1. GENERAL INFORMATION

1.1 These terms and conditions (the “Terms and Conditions”), apply to the provision of certain services to you by Tabadulat Limited (“Tabadulat”, “us”, “our”, “we”). These Terms and Conditions, together with any schedules, annexures, Fee Schedule, Privacy Policy and supplemental agreements (each as may be amended from time to time, and collectively the “Agreement”), constitute a binding client agreement between you and Tabadulat for the purposes of the FSRA Rulebook and shall become effective on the date you accept its terms or use Tabadulat’s Services.

1.2 Tabadulat is a company incorporated and registered in the Abu Dhabi Global Market (“ADGM”) with company number 17310, whose registered office is Office 3104, Level 31, Tamouh Tower, Tamouh, Abu Dhabi, Al Reem Island, United Arab Emirates. Tabadulat is an Islamic Financial Institution regulated by the ADGM Financial Services Regulatory Authority under Financial Services Permission Number 250032 for the regulated activities of Dealing in Investments as Principal (Matched) and Shari’a Compliant Regulated Activities.

1.3 This Agreement will come into effect on the date we open your Account, and, for any new versions thereafter, on the date we notify you. This Agreement is supplied to you in English and we will communicate with you in English for the duration of this Agreement.

1.4 This Agreement will govern all Instructions to Deal received from you, and all transactions entered into by us on your behalf and the holding of any money or the instruments bought on your behalf or transferred to us on your behalf.

1.5 All communications and documents will be in English. By opening an Account, you agree to receive investment services and all documents in English. Any local language support or translated documents are for informational purposes only, and the English version will prevail.

1.6 This Agreement contains the information defining our business relationship with you, including the provision to you by Tabadulat of the financial services of dealing in investments as principal (matched-principal only) and the holding of your money or instruments (where relevant).

1.7 Before you invest, you should read the Agreement carefully, including the Risk Disclosure Notice and Privacy Notice and any other documents that we have supplied or in the future do supply to you. If you do not understand any part of this Agreement, you should not enter into it. You can contact us if you are unsure of your rights or obligations under this Agreement once it has been entered into, and where practicable we will aim to assist.

1.8 Our investment service is not suitable for everyone. You can find an explanation of the risks associated with our investment service in our Risk Disclosure Notice which you should read carefully. You can find our Risk Disclosure Notice on our website http://www.tabadulat.com. You should carefully read the provisions in this Agreement and ensure that you have an understanding of any risks before entering into this Agreement and any Transaction with us. If you do not understand anything in this Agreement, any of the risks highlighted in the Risk Disclosure Notice or the financial or tax implications of entering into any transactions with us, you should seek independent professional, legal, financial or tax advice.

1.9 You will be classified as a Retail Client under FSRA Rules. You may request a different classification, but this may result in the loss of protection under certain FSRA Rules. For certain services, you may be classified as a Professional Client under FSRA Rules and will be notified in writing. You can choose to be a Retail Client by notifying Tabadulat in writing within 5 business days of such notification.

1.10 For additional information regarding us, our Services, and other relevant details concerning this Agreement and our Website, please visit www.tabadulat.com. In case of any discrepancy between this Agreement and the information on our Website, this Agreement will prevail.

1.11 In the event that you are granted access to our Platform and website, then all use of such service will be subject both to this Agreement and to any supplemental mobile dealing terms posted on our website and amended from time to time.

1.12 Capitalised terms, words and expressions are defined in Section 31.

2. TABADULAT SERVICES

2.1 Tabadulat will, subject to the terms of this Agreement, provide Shari’a-compliant non-advised execution only, clearing, settlement and client money and Instruments safekeeping for you (collectively the “Services”). Any Services will be provided to you on a matched-principal basis, meaning we will be the counterparty to every transaction you make with us and all transactions are agreed directly between you and Tabadulat.

2.2 Tabadulat shall provide the Services in connection with the establishment and operation of your Account, and you hereby authorised Tabadulat to:
(1) act upon your Instructions to Deal instructions, including, without limitation, the provision of the Platform via mobile application, website or, in the event the mobile application or website is not available, such alternative access channels as Tabadulat may prescribe from time to time to enable you to open or manage your Account;
(2) provide the means for you to fund your Account;
(3) provide the means for you to withdraw from your account to a nominated bank account;
(4) Buy or Sell Instruments products in accordance with your instructions;
(5) transmit instructions to transact in Instruments in accordance with the selections you have made via your Account; and
(6) process any corporate actions, including but not limited to, receiving and distributing dividends, rights issues, stock splits, mergers or similar events.

2.3 Except as agreed in writing with you, we will provide the Services to you and act on your behalf to execute your Instructions to Deal as principal. You will provide us with Instructions to Deal as principal and not as agent for any undisclosed person. This means that unless we have otherwise agreed in writing, we will treat you as our client for all purposes and you will be responsible for performing your obligations under this Agreement and in respect of each Instruction to Deal issued by you or on your behalf and each transaction entered into by us on your behalf, whether you are dealing with us directly or through an agent. If you act in connection with or on behalf of someone else, whether or not you identify that person to us, we will not accept that person as an indirect client of ours and we will accept no obligation to them unless otherwise specifically agreed in writing.

2.4 You authorise Tabadulat to open, manage, and close your Account; to place, modify, or cancel orders for you; and to take any reasonable steps needed to carry out your instructions. Except as expressly provided in this Agreement, no transaction shall be executed in your Account other than pursuant to your own directions or those of your duly authorised agent.

2.5 Your Account is self-directed (also known as “execution-only”) and you are solely responsible for all orders placed. All orders placed by you or by any authorised person acting on your behalf, shall be deemed unsolicited and based exclusively on your own investment decision. Consequently, we are under no obligation:
(1) to satisfy ourselves as to the suitability of any instrument or transaction for you;
(2) to monitor or advise you on the status of any Instruction to Deal;
(3) to monitor or advise you of the status of instruments held by us on your behalf;
(4) (except where the Applicable Regulations require) to cancel any Instructions to Deal or sell any instruments you have purchased and that we hold on your behalf.

2.6 We will not advise you on the merits of any investment or transaction. We do not provide investment, legal, regulatory, tax or any other form of advice therefore you must not consider any suggested investments, strategies, or communications from us as investment recommendations, advice, or an indication of suitability for your financial objectives. All investment decisions related to your Account must be based on your own judgment. Please consult an independent investment or tax adviser if you require such advice.

2.7 We may, at our discretion, provide information:
(1) in relation to any Instrument, Instruction to Deal or Transaction about which you have enquired, particularly regarding procedures and risks attaching to that Instrument, Instruction to Deal or Transaction and ways of minimising risk; and
(2) by way of factual market information, however, we will be under no obligation to disclose such information to you and in the event of us supplying such information it will not constitute investment advice.

2.8 We may add or remove Instruments from the Platform at our sole and absolute discretion and we shall notify you if we remove an Instrument from the Platform that you hold. We shall use reasonable endeavours to ensure that any Instruments available to Buy on the Platform are Shari’a-compliant, are approved by Tabadulat’s Shari’a Supervisory Board and any such Instruments will be made available and subject to your Instructions to Deal via the Platform.

2.9 Should any Instrument purchased via the Platform become non-Shari’a compliant in accordance with the screening methodology approved by Tabadulat’s Shari’a Supervisory Board, you will only be permitted to Sell the Instrument for such time that the Instrument is deemed non-Shari’a-Compliant.

2.10 Tabadulat may offer a Shari’a screening service and any other features or functionality Tabadulat elects to introduce from time to time to assist you in making investment decisions and placing instructions through the Platform.

2.11 All Services shall be delivered in accordance with this Agreement, Applicable Regulations and laws, any rules issued by the relevant regulatory authorities and the rulings of its Shari’a Supervisory Board.

3. ACCOUNT OPENING AND CUSTOMER DUE DILIGENCE

3.1 To apply to open, and to maintain an Account on the Platform you must:
(1) be at least eighteen (18) years of age;
(2) not be domiciled or ordinarily resident in any jurisdiction designated by Tabadulat as restricted or high-risk;
(3) provide Tabadulat satisfactory Know Your Customer (“KYC”) information;
(4) where required, provide such additional information and documentation as Tabadulat may reasonably request;
(5) have no history of being banned, suspended or otherwise having any Account terminated by Tabadulat for any breach of Tabadulat’s Agreement; and
(6) comply with any further requests for information or documentation reasonably made by Tabadulat to ensure adherence to Applicable Regulations, and internal policies.

3.2 Tabadulat shall, prior to the provision of any Services, collect, verify and retain such information and documentary evidence as it deems necessary to satisfy any Applicable Regulations, including but not limited to your identity, national identification number, residency and tax-residency status. Tabadulat may also obtain information regarding your investment profile such as source of wealth, employment, income, risk tolerance, investment experience and objectives at the point of onboarding or prior to any investment activity, and may require the same upon reactivation of an inactive account or at any other time in its sole discretion. Tabadulat may periodically contact you to confirm that its records remain complete and up to date.

3.3 You acknowledge that Tabadulat, its affiliates, agents and third-party service providers may undertake whatever enquiries they consider appropriate to verify the accuracy of the information you furnish in connection with your Account (or the cash or Instruments held in your Account). You hereby authorise Tabadulat and any such agents or service providers to contact any person or entity referenced in your application or in any other information you supply, and to obtain from them any data necessary for verification purposes. Tabadulat may, pending completion of such verification, restrict your access to your Account. You agree to notify Tabadulat promptly of any changes to your personal information, including name, address, e-mail address or telephone number.

3.4 Tabadulat reserves the right, in its sole discretion, to refuse to open or to continue any customer relationship for any reason, including but not limited to failure to complete the account opening or reactivation process or failure to provide any documentation or information required to comply with anti-money laundering, counter-terrorism financing, counter-proliferation financing or other legal or regulatory requirements. Tabadulat shall also conduct ongoing monitoring for the prevention of financial crime, including periodic screening of customers against sanctions lists and other regulatory watchlists in accordance with Applicable Regulations.

4. CLIENT ASSETS AND ACCOUNT FUNDING

4.1 Tabadulat is permitted both to hold and to control client assets on your behalf under FSRA Rules, including Client Money and Client Investments as defined by the FSRA (collectively “Client Assets”). We may, subject to the FRSA’s Client Assets Rules, appoint any other person as Third Party Agent or otherwise to hold Instruments, including documents of title or certificates evidencing title to such Instruments. We will exercise reasonable skill and care in the selection, appointment and periodic review of any Third Party Agent but we are not liable for their acts, omissions, insolvency or dissolution. Any discrepancy in terms of client assets and any resulting shortfall will be dealt with in accordance with the FRSA’s Client Assets Rules.

4.2 You acknowledge and agree that all Client Assets will be held separate from assets belonging to Tabadulat with Third Party Agents. In relation to Client Money, the Third Party Agent will be UAE-licensed banks and Client Money will be held in trust. In relation to Client Assets, the sub-custodian will either be a regulated financial institution or bank.

4.3 You acknowledge and agree that your Client Assets will be maintained on a pooled basis which means that it is not possible to separately identify your Client Assets from that of our other customers, except by using our internal books and records. This means that Tabadulat will maintain books and records that identify your individual ownership and entitlement to Client Assets. For operational and servicing purposes it is more efficient for us to administer your investments on a pooled basis.

4.4 In the event of the Tabadulat’s insolvency, winding-up or other pooling or distribution event as stipulated by the FSRA, your Client Money will be subject to the FSRA’s “Client Money Distribution Rules”, which will govern how Client Money is pooled and returned to clients.

4.5 Where you transfer your Client Assets to Tabadulat and the relevant Third Party Agent is not regulated by the FSRA, you acknowledge and agree that the protections ordinarily afforded to Client Assets held within ADGM may not apply.

4.6 Your Client Assets will be held in an omnibus account together with the assets of other clients, and you understand that there is a risk that, should Tabadulat or the Third Party Agent become insolvent, you may not recover the full amount to which you are entitled. You further acknowledge that such omnibus account may be maintained in a jurisdiction outside ADGM and that the insolvency, settlement and client-asset protections in that jurisdiction may differ materially from those prevailing in ADGM, with the result that your legal rights and the procedures for recovering any shortfall could be less advantageous than if the funds were held in a segregated client-money account within ADGM.

4.7 All income, distributions or other proceeds paid on your Instruments, such as cash dividends or fund distributions, will be reconciled and credited to your account as soon as practicable after receipt (net of any applicable tax for the relevant market).

4.8 At all times your Client Assets will be held in accordance with Shari’a. This means your Client Money will not accrue interest. Your Client Investments will not be lent, pledged, or rehypothecated unless the relevant arrangement has been approved by its Shariʿa Supervisory Board.

4.9 Where appropriate, you authorise us to allow another person such as an Exchange or intermediate broker to hold or control your Client Assets for the purposes of your Transactions through or with that other person.

4.10 You agree that because of the nature of Applicable Regulations or market practices in certain overseas jurisdictions, we may decide that it is in your best interest for your Instruments held with us to be registered or recorded in our name or in the name of the person who is a custodian for the purposes of the FRSA Rules, and if it is not feasible for us to do this, then:
(1) your Instruments may be registered or recorded in the name of the firm or custodian as the case may be;
(2) your Instruments may not be segregated and separately identifiable from the investments of the firm or custodian in whose name your Instruments are registered; and
(3) as a consequence, in the event of a failure, your Instruments may not be as well protected from claims made on behalf of our general creditors.

4.11 You remain the beneficial owner of the Instruments and money that we hold on your behalf and agree that you will not try to sell, mortgage or otherwise deal in or part with beneficial ownership of the Instruments and money held on your account with us. Other than provided for by Applicable Regulations and this Agreement in the event of your default, we have no lien (legal claim) over Instruments that we hold on your behalf and we will not deposit, pledge or charge your Instruments for any loan. Instruments that we hold on your behalf will not be lent to a third party and we will not borrow money against those Instruments.

4.12 All payments to be made under this Agreement are due and payable immediately upon our demand, which may be oral or in writing unless otherwise agreed. Once demanded, such payments must be paid by you, and must be received by us in full in cleared funds on your Account.

4.13 You can initiate a payment using a wire transfer. Tabadulat may at its sole discretion offer additional funding methods. You acknowledge that Tabadulat may incur processing fees, Charges, and other administrative costs for providing your chosen payment method. We reserve the right to apply an additional fee, which will be added to the total transaction value. Before making a payment, you will see the total amount, inclusive of any such fee.

4.14 You must deposit from and withdraw to an account in your legal name. Deposits from and withdrawals to third-party accounts or sources are prohibited.

4.15 Withdrawals and deposits to your account are subject to limitations, including the number of transfers and daily maximum transfer thresholds. Tabadulat reserves the right to modify these limitations periodically.

4.16 You are responsible for ensuring the nominated bank details for withdrawals are correct. Tabadulat will not be liable for any delay, loss or inconvenience caused resulting from your failure to provide the correct information.

4.17 The currency denomination of investments and uninvested cash made available via the Platform can vary depending on the market and Tabadulat’s procedures. The applicable currency will be stated on the Platform. Should you fund your account using a currency other than the stated base currency for the investment being purchased you acknowledge and agree that you are providing an express instruction to Tabadulat convert the remitted amount accordingly and that the resulting balance will be credited to your Account and held on your behalf in that denomination.

4.18 When you submit a withdrawal request, the withdrawal will be processed in the currency stated within the Platform, and you authorise Tabadulat to convert the withdrawn amount accordingly prior to disbursement. The corresponding amount will then be transferred to your designated bank account or payment method.

4.19 The applicable foreign exchange rate used for each conversion will be made available to you at the time the transaction is executed. You acknowledge and agree that this exchange rate may differ from spot rates publicly quoted by currency providers or displayed elsewhere on the Platform, and may be more or less favourable than rates otherwise available at that time.

4.20 You accept that all foreign exchange conversions in connection with funding and withdrawal are undertaken at your sole risk, and you shall bear the cost or benefit of any currency fluctuations between the time of instruction and the completion of the transaction.

4.21 Subject to the terms of this Agreement, money standing to the credit of your account will be remitted to you if requested by you. Where you do not make such a request, we will be under no obligation to, but may, at our discretion, remit such monies to you. All Charges howsoever arising will, unless otherwise agreed, be for your account. The manner in which we remit monies to you will be at our discretion, having utmost regard to our duties under law regarding the prevention of fraud, countering terrorism financing, money laundering and/or tax offences. We will normally remit money in the same method and to the same place from which it was received. However, in exceptional circumstances we may, at our discretion, consider a suitable alternative.

4.22 Where permitted by the Applicable Regulations, if there has been no movement in the balance of your Account for a period of at least twelve (12) years and we have taken reasonable steps to contact you but cannot do so, we may stop treating the cash and Instruments in your Account as Client Assets and may transfer them to or sell them and pay the proceeds to a charity of our choice. Where we do this, we will unconditionally undertake to pay you a sum equal to the value of the Instruments at the time they were sold or transferred if you later contact us to claim these amounts.

5. ORDERS AND INSTRUCTIONS

5.1 You will enter into a Transaction by ‘buying’ or ‘selling’. In this Agreement a Transaction that is entered into by ‘buying’ is referred to as a ‘Buy’; a Transaction that is entered into by ‘selling’ is referred to as a ‘Sell’. A Transaction must always be made for a specified number of Instruments.

5.2 We will provide you with the Buy and Sell prices for Instruments in the Underlying Market.

5.3 You may place different order types on the Platform, including market orders and limit orders. Tabadulat reserves the right to make other types or orders available via the Platform and gives no guarantee that any specific order type will be available at all times.

5.4 All Instructions to Deal must be submitted electronically through the Platform. Any telephone or written instruction, subject to Tabadulat’s verification procedures and internal policy, may be accepted solely at Tabadulat’s discretion. Orders submitted via the Platform will be routed automatically to an execution venue without manual review by Tabadulat personnel. Any order placed from a device or session authenticated with your username, password, biometric login or other security credential will be deemed to have been authorised by you, and you accept full responsibility for that order except where loss arises solely from Tabadulat’s fraud, wilful default or gross negligence, or where Tabadulat is otherwise liable under Applicable Regulations.

5.5 Our quoting of a Buy or Sell price for each Instrument (whether by telephone, Platform, or otherwise) does not constitute an offer to execute your Transaction at those prices on your behalf. An Instruction to Deal will be initiated by you offering to Buy or Sell an Instrument in a specified quantity and with reference to a specific Order type. We will confirm to you whether we have accepted or rejected an Instruction to Deal. The acceptance of an Instruction to Deal will be evidenced by our confirmation of its terms to you.

5.6 You must ensure that every Instruction to Deal is clear, complete and intelligible. If an Instruction to Deal is ambiguous, incomplete or received too late for prompt execution, Tabadulat may, at your cost and for your protection, request clarification, take any action it reasonably considers necessary, or decline to act. Tabadulat may (but is not obliged to) run additional security checks, including challenge questions or multi-factor authentication. Tabadulat is not liable for delays while such verification is in progress.

5.7 Tabadulat is entitled to rely on and act upon any Instruction to Deal it reasonably believes to have been given by you or by a person purporting to act with your authority, without further enquiry as to the genuineness or authority of the sender. You will be bound by any action taken in good faith on that basis.

5.8 We will not be under any duty to attempt to execute any Instruction to Deal or accept and act in accordance with any communication if we reasonably believe that such agent may be acting in excess of its authority. Nothing in this clause will be construed as placing us under a duty to enquire about the authority of an agent who purports to represent you.

5.9 If an Instruction to Deal is accepted, we will confirm to you whether a Transaction results in the Underlying Market, being the partial or full fill of your Instruction to Deal. We will attempt to execute all eligible Instructions to Deal as soon as reasonably practicable. There is no guarantee that your Instruction to Deal will be filled in full or in part in the Underlying Market. Where a delay occurs because we are unable to interact with the relevant Underlying Market for any reason, we will attempt to execute the Instruction to Deal as soon as reasonably practicable.

5.10 The market price of any Instrument may have moved during the time between our receipt and acceptance of your Instruction to Deal and our attempt to execute your Instruction to Deal. In these circumstances, the third party who has provided the quotation to us is not obliged to honour the indicative price you have received and, if that is the case, we may reject your Instruction to Deal. Such movements in price may be in your favour or against you.

5.11 Each Instruction to Deal or Transaction entered into by you will be binding on you notwithstanding that by entering into the Instruction to Deal or Transaction, as applicable, you may have exceeded any limit applicable to you or in respect of your dealings with us.

5.12 Orders are made available to you at our discretion. Not all Orders are available on all Instruments or Underlying Markets and not all Orders are available on all Electronic Trading Services. Orders may operate differently depending on the third party to whom we send your Order.

5.13 It is important that you understand how an Order operates before you place any such Order with us and that you will not place an Order unless you fully understand the terms and conditions attached to such Order. Details about how Orders work are available from our employees on request. You can communicate such request to us either via telephone or email to the contact details we have provided to you or by posting a message on one of our Platform.

5.14 You must use reasonable endeavours to ensure that any Instructions to Deal placed by you with us are consistent with accepted market practice and conduct in the applicable Underlying Market.

5.15 You must ensure that there is sufficient cleared client money available in your Account before any Buy Order is transmitted. Tabadulat shall have no liability for loss or delay arising from an insufficiency of funds; an Order will not be released until the requisite cash balance is available.

5.16 Tabadulat will use reasonable skill, care and diligence in selecting and reviewing brokers, banks, trading platforms and other intermediaries, but will not be liable for any diminution in the value of your holdings resulting from their default unless such loss arises directly from Tabadulat’s own negligence, fraud or wilful default. Any administrative or pricing error made by Tabadulat will be rectified promptly and, so far as practicable, on a basis that is fair to you.

5.17 You expressly authorise Tabadulat to execute transactions on your behalf outside a “regulated market” or multilateral trading facility where Tabadulat deems it necessary to fulfil your Instruction to Deal.

5.18 You may request cancellation of an outstanding order through the Platform; however, an order marked “pending” or similar may already have been executed and, in that event, cancellation will not be possible. However, you agree that Instructions to Deal form a commitment which may only subsequently be revoked by you with our prior consent (such consent will not be unreasonably withheld) at any time before the Instruction to Deal is executed.

5.19 Tabadulat may cancel a transaction, or decline or defer the execution of any order, without prior notice if it reasonably believes that: (i) execution would contravene Applicable Regulations, exchange rules or market practice; (ii) the order forms part of a pattern of excessive, disruptive or trading that could be market abuse; (iii) the relevant instrument is subject to minimum-deal thresholds that are not satisfied; (iv) cleared funds are unavailable; (v) due-diligence or anti-money-laundering checks are outstanding; or (vi) a counterparty, exchange, clearing house or settlement system refuses to process the transaction. Tabadulat shall not be liable for any loss you may suffer as a consequence of such cancellation, rejection or delay, including where such cancellation, rejection or delay is caused by a third party.

5.20 Unless Applicable Regulations prevent us from doing so, we will use our reasonable efforts to tell you our reason for refusing to act on an Instruction to Deal and what you can do to correct that Instruction to Deal.

5.21 If we accept an Order and then an event takes place which means that it is no longer reasonable for us to act on that Order, we will be entitled to disregard or cancel your Order. If we disregard or cancel your Order then we shall not have any liability to you as a result of such action and we shall not re-enter that Order. Examples include but are not limited to:
(1) a change in the Applicable Regulations, so that the Order or the Transaction to which the Order relates is no longer in compliance with the Applicable Regulations;
(2) for Orders relating to Shares, an event takes place in respect of the company whose shares represent all or part of the subject matter of the Order, for example, a corporate event, dividend or the insolvency of the company; or
(3) if we cease to offer the Order you have requested.

5.22 We may be required to cancel a Transaction if requested by an Exchange or may be required to cancel an Instruction to Deal if requested or recommended by an Exchange and you agree to use all reasonable endeavours to assist us in this regard.

5.23 We will ask you to sign the relevant US tax form before we accept an Instruction to Deal from you to Buy an Instrument in relation to Shares listed in the US. If you have not previously provided us with a valid US tax form and you already hold US Shares, we will ask you to complete the relevant US tax form. If you do not return the signed and completed US tax form before the date we specify (usually 30 days), we reserve the right to sell your US Shares. You have an ongoing obligation to inform us if your tax status changes.
If you instruct us to purchase an exchange traded fund or any other Instrument that has a Fund Document we will require that you have read the relevant Fund Document before we execute your Transaction. You should ensure that you have read any applicableFund Document prior to issuing us with an Instruction to Deal. You agree to any Fund Document being provided to you in electronic format (although you may request a paper copy of any Fund Document on our website or Platform).

5.24 Proceeds and securities will be credited to your Account only once received from the counterparty or settlement system. For certain overseas markets a longer settlement cycle may apply, which may delay your ability to withdraw proceeds or redeploy sale proceeds into other Instruments.

5.25 Tabadulat may, at its sole discretion and subject to market availability, facilitate the execution of orders for fractional shares or units of securities (“Fractional Trading”). The provision of Fractional Trading is not guaranteed, and Tabadulat reserves the right to restrict, suspend or discontinue fractional trading in respect of any security or at any time without prior notice.

5.26 When you submit an order for a fractional security, you acknowledge and agree that:
(1) your ownership will be limited to the fractional quantity recorded in Tabadulat’s books and records and may not entitle you to exercise voting rights or receive shareholder communications unless and to the extent Tabadulat elects, in its discretion, to facilitate such rights;
(2) fractional quantities may be rounded to the nearest decimal place permitted by the relevant market infrastructure, which may result in a cash adjustment;
(3) corporate-action treatment (including, without limitation, dividends, rights issues, stock splits and spin-offs) may differ from that applicable to whole shares and, where necessary, Tabadulat may credit cash in lieu of issuing fractional entitlements; and
(4) fractional holdings are not transferable or certificated and must be liquidated through Tabadulat.

5.27 Orders that cannot be executed as fractional orders,whether because fractional trading is not offered for the relevant security or because market conditions prevent execution,will, unless you instruct otherwise, be rejected rather than rounded up or down to the nearest whole share. Tabadulat shall not be liable for any loss arising from the unavailability of fractional trading or from the rejection of any order in accordance with this clause.

5.28 All Transactions are subject to on-going anti-money-laundering and sanctions screening. Tabadulat may postpone or reverse settlement, or request additional documentation, whenever it considers such action necessary to comply with Applicable Regulations.

6. EXECUTION

6.1 As this is Agreement and the Services provided under it are on an execution only basis, Tabadulat is not bound by the FRSA Rules in relation to “best execution” and consequently any Instructions to Deal validly given by you under the terms of this Agreement will take precedence.

6.2 We may aggregate Instructions to Deal received from our clients. Aggregation means that we may combine your Instruction to Deal with those of other clients of ours for execution as a single order. We may combine your Instruction to Deal with those of other clients if we reasonably believe that this is in the overall best interests of our clients as a whole. However, on occasions, aggregation may result in you obtaining a less favourable price once your Instruction to Deal has been executed. We will not have any liability to you as a result of any such less favourable price being obtained.

6.3 You agree that Retail Service Providers may not agree to accept an Instruction to Deal at the prices that they quote from time to time. We reserve the right to cease providing you with quotes from Retail Service Providers, without notice if, in our reasonable opinion, we consider that you are abusing this service or are acting inappropriately in requesting quotes from any Retail Service Provider.

6.4 We may deal through Exchanges and a number of Retail Service Providers and Market Makers. We may place your Instructions to Deal outside of an Exchange. By signing this Agreement, you agree to us entering into Transactions on your behalf outside a regulated market or a Multilateral Trading Facility.

6.5 We may, at our reasonable discretion, arrange for Instructions to Deal to be executed with or through a third party. We will not be liable to you for any act or omission of any such third party, except where we have acted negligently, fraudulently or in wilful default in relation to the appointment of the third party.

7. SETTLEMENT

7.1 Where available, we may use prime brokers and/or central securities depositories for the settlement of the applicable Instruments. The Charges and rates we quote are for Instruments settled by the applicable primer broker or central securities depository. If an Instrument ceases to be able to be settled through the applicable primer broker or central securities depository, you accept that we may have to use alternative dealing facilities to Buy or Sell that Instrument and/ or levy an increased charge for Buying or Selling that Instrument.

7.2 Transactions in European Shares are currently on a T+2 basis (meaning that the Transaction settles with the applicable Underlying Market two business days after it is made). Your Statement shows the trade date. The settlement date cannot be changed once you offer to enter into a Transaction. Most worldwide Shares settle on a T+1 to T+3 basis. Shares dealt on any settlement date greater than T+3 may obtain a worse price than those dealt on a T+3 settlement. We cannot usually accommodate deals for extended settlement beyond a T+10 basis.

7.3 We are not responsible for any delay in the settlement of a Transaction resulting from circumstances beyond our control, or the failure of any other person or party (including you) to perform all necessary steps to enable completion on the settlement date. Our obligation is only to pass on to you, or to credit to your account, such deliverable documents or sale proceeds (as the case may be) as we actually receive. If you are dealing in Instruments that are not settled through a central securities depository system (i.e., residuals), settlement delays are likely to occur.

7.4 We may refuse to allow a withdrawal on any account that you have with us if it would leave insufficient funds in the account to pay for any unsettled Transactions. Where you make payment into your account and then make a withdrawal shortly afterwards, we reserve the right to delay settlement for up to eight business days to ensure your payment has cleared.

7.5 If you Sell an Instrument, the consideration for the Transaction less all applicable costs, including, commission and all applicable fees and Charges set out in the Fee Schedule and taxes for that Transaction will be available on your account for reinvestment prior to settlement and your account will reflect this. However, you will be unable to withdraw this sum from your account until the Transaction has settled. Should the transaction fail to settle, we may reverse the Transaction, return any applicable costs, including, commission and all applicable fees and Charges set out in the Fee Schedule and taxes for that Transaction and cancel the credit of any cash to your account and amend your account to reflect the same.

7.6 If you Buy an Instrument, the consideration for the Transaction and applicable costs, including, commission and all applicable fees and Charges set out in the Fee Schedule and taxes for that Transaction will be deducted from your account, the Instrument will be available for sale on your account prior to settlement of the Transaction and your account will reflect this. However, you will be unable to transfer this Instrument out of your account into your own name or another nominee until the Transaction has settled. Should the Transaction fail to settle, we may reverse the Transaction, return applicable costs, including, commission and all applicable fees and Charges set out in the Fee Schedule and taxes for that Transaction and cancel the debit of any cash from your account and amend your account to reflect the same.

8. VOTING, INTEREST AND CORPORATE EVENTS

8.1 You are solely responsible for instructing Tabadulat in good time if you wish to exercise voting, conversion, subscription or any similar rights, or respond to takeovers, rights issues, spin-offs or other corporate actions. Tabadulat has no obligation to act unless and until it receives your timely instruction.

8.2 If you become entitled to any proceeds (such as dividends) or non-monetary benefits (such as additional Instruments) as a result of any corporate action in relation to the Instruments in your Account, we will take all reasonable steps to collect such proceeds or benefits and credit your Account accordingly.

8.3 Any dividends that you become entitled to may be rounded down to the nearest USD0.01 when allocated to you.

8.4 All income, distributions or other proceeds paid on your Instruments, such as cash dividends or fund distributions, will be reconciled and credited to your account as soon as practicable after receipt (net of any applicable tax for the relevant market).

8.5 At all times your Client Assets will be held in accordance with Applicable Regulations (which includes Shari’a law). This means your Client Money will not accrue interest. Your Client Assets will not be lent, pledged, or rehypothecated unless the relevant arrangement has been approved by Tabadulat’s Shariʿa Supervisory Board.

9. REPORTING

9.1 Tabadulat will make available, in the secure area of the Platform, electronic statements showing all activity, cash balances, fees, and the composition and value of your account. Where your account is active, a statement will be posted at least monthly.

9.2 For every executed trade, Tabadulat will post an electronic confirmation note no later than the two (2) days Business Days days after execution (or, where confirmation is received from a third‐party broker or venue, no later than the two (2) Business Days after it is received by Tabadulat). A separate confirmation will not be provided where the identical information is supplied to you directly by another party.

9.3 Valuations displayed on confirmations and statements represent Tabadulat’s good-faith determination of fair market value, derived from pricing data that Tabadulat reasonably believes to be reliable, which may include prices supplied by custodians, fund managers, pricing agents or recognised market data vendors. Because prices fluctuate with market conditions, the values shown may not reflect amounts that could actually be realised upon sale.

9.4 You must review every confirmation and statement promptly and notify Tabadulat of any objection within two (2) Business Days of the confirmation becoming available otherwise you will be deemed to have agreed with the confirmation of statement. You must review each account statement promptly and notify Tabadulat in writing of any objection within ten (10) days of the statement being posted. An oral objection must be confirmed immediately in writing. Confirmations and statements will be deemed conclusive and binding on you if no timely objection is received. Nothing in this clause limits any legal rights you may have.

9.5 Our failure to provide you with a confirmation or statement does not invalidate nor make voidable a Transaction that you and we have agreed and we have confirmed in accordance with this Agreement, provided however that in the event that you believe you have entered into a Transaction but we have not provided you with a confirmation or statement in respect of that Transaction, any query in relation to the purported Transaction will not be entertained unless:
(1) you notify us that you have not received such statement or confirmation within two business days of the date on which you ought to have received a Statement for the purported Transaction; and
(2) you can provide accurate details of the time and date of the purported Transaction and supporting evidence, to our reasonable satisfaction, of the purported Transaction.

9.6 Tabadulat reserves the right, acting reasonably, to determine the validity of any objection. If you dispute a transaction, you agree to take all reasonable steps to mitigate any resulting loss. Failure to do so will leave you solely responsible for any avoidable losses even if your dispute is ultimately upheld. Tabadulat, its affiliates and service providers shall not be liable for losses, lost profits or other damages arising from a delay or failure to post a confirmation, statement or status update, save where such loss is a direct result of Tabadulat’s fraud, wilful default or gross negligence.

9.7 We may be obliged under Applicable Regulations to make public certain information regarding our Transactions with you. You agree that we will be entitled to disclose such information to relevant regulators such as the FSRA, and/or other authorities and you should understand that such information will be held by us as our sole and exclusive property.

9.8 You must provide us with all information that we may reasonably request for the purpose of complying with our obligations under Applicable Regulations and you consent to us providing to any third party such information about you and your relationship with us pursuant to this Agreement (including but not limited to your Transactions or Client Assets on your account) as we consider, acting reasonably, appropriate or as required to comply with any Applicable Regulations or any term of this Agreement.

9.9 If you are a legal entity, you agree that we may in certain circumstances obtain a Legal Entity Identifier (LEI) on your behalf. You agree that we may do so if we consider that it is necessary in order to allow you to enter into Transactions with us and that we may pass on to you any charge we incur to obtain a LEI on your behalf and to levy an administration charge to cover our costs in doing so. Please contact one of our employees for this information or visit our Website.

10. DELEGATION AND USE OF THIRD PARTIES

10.1 Tabadulat may, in its absolute discretion and without prior notice, delegate, subcontract or otherwise entrust the performance of any duty or obligation arising under this Agreement, in whole or in part, to any affiliate, Third Party Agent, agent, nominee, sub-custodian, broker, registrar, market-data vendor or other third-party service provider it deems appropriate. Such delegation shall not discharge Tabadulat’s overarching responsibility to you for the proper performance of its contractual obligations; however, provided that Tabadulat has exercised reasonable skill, care and diligence in the selection, appointment and ongoing oversight of the relevant delegate, Tabadulat shall bear no further liability for any act or omission of that delegate or for any loss suffered by you as a result of the delegate’s performance or non-performance.

10.2 You cannot assign or transfer any of your rights or obligations under this agreement to any other person without our prior written consent.

11. COMPLAINTS

11.1 If you wish to make a complaint about any service provided under this Agreement, you may contact us by emailing support@tabadulat.com. We will acknowledge receipt promptly and will conduct a fair, timely and confidential investigation in accordance with our Complaint Handling Procedures, which are available free of charge upon request. A final written response, setting out our findings and any proposed redress, will be issued as soon as reasonably practicable. Should there be any delays in resolving your complaint, we will provide you regular updates.

12. CONFLICTS OF INTEREST

12.1 Tabadulat maintains and implements a written Conflicts of Interest Policy in accordance with the FSRA Rulebook We take all reasonable steps to identify, prevent, or where prevention is impracticable, manage conflicts so as to ensure that your interests are not materially adversely affected. If, after applying our controls, we cannot be reasonably confident that the residual risk of detriment has been eliminated, we will disclose to you the general nature and source of the conflict before proceeding with the relevant service or transaction.

12.2 It is important that you understand that we are not under an obligation to disclose that we, our affiliated companies or Relevant Persons have a material interest in a particular Transaction, or that in a particular circumstance a conflict of interest exists, provided we have managed such conflicts in accordance with our Conflicts Policy. Where we do not consider that the arrangements under our Conflicts Policy are sufficient for us to be reasonably confident that we can manage any particular conflict, then as a last resort, we will inform you of the nature of the conflict and any steps taken to mitigate the risk arising from such conflict, so that you can decide how to proceed. We are not under any obligation to account to you for any profit, commission or remuneration made or received from or by reason of Transactions or circumstances in which we, our affiliated companies or a Relevant Person has a material interest or where in particular circumstances a conflict of interest may exist.

12.3 When we are not able to deal with a conflict of interest effectively we may in some circumstances be unable to provide you with the service you require and we shall not be obliged to disclose the reason why or any further information relating thereto.

13. FEES

13.1 Our fees are set out in the Fee Schedule which you can find on our Website www.tabadulat.com. The Fee Schedule forms part of this Agreement and may change from time to time. For material changes we will endeavour to give you reasonable advance notice unless a change must take effect immediately. By keeping your Account open after the effective date of the change you are considered to have accepted the updated fees.

13.2 You authorise Tabadulat to immediately deduct every fee, third-party cost, regulatory levy and tax directly from the cash balance in your Account and any money deducted from your Account shall not be Client Money. Asset holding fees are calculated daily as a percentage of the total value of your cash and Instruments and are collected monthly in arrears.

13.3 If there is not enough cash to meet a fee owed by you we will, without prior notice, sell your Instruments starting with your largest holding and continue until the amount due (and any sale costs) is covered. Whole share or unit quantities may be sold. Where trading restrictions require us to dispose of more than 95 per cent of a holding, we may liquidate the entire position. We will issue you a confirmation note for every sale carried out for fee-collection purposes. Any residual cash left over after the deduction will remain in your cash balance and will be used first to pay the next month’s fees.

13.4 You are responsible for any tax that arises from the deduction or the forced sale of Instruments. Tabadulat will not be liable if a sale occurs at an unfavourable time, alters your portfolio balance or creates a tax exposure.

14. PLATFORM

14.1 You must ensure that your use of the Platform is compliant with this Agreement.

14.2 Tabadulat will, subject to the terms of this Agreement, use commercially reasonable efforts to ensure that the Platform remains available and operational at all times; provided, however, that availability cannot be guaranteed and interruptions or delays may occur, during which Tabadulat may be unable to process your instructions. In the event of any service interruption or delay, Tabadulat will endeavour to notify you and advise on any necessary steps. You may also contact Tabadulat at support@tabadulat.com for assistance.

14.3 We have no obligation to accept, or to subsequently execute, or cancel an Instruction to Deal that you seek to issue to us or cancel through any Platform. Without limitation of the foregoing, we have no responsibility for transmissions that are inaccurate or not received by us, and we may execute any Instructions to Deal on the terms actually received by us.

14.4 You authorise us to act on any instruction given or appearing (in our reasonable opinion) to be given by you using the Security Details and received by us in relation to any Platform you use. We are not obliged to act on any such instruction, or to execute any particular Instruction to Deal, and need not give any reasons for declining to do so. Instructions to Deal that you give form a commitment which may only subsequently be amended or revoked by you with our prior consent (such consent will not be unreasonably withheld) at any time before the Instruction to Deal is executed. You will be responsible for the genuineness and accuracy, both as to content and form, of any instruction received by us.

14.5 You acknowledge we have the right, unilaterally and with immediate effect, to suspend or terminate (at any time, with or without cause or prior notice) all or any part of any Platform, or your access to any Platform, to change the nature, composition or availability of any Platform, or to change the limits we set on the trading you may conduct through any Platform.

14.6 In accordance with this Agreement, all prices shown on any Platform are quotes, are subject to constant change and do not result in the initiation of a Transaction unless the processes in this Agreement are followed.

14.7 Use of any high speed or automated mass data entry system with any Platform will only be permitted with our prior written consent exercised in our discretion.

14.8 In respect of a direct market access system to any Exchange in respect of which you may submit orders or receive information or data using any Platform, you agree that we may require that you provide us with information in relation to you and your use or intended use of this service. You further agree that we may monitor your use of this system, we may require you to comply with certain conditions in relation to your use and may at our discretion remove your access to this service at any time.

14.9 Where we permit electronic communications between you and us to be based on a customised interface using a protocol such as Financial Information Exchange (FIX) protocol, Representational State Transfer (REST) or any other such interface, those communications will be interpreted by and subject to any rules of engagement for such interface protocol that are provided to you.

14.10 You are required to test any customised interface prior to using it in a live environment and you agree you will be responsible for any errors or failure in your implementation of the interface protocol. Use of any customised interface shall be subject to our prior written consent exercised in our discretion.

14.11 Where we grant you access to any Platform we shall grant you, for the term of this Agreement, a personal, limited, non-exclusive, revocable, non-transferable and non-sublicence to use Platform pursuant to and in strict accordance with this Agreement. We may provide certain portions of our Platform under licence from third parties, and you will comply with any additional restrictions on your usage that we may communicate to you from time to time, or that are otherwise the subject of an agreement between you and such licensors.

14.12 We are providing Platform to you only for your personal use and only for the purposes, and subject to the terms, of this Agreement. You may not sell, lease, or provide, directly or indirectly, any Platform or any portion of any Platform to any third party except as permitted by this Agreement. You acknowledge that all proprietary rights in our Platform are owned by us or by any applicable third party licensors or service providers engaged by us to provide any Platform, and are protected under copyright, trademark and other intellectual property laws and other Applicable Regulations. You receive no copyright, intellectual property rights or other rights in or to any Platform, except those specifically set out in this Agreement. You will protect and not violate those proprietary rights in our Platform and honour and comply with our reasonable requests to protect our and our third-party service providers’ contractual, statutory and common law rights in our Platform. If you become aware of any violation of our or our third-party service providers’ proprietary rights in any Platform, you will notify us in writing immediately.

14.13 You will not use any automated software, algorithm or trading strategy other than those that we make available to you on our Platform without our prior written consent. If we agree to allow you to use any such techniques, you agree that we may require you to comply with certain conditions in connection with your use of such techniques and that we may withdraw our consent at any time without prior notice to you.

14.14 In the event that you receive any data, information or software via any Platform other than that which you are entitled to receive pursuant to this Agreement, you will immediately notify us and will not use, in any way whatsoever, such data, information or software.

14.15 You will take all reasonable steps to ensure that no computer viruses, worms, software bombs or similar items are introduced into the System or software you use to access our Platform.

14.16 We and our licensors (as the case may be) will retain the intellectual property rights in all elements of the Software and such software and databases contained within the Platform and you will not in any circumstances, obtain title or interest in such elements other than as set out in this Agreement.

14.17 With respect to any market data or other information that we or any third- party service provider provide to you in connection with your use of any Platform, you agree that:
(1) we and any such provider are not responsible or liable if any such data or information is inaccurate or incomplete in any respect;
(2) we and any such provider are not responsible or liable for any actions that you take or do not take based on such data or information;
(3) Any information or data you receive through the website or Platform is solely for your personal, non-commercial use in connection with your Tabadulat Account;
(4) You will not copy, reproduce, redistribute, retransmit, publish or permit any third party to access data or information provided through the website or Platform;
(5) all real-time and delayed market data (including quotes, last sale information, indices and derived analytics) made available to you through the Platform is provided “as is” and “as available” by Tabadulat and third-party vendors.
(6) you will use such data or information solely for the purposes set out in this Agreement;
(7) such data or information is proprietary to us and any such provider and you will not retransmit, redistribute, publish, disclose or display in whole or in part such data or information to third parties except as required by Applicable Regulations or as agreed between us;
(8) you will use such data or information solely in compliance with the Applicable Regulations;
(9) Neither Tabadulat nor any data provider warrants the accuracy, completeness, timeliness or fitness for any particular purpose of information provided through the website or Platform,
(10)neither Tabadulat nor any data provider shall be liable for any errors, omissions, interruptions or delays in Market Data or for any losses or damages arising therefrom
(11) Tabadulat may at any time modify, restrict or terminate your access to information provided on the website or the Platform, or change data sources or formats, without liability
(12)you will pay such market data Charges and any applicable taxes (if applicable, for direct market access for example) associated with your use of any Platform or use of market data as we inform you from time to time;
(13)you will notify us if you are not or are no longer a non- professional user for market data purposes (further details about the definition of non-professional user are available from one of our employees on request);
(14)we may require that you provide us with information in relation to you and your use or intended use of market data;
(15)we may monitor your use of our market data;
(16)we may require you to comply with certain conditions in relation to your use of market data; and
(17)we may at our discretion remove your access to market data at any time.

14.18 In addition to the above, in respect of certain types of Exchange data that you elect to receive via any of our Platform, you hereby agree to any terms and conditions relating to the redistribution and use of such data that we may provide to you from time to time.

14.19 Certain Exchanges require that their Exchange data will not be viewed or accessed by you on more than one System at any one time. You warrant and represent that you will comply with any restrictions that we apply in relation to your access to the Platform and ability to view Exchange data from time to time.

14.20 Tabadulat may restrict or suspend your access, liquidate positions or close your Account without prior notice if you breach the obligations in this clause.Tabadulat shall bear no liability for any losses, costs or tax consequences incurred as a result of such liquidation or Account closure.

14.21 Tabadulat reserves the right to suspend the provision of any or all Tabadulat Services where it reasonably considers such suspension necessary or appropriate including, without limitation, for technical maintenance, emergency conditions, regulatory compliance, protection of your interests, periods of exceptional market volatility or to preserve the integrity of other services, and will use reasonable endeavours to inform you of any such suspension.

15. YOUR OBLIGATIONS

15.1 You are responsible for securing your Security Details and any device on which the Platform is installed, and for installing all security and software updates as released. You agree to notify Tabadulat immediately and in any event within twenty-four (24) hours, of any loss, theft or unauthorised use of your Security Details or any suspected fraud. Tabadulat may, at its discretion, delay or refuse to act on instructions pending additional verification and shall not be liable for any resulting delay.

15.2 By maintaining an Account, you represent and warrant to us, and agree that each such representation and warranty is deemed repeated each time you enter into a Transaction by reference to the circumstances prevailing at such time, that:
(1) the information provided to us in your application form and at any time thereafter is true and accurate in all respects;
(2) you are duly authorised to execute and deliver this Agreement, to issue Instructions to Deal to us, to instruct us to enter into each Transaction on your behalf, to be the beneficial holder of Instruments and to perform your obligations in relation to each of these matters and have taken all necessary action to authorise the execution, delivery and performance of each of these matters;
(3) you will enter into this Agreement and provide us with instructions as principal;
(4) any person representing you in providing us with instructions will have been, and (if you are a company, partnership or trust) the person entering into this Agreement on your behalf is, duly authorised to do so on your behalf;
(5) you have obtained all governmental or other authorisations and consents required by you in connection with this Agreement and in connection with Buying and Selling and being the beneficial owner of Instruments using our service and such authorisations and consents are in full force and effect and all of their conditions have been and will be complied with;
(6) execution, delivery and performance of this Agreement and Buying and Selling and being the beneficial owner of Instruments using our service will not violate any law, ordinance, charter, by-law or rule applicable to you, the jurisdiction in which you are resident, or any agreement by which you are bound or by which any of your assets are affected;
(7) other than in exceptional circumstances, you will not send funds to your account(s) with us from, or request that funds be sent from your account(s) to a bank account other than that identified in your account opening form or as otherwise agreed by us. Whether exceptional circumstances exist will be determined by us from time to time;
(8) if you are an employee or contractor of a financial services firm or any other firm that has controls over the financial transactions in which its employees and contractors deal, you will give us proper notice of this and of any restrictions that apply to your dealing;
(9) you will not use the prices or market information we make available to you for any purpose other than for your own trading purposes, and you agree not to redistribute the prices we make available to you to any other person whether such redistribution be for commercial or other purposes;
(10) you will use the services offered by us pursuant to this Agreement in good faith and, to this end, you will not use any electronic device, software, algorithm, or any trading strategy or any arbitrage practices (such as but not limited to latency abuse, price manipulation or time manipulation) that aims to manipulate or take unfair advantage of the way in which we make available bid or offer prices. In addition, you agree that using any device, software, algorithm, strategy or practice in your dealings with us whereby you are not subject to any downside market risk will be evidence that you are taking unfair advantage of us;
(11) you will use the services offered by us pursuant to this Agreement in good faith and, to this end, you will not use any electronic device, software, algorithm, or any trading strategy that aims to manipulate or take unfair advantage of any Platform;
(12) you will not use any automated software, algorithm or trading strategy other than in accordance with the terms of this Agreement;
(13) other than as expressly permitted by us, you will not, and will not attempt to, communicate with us electronically via any customised interface using a protocol such as Financial Information Exchange (FIX) protocol, Representational State Transfer (REST) or any other such interface;
(14) you will not submit or request information electronically from us in a manner that is likely to strain or overload the Platform;
(15) you will not and will not attempt to decompile any Platform including any of our web or mobile applications;
(16) you will provide us with all information that we reasonably require to comply with our obligations under this Agreement and you will provide us with any information that we may reasonably request from you from time to time for the purposes of our compliance with Applicable Regulations;
(17) you are, and will at all times remain, in full compliance with all Applicable Regulations, regulations, rules and disclosure requirements of every jurisdiction, Exchange, regulated market, multilateral trading facility, organised trading facility and regulatory authority that applies to Tabadulat, its affiliates or your Instruments;
(18) you are, and will at all times remain, in full compliance with all tax-related legal and reporting obligations in every relevant jurisdiction;
(19) you will not place and have not placed an Instruction to Deal with us that results in a Transaction that contravenes any primary or secondary legislation or other law against insider dealing or market manipulation.
(20) you are, and will at all times remain, in adherence to all anti-bribery, anti-corruption, anti-money-laundering and other financial-crime laws and regulations, and that you will not engage in, facilitate or otherwise undertake any transaction or conduct that could implicate Tabadulat or its affiliates in bribery, corruption, money laundering or any other illicit financial activity; and
(21) where we have provided you with Fund Documents in respect of any relevant Transaction you agree to us providing you with the Fund Documents in electronic format on our Website Platform (you may request a paper copy of any Fund Documents on our Website or Platform) and you should ensure that you have read the relevant Fund Documents before entering into the Transaction;
(22)should any Instrument purchased via the Platform become non-Shari’a compliant in accordance with the screening methodology approved by Tabadulat’s Shari’a Supervisory Board, you will only be permitted to Sell the Instrument for such time that the Instrument is deemed non-Shari’a-Compliant.

15.3 This Agreement contains the entire understanding between the parties in relation to the Services we offer.

15.4 In the absence of our fraud, wilful default or negligence, we give no warranty regarding the performance of our Website(s), our Platform or other software or their suitability for any equipment used by you for any particular purpose.

15.5 You acknowledge that Tabadulat does not provide investment advice, discretionary portfolio management, and any tools, research or educational materials on the Platform are for informational purposes only. You remain solely responsible for your investment decisions, for timely exercising any rights attached to your holdings and for ensuring that you have sufficient cleared funds or available securities to settle all transactions. In the event of any unpaid obligation, Tabadulat may liquidate positions without notice to satisfy your indebtedness, and you will bear all resulting losses, costs and tax liabilities.

16. EVENTS OF DEFAULT

16.1
Each of the following constitutes an ‘Event of Default’:

(1) your failure to make any payment to us in accordance with the terms of this Agreement;
(2) your failure to perform any obligation due to us;
(3) where any Instruction to Deal or Transaction or combination of Instructions to Deal and/or Transactions or any realised or unrealised losses on your account with us results in your exceeding any limit placed on your dealings with us;
(4) if you are an individual, your death or your incapacity;
(5) the initiation by a third party of proceedings for your bankruptcy (if you are an individual) or for your winding-up or for the appointment of an administrator or receiver in respect of you or any of your assets (if you are a company) or (in both cases) if you make an arrangement or composition with your creditors or any other similar or analogous procedure is commenced in respect of you;
(6) where any representation or warranty made by you in this Agreement, including but not limited to the representations and warranties is or becomes untrue;
(7) you are or become unable to pay your debts as and when they fall due;
(8) you have committed, or we have reasonable grounds for suspecting that you have committed, fraud or any other offence or been deceitful in your dealings with us in relation to your account with us under this Agreement;
(9) you are in material or persistent breach of any term of this Agreement;
(10) you are abusive, threatening or or exhibit violent conduct, whether verbal, written, electronic or physical, directed at Tabadulat, its officers, employees, contractors or other clients; or
(11) any other circumstance where we reasonably believe that it is necessary or desirable to take any action in accordance with this clause to protect ourselves or all or any of our other clients.

16.2
If an Event of Default occurs in relation to your Account(s) with us, we may, at our discretion, at any time and without prior notice take any one or any number of the below steps:

(1) convert any currency balances on your account into another currency;
(2) exercise rights of set-off, retain any funds, Instruments (including payment payable thereon) or other assets due to you or held on your behalf, and sell them without notice to you at such price and in such manner as we, acting reasonably, decide, applying the proceeds of sale and discharging the costs of sale and the sums secured under this clause;
(3) charge you for all reasonable legal and administrative costs and expenses incurred by us;
(4) treat any outstanding proposed Transaction or Instruction to Deal as having been cancelled and terminated;
(5) close all or any of your accounts held with us of whatever nature, remit any monies owing to you and sell any Instruments or other assets held on your behalf and remit the cash balance to you subject to any rights of set-off and any rights under this clause and refuse to accept any further Instructions to Deal from you; and
(6) terminate this Agreement in accordance with the terms of this Agreement.

16.3
If we take any action under this clause, unless at our reasonable discretion we consider it necessary or desirable to do so without prior notice to you, we may, where reasonably possible, take steps to advise you before exercising such rights. However, any failure on our part to take such steps will not invalidate the action taken by us under clause.

16.4
In the event of your being in excess of any limit placed on your dealings with us, we may at our discretion allow you to continue to Buy and Sell Instruments, but this will depend on our assessment of your financial circumstances. You acknowledge that, if we agree to allow you to continue to Buy or Sell Instruments you may incur further losses.

16.5
In Selling any Instruments held by us on your behalf under this clause, it may be necessary for us to ‘work’ the order. This may have the result that the Instruments held on your behalf are sold in tranches at different prices, resulting in an aggregate closing price for your Instrument that results in further losses being incurred on your account. We will not have any liability to you as a result of any such ‘working’ of your Instruments held by us on your behalf.

16.6
You further agree that Tabadulat shall bear no liability for any losses, costs or tax consequences incurred as a result of such liquidation or Account closure. Tabadulat shall bear no liability for any losses, costs or tax consequences incurred as a consequence of Tabadulat taking any action pursuant to this clause.

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17. EXCEPTIONAL EVENTS, MARKET DISRUPTION EVENTS AND THIRD PARTY OR INFRASTRUCTURE EVENTS

17.1
We may, in our reasonable opinion, determine that an Exceptional Event, Market Disruption Event or Third Party or Infrastructure Event has occurred. We have set out some examples of ‘Exceptional Events’, ‘Market Disruption Events’ and ‘Third Party or Infrastructure Events’ in the Definitions and Interpretation section of this Agreement.

17.2
If we determine that an Exceptional Event, Market Disruption Event or Third Party or Infrastructure Event exists we may, acting reasonably:
(1) treat any outstanding proposed Transaction or Instruction to Deal as having been cancelled and terminated;
(2) Sell any Instruments held by us on your behalf at the prevailing market price, at our discretion; or
(3) suspend or modify the application of all or any of the terms of this Agreement to the extent that the Exceptional Event, Market Disruption Event or Third Party or Infrastructure Event makes it impossible or impracticable for us to comply with the Term or Terms in question; or
(4) in the case of an Exceptional Event, Market Disruption Event or Third Party or Infrastructure Event which has occurred and has continued for a period of five (5) Business Days, terminate this Agreement.

17.3
If we exercise any of our rights under this clause, we will use our reasonable endeavours to inform you as soon as possible.

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18. SUSPENSION AND INSOLVENCY

18.1
We reserve the right to suspend your Account or a specific Instruction to Deal that you have in progress with us at a sole and absolute discretion. If we suspend an Instruction to Deal, it means that:

(1) you will only be permitted to Buy or Sell the Instruments subject to the suspended Instruction to Deal; and
(2) in relation to the suspended Instruction to Deal, you will no longer be permitted to deal with us via our Platform, but you will be required to deal with us via the phone.

18.2
The circumstances where we may decide to exercise our discretion to suspend your Account or a specific instruction to Deal, include:

(1) you have failed to provide us with any evidential documents we have requested to confirm your identity and financial condition in the context of our customer due diligence (which includes indicatively the ‘Know Your Customer’ process (also known as ‘KYC’), anti-money laundering assessment and an evaluation of your financial condition);
(2) we have considered that the maintenance of an account with us will not be suitable for you, for example, on the basis of our assessment of your identity or your financial condition;
(3) there is a court order and/or any other legal proceedings pending before any authority in relation to your trading activity with us;
(4) we have detected fraudulent activity associated with your account;
(5) there is suspected or actual fraud or security threats associated with any of your accounts with us;
(6) there are debts due in respect of any of your accounts with us; and
(7) where your Account has a balance of less than [USD5] for 90 days.

18.3
If at any time trading on the Underlying Market is suspended in any Instrument that forms the subject of an Instruction to Deal, then the applicable Instruction to Deal will also be suspended and you will not be able to Sell any Instruments we hold on your behalf.

18.4
Irrespective of any Orders given by you, the Instruction to Deal will remain suspended and you will not be able to Sell any Instruments we hold on your behalf until either of the following takes place:

(1) the suspension in the Underlying Market is terminated and trading recommences, at which point the suspension of your Instruction to Deal will also cease and you will be able to Sell any Instruments we hold on your behalf. Following the lifting of the suspension, any Instructions to Deal that you may have given us with respect to the Instrument that have been triggered will be executed as soon as we consider reasonable in the circumstances having regard to liquidity in the Underlying Market. We cannot guarantee that Instructions to Deal will be executed at the first available Underlying Market price; or

(2) where the Instrument is in respect of a company, that company is delisted from the Underlying Market, goes into insolvency or is dissolved, at which point your Instruction to Deal will be cancelled and any Instruments we hold on your behalf will be dealt with in accordance with the terms of the delisting, insolvency or dissolution, as applicable.

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19. COMMUNICATIONS AND CALL RECORDING

19.1
You hereby consent to Tabadulat and its affiliates recording and retaining all telephone conversations, electronic communications, system access logs, transaction data and any other interactions between you and Tabadulat or its personnel. Such recordings and records shall be and remain the exclusive property of Tabadulat, and may be used by Tabadulat in any manner it deems appropriate, including as evidence in any legal or regulatory proceeding. You agree that any such recording or record shall be admissible and given full evidentiary weight equivalent to an original written document, and you irrevocably waive any right to challenge or contest the admissibility, reliability, completeness, accuracy or authenticity of such recordings or records. Recordings and records made by Tabadulat shall constitute conclusive proof of the matters recorded and shall be binding on you.

19.2
If you have any questions about this Agreement with us or need to contact us about your Account(s), you can contact us by email at support@tabadulat.com or, to the extent that it is available to you through our Platform. We do not offer customer support over the telephone.

19.3
By agreeing to this Agreement and using our Services, you agree to us providing you with information about us and/or our Services on our website, by email, or in the Platform, as we consider appropriate.

19.4
If we need to contact you or send or return to you any documents, statements or notices, we will usually email you at the address you've given us and/or send you a notification in the Platform. We may also contact you in other ways, including by telephone or post using the details you gave us when opening your Account. We will always communicate with you in English.

19.5
It is important that you regularly check your emails and the Platform for any communications from us. If any of your contact details change, please let us know as soon as possible through our Platform or by emailing us at support@tabadulat.com.

19.6
You acknowledge the inherent risk that communications by electronic means may not reach their intended destination or may do so later than intended for reasons outside our control. By entering into this Agreement, you are accepting this risk and you agree that a failure or delay by us to receive any offer or communication from you sent electronically, whether due to mechanical, software, computer, telecommunications or other electronic systems failure, does not in any way invalidate or otherwise prejudice that offer or communication or any transaction to which it relates. If, for any reason, we are unable to accept your offer electronically, we may, without obligation, provide you with further information advising you that your offer can be made by telephone as an alternative and we may endeavour to inform you of this.

20. PROMOTIONS

20.1
By participating in any Tabadulat promotional program, you thereby agree to be bound by and subject to all of the terms, conditions, limitations and requirements of that specific program, and acknowledge that Tabadulat may at any time modify, suspend or terminate the program or your eligibility for rewards.

21. YOUR INFORMATION AND DATA

21.1
Tabadulat may collect, use and store any personal information you supply, including “Personal Data” and “Sensitive Personal Data” within the meaning of the ADGM Data Protection Regulations 2021 (as amended) together with data generated by transactions we execute on your behalf. We process this information strictly in accordance with our Privacy Policy available on our Website and with the consent you give by entering into this Agreement.

22. CONFIDENTIALITY

22.1
We and you undertake to not (a) disclose to any person any Confidential Information except as permitted by this clause; and (b) use any Confidential Information for any purpose other than to exercise any rights and perform any obligations under or in connection with this Agreement.

22.2
We and you may disclose Confidential Information:
(1) to such of our or your employees, officers, representatives, advisers or trading partners who need to know such Confidential Information for the purposes of exercising any rights or carrying out any obligations under or in connection with this Agreement, provided that we and you shall ensure that such employees, officers, representatives or advisers are bound by confidentiality undertakings consistent with this Agreement;
(2) as may be required by law, mandatory Applicable Regulations, a credit reporting agency, a court of competent jurisdiction or any governmental or regulatory authority; and
(3) as permitted in the Privacy Policy.

23. TAXATION

23.1
You acknowledge that Tabadulat does not provide financial, legal, tax or investment advice. You are solely responsible for obtaining independent advice from a suitably qualified professional concerning the tax consequences of opening or maintaining a Tabadulat Account, holding or disposing of any investment, or otherwise transacting through the Platform. All tax liabilities that arise in relation to your Account, including any income, capital-gains, dividend or withholding taxes, remain entirely your responsibility, and you agree to pay all such amounts when due. Levels of taxation and the availability of reliefs may change without notice and will depend on your individual circumstances.

23.2
Under applicable international exchange-of-information regimes Tabadulat may be required to collect, verify and, where obliged, report information about your tax residency and certain details of your Account. Tabadulat may disclose this information to the UAE Federal Tax Authority or other competent authority, which may in turn exchange it with the tax authority of a jurisdiction with which the UAE has a relevant information-sharing agreement.

23.3
Should any change in the basis or scope of taxation occur at any time which results in us having to withhold amounts on account of taxes owed or payable by you in respect of any Applicable Regulations in respect of your Transactions or your Account with us, we reserve the right to deduct the amount of any such payment(s) from your Account or otherwise require you to pay or reimburse us for such payment(s).

24. LIABILITY

24.1
You are responsible for all reasonable liabilities, losses or costs of any kind or nature whatsoever that may be incurred by us as a result of any failure by you to perform any of your obligations under this Agreement, in relation to any Instruction to Deal received from you, Transaction that we execute on your behalf or in relation to any false information or declaration made either to us or to any third party, in particular to any Exchange. Your responsibility extends to paying our reasonable legal and administrative costs and expenses incurred in respect of taking any legal or investigatory action against you, or instructing any debt collection agency, to recover monies owed by you to us.

24.2
Tabadulat shall perform its obligations and operate the Platform with the reasonable skill, care and diligence expected of a prudent Shariʿa-compliant matched-principal broker who provides services similar to the Services.

24.3
Except as required by law, Tabadulat’s liability to you is limited to direct losses that are the reasonably foreseeable and proximate result of Tabadulat’s own negligence, wilful default or material breach of a mandatory FSRA Rule.

24.4
Nothing in this Agreement excludes or limits Tabadulat’s liability for death or personal injury resulting from its negligence or for any liability that cannot be excluded by Applicable Regulations.

24.5
Tabadulat shall not be liable for any loss of profits, loss of business or opportunity, loss of goodwill, reputational damage, or any indirect, special, consequential, exemplary or punitive losses of any kind.

24.6
Tabadulat shall not be liable for losses arising from your investment decisions, including the selection, acquisition, retention or disposal of any security or other investment held in your Account.

24.7
Tabadulat shall not be liable for any action taken or omitted in good-faith reliance upon an instruction believed to have been validly given by you or your duly authorised representative.

24.8
Tabadulat shall not be liable for any loss caused by the default, insolvency or misconduct of any Third Party Agent, Exchange, bank, custodian, sub-custodian, clearing system, market venue, fund manager or other third party holding or administering your assets, except to the extent directly caused by Tabadulat’s negligence in selecting or supervising that party.

24.9
Tabadulat shall not be liable for any loss resulting from fluctuations in market prices or the performance of any Instrument or class of Instruments.

24.10
Tabadulat shall not be liable for any tax liability, duty, levy or regulatory charge arising in respect of your Account or the assets held therein.

24.11
Tabadulat shall not be liable for any losses, liabilities, judgments, suits, actions, proceedings, claims, damages and/or costs suffered by you, resulting from or arising out of any act or omission by any person obtaining access to your account by using your designated account number, user name, password and/or Security Details, whether or not you authorised such access unless this results from our own negligence, fraud or wilful default.

24.12
Tabadulat shall not be liable for any instruction you give that is not received by Tabadulat, is received late, or is received in an incorrect or ambiguous form.

24.13
Tabadulat shall not be liable for any delay, suspension or failure to provide services or execute transactions caused by any Exceptional Events, Market Disruption Events or Third Party or Infrastructure Events.

24.14
Tabadulat shall not be liable for any other failure or delay in the Platform, provided it has exercised reasonable skill and care in selecting and supervising its technology and service-provider partners.

24.15
The Platform and any associated mobile application, including any Shari’a screening service, are provided “as is” and “as available,” without warranty of uninterrupted, error-free or timely access, or freedom from viruses or other harmful code and Tabadulat shall not be liable for any losses you incur from the same.

24.16
Certain information in relation to our services is provided by third parties and we are not liable for any inaccuracy, errors or omissions in the information they provide us except where such inaccuracy, error or omission is caused by our own negligence, fraud or wilful default in relation to the appointment of that third party.

24.17
Tabadulat may suspend or restrict Platform access at its discretion for maintenance, upgrades, Shariʿa-compliance checks or security enhancements, and will endeavour to schedule interruptions outside normal trading hours but may act urgently during trading hours if necessary.

24.18
Tabadulat shall have no liability should any Instrument purchased via the Platform become non-Shari’a compliant in accordance with the screening methodology approved by Tabadulat’s Shari’a Supervisory Board, and you agree you will only be permitted to Sell the Instrument for such time that the Instrument is deemed non-Shari’a-Compliant.

24.19
Tabadulat may offer a Shari’a screening service and any other features or functionality Tabadulat elects to introduce from time to time to assist you in making investment decisions and placing instructions through the website or Platform and Tabaulat shall have no liability for any decision you make based on the information or data you receive through the Shari’a screening service or other functionality provided through the website or Platform.

24.20
You acknowledge that internet and telecommunications systems are inherently subject to outages and delays beyond Tabadulat’s control, and Tabadulat shall not be liable for any loss resulting from such outages.

24.21
The Platform may contain links to third-party websites, over which Tabadulat has no control and for which it disclaims all liability for any loss or damage arising from your use of or reliance on such sites.

24.22
Tabadulat may employ automated systems for order entry, execution, record-keeping, reporting and risk management; you accept the risks of system failures, and Tabadulat shall not be liable for any loss arising from such failures so long as it has implemented reasonable security measures and oversight.

24.23
Tabadulat’s aggregate liability to you under this Agreement, whether in contract, tort (including negligence), breach of duty or otherwise, shall not exceed the total fees paid by you to Tabadulat in the twelve (12) months immediately preceding the event giving rise to the claim, except for liability for death, personal injury, fraudulent misrepresentation or any other liability which cannot be excluded by law.

24.24
Nothing in this Agreement shall exclude or restrict any liability which cannot be excluded in accordance with Applicable Regulations.

25. AMENDMENTS TO THIS AGREEMENT

25.1
Tabadulat may update these Terms from time to time. We will give you reasonably advanced written notice for you to read the proposed changes before they take effect.

25.2
If you do not agree with a proposed change, you may close your Account and end the Agreement without exit fees, provided you tell us before the change becomes effective.

25.3
Some updates may take effect immediately, and we will notify you as soon as they are made. Immediate changes will typically only be made when they:
(1) reflect changes in applicable laws;
(2) making this Agreement clearer;
(3) implement decisions by a relevant court, regulator or similar body;
(4) correct an obvious error without reducing your rights;
(5) update our contact details;
(6) reduce the costs we charge you or otherwise benefit you; or
(7) introduce a new system, process, product, or technology that does not disadvantage you.

25.4
Any amended agreement will supersede any previous agreement between us on the same subject matter and will govern any Instruction to Deal issued or outstanding and each Transaction entered into or outstanding on or after the date the new edition comes into effect and any Instruments held on your behalf after, or on, the date the new edition comes into effect.

26. TERMINATION AND SUSPENSION OF YOUR ACCOUNT

26.1
You may close your Tabadulat Account and end this Agreement at any time by giving us at least thirty (30) calendar days’ written notice. Closure takes effect when that notice expires or once we have all information and documents we reasonably require to complete the process.

26.2
Tabadulat may terminate this Agreement and close your Account on not less than thirty calendar days’ written notice, unless a shorter period is required or permitted by Applicable Regulations.

26.3
You may terminate this Agreement immediately by written notice (including e-mail) if we commit a material breach of the Agreement that, where capable of remedy, is not corrected within fourteen calendar days of a written request.

26.4
The Agreement will also terminate automatically if Tabadulat ceases to be authorised by the Financial Services Regulatory Authority of the Abu Dhabi Global Market to perform the regulated activities needed to provide the Services, or if an insolvency or winding-up order is made against Tabadulat.

26.5
We may immediately terminate this Agreement with you if:
(1) an Exceptional Event, Market Disruption Event or Third Party or Infrastructure Event has occurred and has continued for a period of 5 business days; or
(2) an Event of Default has occurred or is continuing.

26.6
In the event of termination you authorise Tabadulat retain or debit from your Account:
(1) all fees, costs and Charges accrued to the date of termination,
(2) any additional, reasonable costs necessarily incurred in giving effect to the closure,
(3) any losses that arise in settling or concluding outstanding obligations.

26.7
On receipt or issue of a termination notice we will ask for your instructions regarding the cash and Instruments in your Account. If you do not provide instructions within a reasonable time, Tabadulat may act reasonably in your interests by liquidating the portfolio at prevailing market prices and sending the cash to your nominated bank account in your name.

26.8
Where, following a termination, Instruments are sold, you may suffer a shortfall between the amount you invested and the amount you get back after sale. We are not responsible for any shortfall that arises. Any shortfall will be borne by you. Where Instruments cannot be sold, redeemed or transferred, we will certificate the Instruments at your cost and distribute these certificates to you. This Agreement will continue until we have transferred, sold, redeemed or otherwise distributed the Instruments or paid you the proceeds.

26.9
Termination does not prejudice the completion of transactions already entered into; any trade executed but not yet settled will complete in the ordinary course. All rights, obligations and liabilities that have accrued before the effective date of termination will survive, as will any provision that by its nature is intended to continue, such as those dealing with definitions, interpretation, liability, data-protection, taxation, governing law, dispute resolution and these termination provisions themselves.

27. ASSIGNMENT

27.1
Tabadulat may at any time assign, novate or otherwise transfer any of its rights or obligations under this Agreement, in whole or in part, to any affiliate or suitably regulated third party. If you object to a proposed assignment, you may terminate this Agreement with immediate effect by giving written notice to support@tabadulat.com before the transfer becomes effective. This Agreement binds and inures to the benefit of your heirs, personal representatives, successors and permitted assignees. You may not assign or transfer any rights or obligations hereunder without Tabadulat’s prior written consent.

28. EVENT OF DEATH

28.1
In the event of your death, we will deal with your Account as instructed by your personal representatives once we have satisfactorily received evidence that they have the authority to give us instructions.

28.2
Upon notification of your death, Tabadulat will freeze your Account and suspend all dealing instructions until we have received:
(1) an official death certificate
(2) formal evidence of the personal representative’s authority; or
(3) in the case of an estate subject to Shari’a succession rules, a valid letter from a court detailing how your estate will be distributed.

28.3
Once satisfactory documentation has been received, the duly appointed personal representative may, in accordance with Sharīʿa principles where applicable, instruct Tabadulat to sell, transfer, redirect or otherwise deal with the cash and Instruments in the Account and to distribute the net proceeds to the lawful heirs or beneficiaries.

28.4
Platform fees will continue to accrue on the portfolio until all assets and cash have been realised and paid to, or transferred at the direction of, the personal representative for distribution to the beneficiaries in accordance with the Applicable Regulations of succession.

29. GOVERNING LAW AND DISPUTE RESOLUTION

29.1
This Agreement will be governed by and construed in accordance with the laws of the ADGM.

29.2
Any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity or termination, will be subject to the exclusive jurisdiction of the Courts of the DIFC. For disputes under USD 100,000 in value, the parties agree to exclusively hear the matter in the Small Claims Division at the ADGM Courts.

30. MISCELLANEOUS

30.1
Our records, unless shown to be wrong, will be evidence of your dealings with us in connection with our services. You will not object to the admission of our records as evidence in any legal or regulatory proceedings because such records are not originals, are not in writing or are documents produced by a computer. You will not rely on us to comply with your record keeping obligations, although records may be made available to you on request at our discretion.

30.2
Unless a term of this Agreement provides otherwise, a person who is not a party to this Agreement will have no rights to enforce any of its terms.

30.3
The copyrights, trademarks, database and other property or rights in any information distributed to or received by you from us, together with the contents of our Platform, website, brochures and other material connected with our dealing service and in any database that contains or constitutes such information, will remain our sole and exclusive property, or the sole and exclusive property of any third party identified as being the owner of such rights.

30.4
Our rights and remedies under this Agreement will be cumulative, and our exercise or waiver of any right or remedy will not preclude or inhibit the exercise of any additional right or remedy. Our failure to enforce or exercise any right under this Agreement will not amount to a waiver or bar to enforcement of that right.

30.5
If, at any time, any term of this Agreement is found to be unlawful, invalid or unenforceable in any jurisdiction, that finding will not affect the legality, validity or enforceability of the remaining terms, nor will it render the same term unlawful, invalid or unenforceable in any other jurisdiction.

30.6
All products and services referenced on the Platform are made available solely in those jurisdictions where their distribution and sale are lawful. Nothing contained on the Website or within the Platform constitutes, or should be construed as, an offer to sell, or a solicitation of an offer to buy, any Instrument or service in any territory where such offer or solicitation would be unlawful.

31. DEFINITIONS

31.1
References to clauses, sections and schedules are references to clauses, sections and schedules to this Agreement.

31.2
Headings are included for ease of reference only and shall not affect the interpretation of this Agreement.

31.3
Any words following the terms “including”, “include”, “in particular”, “for example” or any similar expression shall be interpreted as illustrative and shall not limit the meaning of the words, description, definition, phrase, or term used before those terms.

31.4
Any reference to any regulation, legislative act, or rule is a reference to such Act as from time to time amended, consolidated or re-enacted (with or without modification) and includes all instruments or orders made under such enactment.

‘Account’ means the account you open to Buy, Sell or hold cash and Instruments on our Platform;

‘Applicable Regulations’ means:
(a) the FRSA Rules;
(b) rules of a relevant regulatory authority;
(c) the rules of the relevant Exchange;
(d) the rules of the relevant settlement system;
(e) the decisions, determinations, rulings or orders of Tabadulat’s Shari’a Supervisory Board; and
(f) all other applicable laws (including Shari’a law), rules and regulations as in force from time to time, as applicable to this Agreement, any Instruction to Deal, any Transactions, the holding of Instruments by us on your behalf on our Platform;

‘Authorised Person’ has the meaning given in the FRSA Rules but broadly includes Tabadulat and any other person authorised under the FSRM;

‘Base Currency’ is the currency listed in your Account as your base currency.

‘Buy’ means to enter into a Transaction by buying an Instrument, as further described in [ • ];

‘Charges’ any transaction or account costs, fees or other charges including asset holding fees, notified to you from time to time;

‘Commission’ is the charge you will need to pay to us when you enter into a Transaction in an Instrument. This charge is calculated as a percentage of the value of the Transaction or as an amount per Instrument or Instruments or on any other basis agreed between ourselves in writing;

‘Confidential Information’ includes, but is not limited to, information about our or your business (including any operations, processes, products and technology), affairs, trading, transactions, strategies, customers, clients and suppliers, but excludes information that:
(a) is or becomes public knowledge other than as a result of any breach of this Agreement;
(b) is lawfully within our possession before receiving such information from you;
(c) is lawfully within your possession before receiving such information from us; or
(d) is received by us or you without any obligation of confidentiality;

‘Client Assets’ has the meaning given to it under the FRSA Rules;

‘Client Assets Rules’ means the provisions of the FRSA Rules that relate to assets held by us from clients;

‘Client Investment’ has the meaning given to it under the FRSA Rules;

‘Client Money’ has the meaning given to it under the FRSA Rules;

‘Client Money Rules’ means the provisions of the FRSA Rules that relate to money received by us from clients;

‘Exceptional Event’ means any event or circumstance which is not within our reasonable control, and could include:
(a) acts of God, flood, drought, earthquake or other natural disaster; or
(b) any act, event or occurrence (including without limitation any strike, riot or civil commotion, act of terrorism, war, industrial action, acts and regulations of any governmental or supra national bodies or authorities) that, in our opinion, prevents us from providing you with access to a market in one or more of the Instruments in respect of which we ordinarily provide our services;

‘Exchange’ means any securities exchange, clearing house, self-regulatory organisations, alternative trading system, organised trading facility, or Multilateral Trading Facility as the context may require from time to time;

‘FRSA’ means the Financial Services Regulatory Authority or any organisation that will replace the FRSA or take over the conduct of its affairs;

‘FRSA Rules’ means the rules of the FRSA as from time to time varied, amended or substituted by the FRSA;

‘FSRM’ means the Financial Services and Markets Regulations 2015 (as amended, supplemented or replaced from time to time).

‘Fund Document’ means any prospectus, offering memorandum or equivalent document issued in relation to an exchange traded fund.

‘Instruction to Deal’ means an instruction given or appearing to be given by you electronically via our Platform or by such other means as we may from time to time notify to you, for us to Buy or Sell any Instrument on your behalf including, for the avoidance of doubt, an Order;

‘Instrument’ includes, but is not limited to, any Share, Sukuk, Murabaha Deposit or other investment trust, unit trust or other security or investment which is Shari’a-compliant and approved by Tabadulat’s Shari’a Supervisory Board in respect of which we offer to deal in Transactions;

‘Limit Order’ means an order to buy or sell a specific Instrument at a specified price limit or better. For example, an instruction to sell an Instrument at a price that is higher than the current Underlying Market price or an instruction to buy an Instrument at a price that is lower than the current Underlying Market price;

‘Market Disruption Event’ means:
(a) the suspension or closure of any market or the abandonment or failure of any event or the imposition of limits or special or unusual terms on the trading in any such market in relation to any Instruments in respect of which we ordinarily provide our services; or
(b) the occurrence of an excessive movement in the price of any Instrument or our anticipation (acting reasonably) of the occurrence of such a movement;

‘Market Maker’ means a firm that provides on request buy and sell prices for an Instrument;

‘Multilateral Trading Facility’ means a multilateral system, operated by an FSRM authorised person or an FSRM recognised Investment Exchange, which brings together multiple third-party buying and selling interests in Financial Instruments, in the system and in accordance with non-discretionary rules, in a way that results in a contract in accordance with its rules.

‘Order’ means any order supported by us or the relevant Exchange that we make available to you;

‘Platform’ means any electronic services (together with any related software or application) accessible by whatever means we offer including without limitation trading, direct market access order routing or information services that we grant you access to or make available to you either directly or through a third party service provider, and used by you to view information and/or issue Instructions to Deal and ‘Platform’ shall mean any one of those services;

‘Risk Disclosure Notice’ means the notice which you can find on our website, [insert URL], in compliance with FRSA Rules regarding the risks associated with Buying and Selling Instruments under this Agreement;

‘Retail Client’ has the meaning given to this term in the FSRA Rules, but in broad terms means an individual or undertaking (for example, a company, partnership, trust or other legal entity) which is afforded with the highest degree of consumer protection under the Applicable Regulations;

‘Retail Service Provider’ means a firm that provides on request buy and sell prices for an Instrument with a view to dealing an Instrument or foreign exchange;

‘Relevant Person’ has the meaning given to it in the FSMR and in particular includes a person (natural or otherwise) who has been or is or is proposed to be a director or “controller” of Tabadulat; or has been or is an employee of Tabadulat.

‘Security Details’ means one or more user identification codes, digital certificates, passwords, authentication codes, API keys, or such other information or devices (electronic or otherwise), to enable your access to any Platform;

‘Sell’ means to enter into a Transaction by selling an Instrument, as further described in [ • ];

‘Share’ means any equity shares, exchange traded commodities and exchange traded funds;

‘System’ means all computer hardware and software, applications, equipment, network facilities and other resources and facilities needed to enable you to the Platform;

‘Third Party Agent’ has the meaning given to it in the FRSA Rules as amended from time to time, and currently means in relation to an Account, a financial institution including a bank, custodian, an intermediate broker, a settlement agent, a clearing house, an exchange and “over the-counter” counterparty acting in the capacity of a third party agent, the identity of which shall be notified to you from time to time;

‘Third Party or Infrastructure Event’ means:
(a) any breakdown or failure of transmission, communication or computer facilities, interruption of power supply, or electronic or communications equipment failure, provided that such events are not within our reasonable control; or
(b) failure of any relevant supplier, intermediate broker, agent or principal of ours, custodian, sub-custodian, broker, exchange, clearing house or regulatory or self-regulatory organisation, for any reason, to perform its obligations;

‘Transaction’ means the partial or full fill of your Instruction to Deal;

‘Underlying Market’ means an Exchange, Market Maker, Retail Service Provider and/or other similar body and/or liquidity pool on which an Instrument is traded or trading as the context requires.

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Introduction:

Tabadulat Limited (“we,” “us,” or “our”) values your privacy and is committed to protecting your personal data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you interact with our services, website, platform, or applications.

1. Who We Are

1. Company Name: Tabadulat Limited
2. Registered Office: Office 3104, Level 31 Al Tamouh Tower Al Reem Island,  Abu Dhabi United Arab Emirates
3. Email: privacy@tabadulat.com
4. Website: www.tabadulat.com

2. What Data We Collect

We collect personal and business-related data either directly from you, through third parties, or automatically. This may include:

• Identity Data – Full name, nationality, date of birth, copies of identification documents such as your passport, which may also indicate ID numbers, sex, photographs or other descriptions of your likeness
• Contact Details – Email, phone number, residential address.
• KYC/Onboarding Information – Proof of address, tax ID, live selfie, source of funds/wealth.
• Transactional Data – Your transactions on our platform, payment and banking details.
• Technical Data – IP address, device ID, browser type, operating system, access times.
• Usage Data – Interaction with our website, portal, or app features.
• Communications – Records of correspondence, chat, or customer support.
• You may also provide us with information when you fill out other forms, enter competitions or promotions, respond to surveys, get referred, create goals, add images, or communicate with us by phone, email, text message, or through our live chat feature.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this does not directly or indirectly reveal your identity.

We do not collect sensitive personal data unless explicitly required and consented to.

3. Links to other websites

Our website or platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

4. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and if you fail to provide that data when requested, we may not be able to perform the contract and may therefore be unable to provide you with one or more of our products or services.

5. What we do with your information

We only process your data where permitted under ADGM Data Protection Regulations and for legitimate purposes. We use the information we collect from you to deliver, protect and continually improve the services we provide.

Most commonly we will process your personal data in order to:

• provide you with Tabadulat’s Shariah-compliant investment services. We use your data in this way under the lawful bases of contract performance and legitimate interests to provide our services;
• permit your participation in any Tabadulat promotions, referral programmes or newsletter subscription, under the lawful bases of contract performance and legitimate interests to provide our services and keep you informed;
• confirm that your details are correct under the lawful bases of contract performance, legal obligations and substantial public interest (fraud prevention)
• prevent fraud, money laundering, terrorist financing, proliferation financing, market abuse, or other financial crimes. Where personal information includes biometric data, this is processed by third party suppliers who undergo thorough due diligence checks to ensure compliance with applicable data protection regulations. The lawful basis for this processing is legal obligations and substantial public interest (fraud prevention);
• conduct ongoing monitoring of your transactions and account activity, screening against watchlists and fraud databases. This may involve requesting additional information or temporarily suspending account activity where required. This processing falls under the lawful basis of legal obligations and substantial public interest (fraud prevention);
• process payments to and from your Tabadulat account using regulated payment processors, banks, and custodians under the lawful basis of contract performance;
• engage with third party providers for provision of your account. We may share your personal data, usage data and any other relevant information under the lawful basis of contract performance. Where a third party is involved in the provision of an account you have signed up for, this will be made clear in the Terms that are presented to you. You are responsible for checking the privacy policy of any such third parties so that you can be informed of how they will handle personal information;
• enable us to identify instances where you may benefit from additional support or assistance in the management of your account under the legal bases of contract performance, legal obligations and legitimate interests;
• enhance your individual user experience, for instance by enabling us to offer suitable products to you from us under the lawful basis of legitimate interest;
•  improve and optimise our service through analytics and search engine providers under the lawful basis of legitimate interests. We, or our partner providers, may also use cookies to collect information about you and use personal data to provide personalised advertisements to provide you with a good experience while you use our service. This usage falls under the lawful basis of legitimate interests. See our Cookie Policy for more information;.
•  Analyse your personal data and service interactions, under our legitimate interests, to research, refine and enhance our products and deliver tailored insights on your account;
• Inform you of any necessary information or changes to the products you use with Tabadulat under the lawful basis of contract performance;
• Monitor your electronic communications with us for training and monitoring purposes, including telephone conversations, email, instant messaging and any other electronic communications to the extent permitted by law, under the lawful bases of legitimate interests and legal obligations;
• Share your personal data as required to meet legal or regulatory obligations, enforce our agreements, or respond to requests, inquiries, or investigations by regulatory bodies or law enforcement authorities in jurisdictions where compliance is mandatory. This includes exchanging your information with third-party organisations for fraud prevention and credit risk management purposes. Where allowed, we will forward requests to you or provide advance notification, unless notifying you could hinder the prevention or investigation of criminal activities. This processing is under the lawful bases of legal obligations, legal claims and legitimate interests
• process your personal data in other situations where necessary for our legitimate interests (or those of a third-party provider), provided these interests do not outweigh your fundamental rights and interests. Where possible or required, we will inform you beforehand if your data will be used in ways not previously described.

6. How we share your information

How we share your information
We may share your personal data with:

Regulators and authorities – such as FSRA, ADGM, UAE Central Bank, or foreign regulators.
Service providers and partners – cloud platforms, verification vendors, online chat, IT providers.
Professional advisors – legal, audit, or consulting firms.
Affiliates and subsidiaries, where applicable.
Third parties involved in mergers, acquisitions, or business transfers.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes.

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7. Cross-Border Data Transfers

Your personal data may be transferred outside the ADGM. Where such transfers occur, we ensure that appropriate safeguards are in place.

8. Data Retention

We only keep your personal data for as long as needed to achieve the purpose for which it was collected, and to meet legal, accounting, or reporting obligations.

The type and sensitivity of the data.
The risk of harm from unauthorized use or disclosure.
The reasons we process your data and if we can achieve those reasons differently.
Relevant laws and regulations.

We might keep your data longer if there's a complaint, or if we anticipate legal action related to our relationship with you.

9. Your Rights

You have the following rights:

• Right to Access - You can request a copy of the personal data we hold about you.
• Right to Rectification - You can ask us to correct any inaccurate or incomplete data.
• Right to Erasure - You can request that we delete your personal data under certain circumstances.
• Right to Object - You can object to certain types of processing, including direct marketing.
• Right to Data Portability - You can request that we transfer certain personal data to you or another data controller. This right only covers automated data you consented to us using or data we used to fulfill a contract with you.
• Right to Withdraw Consent - If processing is based on your consent, you can withdraw it at any time.

To exercise any of these rights, please contact us at privacy@tabadulat.com.

Additionally, you have the right to lodge a complaint with the Office of Data Protection Commissioner (ODPC) in ADGM if you believe your data protection rights have been violated.

10. Cookies and Tracking

Our website and apps may use cookies and similar technologies to enhance your user experience. You may manage your cookie preferences through your browser settings

11. Data Security

We take your privacy seriously and apply industry-standard security measures to protect your data, including:

• HTTPS encryption

• Secure server storage

• Limited access to personal data

We implement appropriate technical and organizational measures to secure your data and retain your email only for as long as necessary to fulfill the purpose for which it was collected or to comply with legal obligations.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any updates will be posted on this page, with an updated Effective Date. Continued use of the website means you accept the new terms.

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Introduction:

Tabadulat Limited (“we,” “us,” or “our”) values your privacy and is committed to protecting your personal data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you interact with our services, website, platform, or applications.

1. Who We Are

1. Company Name: Tabadulat Limited
2. Registered Office: Office 3104, Level 31 Al Tamouh Tower Al Reem Island, Abu Dhabi United Arab Emirates
3. Email: privacy@tabadulat.com
4. Website: www.tabadulat.com

2. What Data We Collect

We collect personal and business-related data either directly from you, through third parties, or automatically. This may include:

• Identity Data – Full name, nationality, date of birth, copies of identification documents such as your passport, which may also indicate ID numbers, sex, photographs or other descriptions of your likeness
• Contact Details – Email, phone number, residential address.
• KYC/Onboarding Information – Proof of address, tax ID, live selfie, source of funds/wealth.
• Transactional Data – your transactions on our platform, payment and banking details.
• Technical Data – IP address, device ID, browser type, operating system, access times.
• Usage Data – Interaction with our website, portal, or app features.
• Communications – Records of correspondence, chat, or customer support.
• You may also provide us with information when you fill out other forms, enter competitions or promotions, respond to surveys, get referred, create goals, add images, or communicate with us by phone, email, text message, or through our live chat feature.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this does not directly or indirectly reveal your identity.

We do not collect sensitive personal data unless explicitly required and consented to.

3. Links to other websites

Our website or platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

4. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and if you fail to provide that data when requested, we may not be able to perform the contract and may therefore be unable to provide you with one or more of our products or services.

5. What we do with your information

We only process your data where permitted under ADGM Data Protection Regulations and for legitimate purposes. We use the information we collect from you to deliver, protect and continually improve the services we provide.

Most commonly we will process your personal data in order to:

• provide you with Tabadulat’s Shari’a Compliant investment services. We use your data in this way under the lawful bases of contract performance and legitimate interests to provide our services;
• permit your participation in any Tabadulat promotions, referral programmes or newsletter subscription, under the lawful bases of contract performance and legitimate interests to provide our services and keep you informed;
• confirm that your details are correct under the lawful bases of contract performance, legal obligations and substantial public interest (fraud prevention)
• prevent fraud, money laundering, terrorist financing, proliferation financing, market abuse, or other financial crimes. Where personal information includes biometric data, this is processed by third party suppliers who undergo thorough due diligence checks to ensure compliance with applicable data protection regulations. The lawful basis for this processing is legal obligations and substantial public interest (fraud prevention);
• conduct ongoing monitoring of your transactions and account activity, screening against watchlists and fraud databases. This may involve requesting additional information or temporarily suspending account activity where required. This processing falls under the lawful basis of legal obligations and substantial public interest (fraud prevention);
• process payments to and from your Tabadulat account using regulated payment processors, banks, and custodians under the lawful basis of contract performance;
• engage with third party providers for provision of your account. We may share your personal data, usage data and any other relevant information under the lawful basis of contract performance. Where a third party is involved in the provision of an account you have signed up for, this will be made clear in the Terms that are presented to you. You are responsible for checking the privacy policy of any such third parties so that you can be informed of how they will handle personal information;
• enable us to identify instances where you may benefit from additional support or assistance in the management of your account under the legal bases of contract performance, legal obligations and legitimate interests;
• enhance your individual user experience, for instance by enabling us to offer suitable products to you from us under the lawful basis of legitimate interest;

Introduction:

Tabadulat Limited (“we,” “us,” or “our”) values your privacy and is committed to protecting your personal data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you interact with our services, website, platform, or applications.

1. Who We Are

1. Company Name: Tabadulat Limited
2. Registered Office: Office 3104, Level 31 Al Tamouh Tower Al Reem Island, Abu Dhabi United Arab Emirates
3. Email: privacy@tabadulat.com
4. Website: www.tabadulat.com

2. What Data We Collect

We collect personal and business-related data either directly from you, through third parties, or automatically. This may include:

• Identity Data – Full name, nationality, date of birth, copies of identification documents such as your passport, which may also indicate ID numbers, sex, photographs or other descriptions of your likeness
• Contact Details – Email, phone number, residential address.
• KYC/Onboarding Information – Proof of address, tax ID, live selfie, source of funds/wealth.
• Transactional Data – your transactions on our platform, payment and banking details.
• Technical Data – IP address, device ID, browser type, operating system, access times.
• Usage Data – Interaction with our website, portal, or app features.
• Communications – Records of correspondence, chat, or customer support.
• You may also provide us with information when you fill out other forms, enter competitions or promotions, respond to surveys, get referred, create goals, add images, or communicate with us by phone, email, text message, or through our live chat feature.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this does not directly or indirectly reveal your identity.

We do not collect sensitive personal data unless explicitly required and consented to.

3. Links to other websites

Our website or platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

4. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and if you fail to provide that data when requested, we may not be able to perform the contract and may therefore be unable to provide you with one or more of our products or services.

5. What we do with your information

We only process your data where permitted under ADGM Data Protection Regulations and for legitimate purposes. We use the information we collect from you to deliver, protect and continually improve the services we provide.

Most commonly we will process your personal data in order to:

• provide you with Tabadulat’s Shari’a Compliant investment services. We use your data in this way under the lawful bases of contract performance and legitimate interests to provide our services;
• permit your participation in any Tabadulat promotions, referral programmes or newsletter subscription, under the lawful bases of contract performance and legitimate interests to provide our services and keep you informed;
• confirm that your details are correct under the lawful bases of contract performance, legal obligations and substantial public interest (fraud prevention)
• prevent fraud, money laundering, terrorist financing, proliferation financing, market abuse, or other financial crimes. Where personal information includes biometric data, this is processed by third party suppliers who undergo thorough due diligence checks to ensure compliance with applicable data protection regulations. The lawful basis for this processing is legal obligations and substantial public interest (fraud prevention);
• conduct ongoing monitoring of your transactions and account activity, screening against watchlists and fraud databases. This may involve requesting additional information or temporarily suspending account activity where required. This processing falls under the lawful basis of legal obligations and substantial public interest (fraud prevention);
• process payments to and from your Tabadulat account using regulated payment processors, banks, and custodians under the lawful basis of contract performance;
• engage with third party providers for provision of your account. We may share your personal data, usage data and any other relevant information under the lawful basis of contract performance. Where a third party is involved in the provision of an account you have signed up for, this will be made clear in the Terms that are presented to you. You are responsible for checking the privacy policy of any such third parties so that you can be informed of how they will handle personal information;
• enable us to identify instances where you may benefit from additional support or assistance in the management of your account under the legal bases of contract performance, legal obligations and legitimate interests;
• enhance your individual user experience, for instance by enabling us to offer suitable products to you from us under the lawful basis of legitimate interest;

Cookies Policy

This Cookies Policy explains how Tabadulat Limited uses cookies and similar technologies when you visit our website or use our online services.

1. What are cookies?

Cookies are small text files placed on your device when you visit a website. They allow us to recognise your device, store preferences, and improve your overall experience. Some cookies are necessary for the site to function, while others help us understand how you use our services and tailor them to you.

2. What types of cookies do we use?

● Strictly necessary cookies:
These cookies are essential for our website and platform to work properly. They enable core functions such as secure login and account management.

● Performance and analytics cookies:
These help us understand how visitors use our website, measure traffic, and identify areas for improvement. We may use trusted tools such as Google Analytics for this purpose.

● Functionality cookies:
These cookies allow us to remember your preferences (e.g., language settings) and personalise your experience.

● Marketing cookies (where applicable):
We may use cookies to deliver more relevant marketing messages based on your browsing habits, but only where permitted by law and, if required, with your consent.

3. Third-party cookies

Some cookies are set by third-party service providers we work with. These include:

• Tuemilio – used for our waitlist management system to securely track referrals and email submissions.
• Google Analytics – used to analyse website traffic and user behaviour.
• Email marketing tools – which track engagement with communications we send you (e.g. open and click rates).

These third parties may use cookies to collect information about your online activities over time and across different websites.

4. How we obtain your consent

When you first visit our website, you will see a banner asking you to accept or manage your cookie preferences. By continuing to browse or selecting “Accept all”, you consent to the use of cookies as described in this policy.
You can change your cookie preferences at any time by revisiting the banner or through your browser settings.

You can update your cookie preferences at any time by using the consent banner available on our website.

5. How to manage your cookie preferences

You can set your browser to refuse or delete cookies at any time. Please note that if you disable cookies, some parts of our website may not function properly.

Most browsers allow you to control cookies through their settings. The “Help” or “Settings” section of your browser will provide details on how to adjust your cookie preferences.

6. Updates to this Cookies Policy

We may update this Cookies Policy from time to time to reflect changes in technology, the services we provide, or legal requirements. Any updates will be posted on this page with a revised date.

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