Terms and Conditions

1. Acceptance of Terms

By creating an account and using Prisma, you agree to be bound by these Terms and Conditions ("Terms"). If you do not agree to these Terms, please do not use our service.

2. Description of Service

Prisma is a portfolio tracking application that allows users to:

• Track investment portfolios
• Monitor asset prices and performance
• Import transactions from supported brokers or manually enter transactions
• View financial analytics and reports

3. User Accounts

3.1 Account Creation

• You must provide accurate and complete information when creating an account
• You are responsible for maintaining the security of your account credentials
• You must be at least 18 years old to create an account

3.2 Account Responsibility

• You are solely responsible for all activities under your account
• You must notify us immediately of any unauthorized use of your account
• We reserve the right to suspend or terminate accounts that violate our Terms and Conditions

3.3 Account Individuality

• Each account is intended for use by a single individual only
• Sharing account credentials or access with other persons is strictly prohibited
• Each user may maintain only one active account
• Violation of this policy may result in immediate account suspension or termination

4. Use of the Service

4.1 Permitted Use

• Use the service for personal portfolio tracking and analysis
• Import legitimate financial data from supported sources
• Access and use features as intended by the application design

4.2 Prohibited Use

• Use the service for any illegal or unauthorized purpose
• Attempt to gain unauthorized access to other users' data
• Interfere with or disrupt the service or servers
• Use automated systems to access the service without permission
• Share your account credentials or allow others to use your account
• Create multiple accounts for the same individual

4.3 Broker Import — User Responsibility

• Prisma's broker import is a parser that reads broker transaction statement files (PDF, CSV) that you upload yourself. We do not connect to your broker account and never have access to your broker login credentials
• You are solely responsible for ensuring that uploading and processing these statements via Prisma is permitted under your broker's terms of service. Broker terms vary and may restrict re-processing of statement files by third parties
• You retain full data sovereignty: you choose which files to upload, and you can delete them from Prisma at any time
• Broker statement formats may change without notice. We make reasonable efforts to keep parsers up to date but cannot guarantee continued compatibility with future broker statement versions

4.4 Broker Non-Affiliation

Prisma is an independent product of Surplexic GmbH. Prisma is not affiliated with, endorsed by, sponsored by, or otherwise associated with DeGiro, Trade Republic, ING, DKB, or any other broker, exchange, or financial institution. References to broker names in the app, on our website, or in marketing materials are descriptive only and do not imply any business relationship or endorsement. All broker trademarks remain the property of their respective owners.

5. Data and Privacy

5.1 Data Collection

• We collect and process data as described in our Privacy Policy
• Financial data is encrypted and stored securely
• We do not share your unencrypted personal financial data with third parties except as described in our Privacy Policy (notably the processors and legal bases listed in Privacy Policy § 4)

5.2 Data Accuracy

• You are responsible for the accuracy of data you input
• We cannot guarantee the accuracy of financial data displayed in the app
• We are not responsible for investment decisions based on data in the app
• Market data may be delayed and is provided for informational purposes only

6. Investment Disclaimer

IMPORTANT: Please read this section carefully before using Prisma.

6.1 No Investment Advice or Recommendations

• Prisma is a portfolio tracking tool for informational and educational purposes only
• All information, data, analytics, performance metrics, and content displayed in this application are provided solely for informational purposes and do not constitute investment advice, financial advice, trading advice, or any other form of advice
• No personal recommendation within the meaning of § 2 Abs. 10 WpHG (German Securities Trading Act) is made or intended. Prisma does not assess your individual circumstances, financial situation, or investment objectives and does not generate recommendations tailored to you personally
• Any scores, ratings, or analytics shown in the app (including Quality Score, Appeal Score, and similar metrics) are general informational indicators derived from publicly available data and apply uniformly to all users — they are not adapted to your individual portfolio, risk tolerance, or objectives
• We do not provide personalized investment recommendations and no content in this application should be construed as a recommendation to buy, sell, or hold any security, investment product, or financial instrument
• Any references to specific securities, asset classes, or investment strategies are purely for illustrative and tracking purposes
• Past performance is not indicative of future results and should not be relied upon when making investment decisions

6.2 Investment Risk Warning

Investing in stocks, ETFs, bonds, funds, and other securities involves substantial risk, including the potential total loss of your invested capital. You could lose some or all of the money you invest. The value of your investments can fluctuate significantly, and there is no guarantee that any investment strategy will be successful.

You acknowledge and agree that:

• You are solely responsible for your own investment decisions
• You should conduct your own research and due diligence before making any investment decision
• You should consult with qualified, licensed financial advisors, tax professionals, and legal counsel before making investment decisions
• Investment decisions should be based on your individual financial situation, investment objectives, and risk tolerance

6.3 Documentation Only Service

• Prisma is not a broker, investment advisor, or trading platform
• We are not licensed or regulated to provide investment advice
• Adding transactions in Prisma is for documentation and tracking purposes only
• No transactions entered in the app will execute actual trades or orders with any broker
• Users must execute all trades through their own licensed brokers or financial institutions
• We do not facilitate, execute, or recommend any securities transactions
• Analytics scores (Quality, Appeal), analyst consensus data, tax calculations, and portfolio impact assessments shown in the app are derived from publicly available data and are provided for educational and informational purposes only
• Tax-related features (Tax Intelligence, tax reports, holding-period indicators) are informational tools, not tax advice within the meaning of § 1 StBerG (German Tax Advisory Act). They do not replace consultation with a Steuerberater (qualified tax advisor). Tax outcomes depend on individual circumstances we do not assess. Users are solely responsible for the accuracy and completeness of their tax filings

6.4 Data Accuracy Disclaimer

• While we strive to provide accurate information, we do not guarantee the accuracy, completeness, or timeliness of any data displayed in the application
• Market data may be delayed and is provided for informational purposes only
• We are not responsible for any errors or omissions in the data or for any actions taken based on such data
• You should verify all information independently before making any investment decisions

7. Service Availability

7.1 Service Uptime

• We strive to maintain high service availability and use reasonable efforts to minimize service interruptions
• Scheduled maintenance may temporarily interrupt service; we will provide reasonable notice where feasible
• Our liability for service interruptions, downtime, and data loss is governed by the limitation of liability in § 12 below

8. Modifications

8.1 Modification of Terms

• We may modify these Terms with at least 30 days' prior notice provided by email and/or in-app notification
• Modifications may be made only for the following reasons: changes in applicable law, court or regulatory decisions, changes in technology or security standards, modifications to the service that necessitate term adjustments, or correction of regulatory gaps in these Terms
• You have the right to object to the modifications within 30 days of notification. The notification will explicitly highlight that absence of an objection within this period is deemed acceptance of the modifications
• If you object, you may terminate the contract with effect from the date the modifications would have taken effect; we may also terminate the contract with the same effect

8.2 Service Changes

• We may add, modify, or discontinue features with reasonable notice
• Material adverse changes affecting paid features will be communicated at least 30 days in advance
• For service discontinuation, see § 11.3

9. Subscriptions, Pricing, and Renewal

9.1 Plans

Prisma offers a free tier and a paid tier ("Prisma Pro"). Available plans, features, and prices are shown in the in-app paywall before purchase. Prices include applicable VAT/USt where required.

9.2 Billing via Apple In-App Purchase

All paid subscriptions are concluded and billed exclusively through Apple's In-App Purchase system. By starting a subscription, you authorize Apple to charge the payment method on file with your Apple ID for the selected plan and any auto-renewal.

9.3 Automatic Renewal

Subscriptions renew automatically at the end of each billing period (monthly or annual, as selected) at the then-current price, unless you cancel at least 24 hours before the end of the current period (per Apple's standard subscription rules). You will be charged for the renewal within 24 hours prior to the end of the current period.

The renewed term will not exceed one year for unilateral extensions (in line with the "Gesetz für faire Verbraucherverträge", in force since 1 March 2022); after the first paid term you may cancel monthly with effect at the end of the next billing month.

9.4 Price Changes

We may adjust the price of your subscription only where one of the following triggering events occurs after the contract was concluded: (a) a sustained increase in our own costs of providing the service (in particular costs of third-party infrastructure such as Firebase, market data providers, or payment processors); (b) changes in applicable law, taxes, or regulatory levies; (c) changes in the scope of paid features that materially increase the value of the subscription. The price adjustment must be proportionate to the actual change in costs and may not be used to increase our margin.

We will notify you of any price change at least 30 days in advance, by email or in-app notice, stating the new price, the effective date, and the reason for the adjustment. You have the right to object to the price change in writing (info@surplexic.com) or to cancel your subscription before the new price takes effect; in case of timely objection, the existing contract may be terminated by us with effect from the proposed effective date. Continued use of the paid subscription after the new price has taken effect, combined with non-objection during the 30-day notice period, constitutes acceptance of the new price.

Any unilateral extension of the subscription term following a price change remains subject to the 1-year cap under the German Act on Fair Consumer Contracts (Gesetz für faire Verbraucherverträge).

9.5 Refunds

Refunds for unused periods are handled by Apple under the App Store Refund Policy and are not within our control. You can request a refund directly at https://reportaproblem.apple.com.

9.6 Free Trials

If a free trial is offered, the paid subscription begins automatically at the end of the trial period unless cancelled at least 24 hours before the trial ends. The remaining trial period is forfeited if you upgrade to a paid plan early.

10. Right of Withdrawal (Widerrufsrecht)

This section applies to consumers within the meaning of § 13 BGB residing in the European Union.

10.1 Right of Withdrawal

You have the right to withdraw from this contract within 14 days without giving any reason.

The withdrawal period will expire 14 days from the day of the conclusion of the contract.

To exercise your right of withdrawal, you must inform us:

by an unequivocal statement (e.g., a letter sent by post or email) of your decision to withdraw from this contract. You may use the model withdrawal form below, but it is not obligatory.

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

10.2 Effects of Withdrawal

If you withdraw from this contract, we shall reimburse all payments received from you, without undue delay and in any event not later than 14 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 you used for the initial transaction, unless you have expressly agreed otherwise; in no event will you incur any fees as a result of such reimbursement.

10.3 Premature Expiry of the Right of Withdrawal

The right of withdrawal expires prematurely in the case of contracts for the supply of digital content not supplied on a tangible medium, and contracts for the provision of services, if performance commenced with your express prior consent and your acknowledgment that you thereby lose your right of withdrawal upon full performance.

By starting a paid Prisma subscription you expressly consent that performance of the service begins immediately and acknowledge that you thereby lose your right of withdrawal upon full performance of the contract.

10.4 Model Withdrawal Form

(Complete and return this form only if you wish to withdraw from the contract.)

11. Termination and Subscription Cancellation

11.1 Account Termination

• You may terminate your account at any time via Settings → Delete Account
• Upon termination, your data will be deleted according to our Privacy Policy

11.2 Subscription Cancellation (§ 312k BGB)

Paid subscriptions to Prisma are managed and billed by the app-store provider on whose platform you originally subscribed (Apple via the App Store on iOS/iPadOS, or Google via Google Play on Android). You can cancel your subscription at any time directly from your device, without giving any reason:

iOS / iPadOS: Settings app → tap your Apple ID at the top → Subscriptions → select Prisma → tap Cancel Subscription.

Alternatively: open the App Store → tap your profile icon → Subscriptions → select Prisma → Cancel Subscription.

Android: open the Google Play Store app → tap your profile icon → Payments & subscriptions → Subscriptions → select Prisma → Cancel subscription.

Alternatively: open https://play.google.com/store/account/subscriptions on the web → select Prisma → Cancel subscription.

If you cancel before the next renewal date, you retain access to paid features until the end of the current billing period; Apple or Google will not charge you for any subsequent renewal period. Refunds for unused periods are handled by Apple under the App Store Refund Policy or by Google under the Google Play Refund Policy and are not subject to our control.

For non-subscription contractual disputes, you may also notify us in writing at info@surplexic.com.

11.3 Service Termination by Us

• We may terminate accounts that violate these Terms, after notice and a reasonable opportunity to cure where appropriate
• We may discontinue the service with at least 30 days' prior notice, except where immediate discontinuation is required for legal, security, or technical reasons
• In the event of service discontinuation, paid subscribers will receive a pro-rata refund for unused periods

12. Liability and Warranty

12.1 Statutory Warranty Rights

Your statutory warranty rights under German law remain unaffected. For paid digital services, this includes the rights under §§ 327 ff. BGB. We make no commercial guarantees (Garantien im Sinne des § 443 BGB) beyond the statutory warranty unless expressly stated in writing.

12.2 Limitation of Liability

Surplexic GmbH is liable without limitation:

• for damages caused by intent (Vorsatz) or gross negligence (grobe Fahrlässigkeit)
• for injury to life, body, or health caused by any negligence on our part
• under the German Product Liability Act (Produkthaftungsgesetz)
• for damages resulting from a guarantee (Garantie) expressly given by us
• for damages arising from any violation of our obligations under the German Federal Data Protection Act (BDSG) or the EU General Data Protection Regulation (GDPR), including but not limited to the user's right to material and non-material damages under Art. 82 GDPR

For damages caused by slight negligence (leichte Fahrlässigkeit), Surplexic GmbH is liable only for the breach of essential contractual obligations (Kardinalpflichten — obligations the fulfillment of which makes the proper execution of the contract possible in the first place and on whose observance you may regularly rely). In such cases, liability is limited to damages that are typical for contracts of this kind and reasonably foreseeable at the time of contract conclusion.

For all other damages caused by slight negligence, liability is excluded to the extent permitted by law.

The above limitations also apply to liability for our legal representatives, employees, and vicarious agents (Erfüllungsgehilfen).

12.3 Data Loss

You are responsible for backing up data you enter into Prisma where the data is critical to you; we recommend exporting your portfolio data regularly via the in-app export feature. In the event of data loss caused by us, our liability is limited under § 12.2 above; in addition, we are only liable for the restoration of data that would also have been lost if you had maintained reasonable backups.

13. Governing Law

These Terms are governed by the laws of the Federal Republic of Germany, excluding its conflict-of-laws provisions and the UN Convention on Contracts for the International Sale of Goods (CISG).

For consumers within the meaning of § 13 BGB residing in another EU Member State, mandatory consumer-protection provisions of the country of habitual residence apply in addition (Art. 6 Rome I-Regulation).

For consumers residing outside the European Union (including in the United States, Canada, the United Kingdom, Switzerland, and other jurisdictions), this choice of German law does not deprive you of the protection afforded to you by mandatory provisions of the law of your country of habitual residence that cannot be derogated from by agreement. Where local consumer-protection statutes grant you rights that exceed those provided under German law (e.g., U.S. state consumer-protection statutes, Canadian provincial consumer-protection acts, the UK Consumer Rights Act 2015), those rights remain available to you.

The place of jurisdiction is the courts of Frankfurt am Main; for consumers, the statutory place of jurisdiction applies, and consumers may bring proceedings in the courts of their country of habitual residence to the extent permitted by mandatory local law.

14. Contact Information

For questions about these Terms, please contact us at:

• Support / questions about the service: support@myprisma.app
• Legal / contractual notices / cancellation: info@surplexic.com
• Website: https://myprisma.app/contact

15. Severability

If any provision of these Terms is found to be unenforceable, the remaining provisions will remain in full force and effect.