does not collect, store or process any payment data. Billing is issued directly by Apple.

Android apps (Google Play): Payment is handled entirely by Google LLC through In-App Purchase. Ad Viternam does not collect, store or process any payment data. Billing is issued directly by Google.

Web and desktop terminal: Payment is processed by Stripe, Inc. through Stripe Invoicing. Ad Viternam does not collect, store or hold any card data. Invoices are issued by Stripe on behalf of Ad Viternam.

4.2 Subscription management

Technical management of in-app subscriptions (iOS and Android) is provided by RevenueCat, Inc. (United States), acting as a processor under its data processing agreement (DPA) available at revenuecat.com/dpa.

4.3 Payment default

In the event of a failed payment, the User is notified. Without regularisation within 7 days, access to paid features may be suspended. After 30 days without regularisation, the subscription may be terminated.

Art. 5Right of withdrawal

5.1 Principle and period

In accordance with Articles L.221-18 et seq. of the French Consumer Code, consumer Users have a withdrawal right of 14 calendar days from subscription, without having to give reasons.

5.2 How to exercise the right

For subscriptions made via the web or desktop terminal, the User gives notice before the end of the 14-day period directly through the Stripe subscription management portal, accessible from their personal space.

For subscriptions made via the App Store (Apple) or Google Play, withdrawal and refunds are handled directly through the relevant store's subscription management interface, under Apple's or Google's conditions respectively.

If the User requests immediate performance of the service before the end of the withdrawal period, they acknowledge losing their withdrawal right for the portion of the service already performed, in accordance with Article L.221-28 of the French Consumer Code.

Art. 6Term, renewal and cancellation

6.1 Automatic renewal

Subscriptions are taken out for a monthly or annual term, automatically renewed. Ad Viternam sends a renewal reminder by email 30 days before the renewal of annual subscriptions.

6.2 Cancellation

The User may cancel their subscription at any time: through the Stripe management portal for web/desktop subscriptions, or through Apple's or Google's subscription management interface for in-app subscriptions. Cancellation takes effect at the end of the current period. Upon expiry, the account automatically reverts to the Free Plan, unless the User requests account deletion.

Art. 7Price changes

Ad Viternam reserves the right to change its prices. Any change is notified by email with at least 30 days' notice and applies to the next billing period following expiry of the notice. A User who declines the new price may cancel their subscription before it takes effect.

Art. 8Mediation and dispute resolution

In the event of a dispute, the parties undertake to seek an amicable solution before any court action. The User may address complaints to [email protected]; Ad Viternam undertakes to respond within 30 days.

In accordance with Articles L.611-1 et seq. of the French Consumer Code, consumer Users may have free recourse to a consumer mediation scheme. The contact details of the competent mediator are provided upon request to [email protected]. The European Online Dispute Resolution platform is available at: https://ec.europa.eu/consumers/odr/

Art. 9Governing law and jurisdiction

These Terms of Sale are governed by French law, subject to mandatory provisions of the law applicable in the consumer's country of habitual residence. Failing amicable resolution, any dispute shall be submitted to the competent courts of the place of Ad Viternam's registered office, subject to mandatory jurisdiction rules applicable to consumers residing in an EU Member State.

Annex — Model withdrawal form

(Complete and return this form only if you wish to withdraw from the contract. Applicable to subscriptions made via the web or desktop terminal. For subscriptions via the App Store or Google Play, please use the relevant store's subscription management interface.)

To: Ad Viternam, SAS — 60 rue François 1er, 75008 Paris, France — [email protected]

I hereby give notice that I withdraw from my contract for the provision of the following service:

Plan subscribed (Duo / Early Pro / AVI): ______________________________________

Subscribed on: ______________________________________

Email address associated with the account: ______________________________________

Name of consumer (optional): ______________________________________

Date: ______________________________________

Signature (only if this form is notified on paper): ______________________________________