TERMS AND CONDITIONS

eFinno is owned and operated by Streams Financial Services LTD, a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus

Securities and Exchange Commission (CySEC), with CIF license number 376/19 and company registration number HE 387124, located at

16th June 1943, Gladstonos Court No16, Office 101, 3022, Limassol, Cyprus

16th June 1943, Gladstonos Court No16,

Office 101, 3022, Limassol, Cyprus

TERMS AND CONDITIONS

Please Read the Terms and Conditions stated below. They govern the relationship between Streams Financial

Services LTD (herein the "Company”) a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus

Securities and Exchange Commission (CySEC) with CIF license number 376/19, Company registration number HE

387124 and its Clients.

1. Introduction

1.1. This Agreement is entered by and between the Company and the Client (which may be a legal entity or

a natural person) who has completed the Account Opening Application Form and has been accepted

by the Company as a Client.

1.2. The Company is authorized and regulated by the Cyprus Securities and Exchange Commission (“CySEC”)

as a Cyprus Investment Firm (CIF) to offer certain Investment Services under the Applicable Laws and

Regulations, as defined below and as subsequently amended or replaced from time to time. It is

registered in Cyprus, under the Companies Law with registration number HE 387124. the Company’s

registered office’s location is at 16th June 1943, Gladstonos Court No16, Office 101, 3022, Limassol,

Cyprus.

1.3. This Client Agreement and following the below information, as amended from time to time: "Client

Categorisation Policy”, "Investor Compensation Fund”, "Conflicts of Interest Policy”, "Best Interest and

Order Execution Policy”, "Risk Disclosure and Warnings Notice”, “Privacy Policy”, "Complaints

Handling Policy”, “Cookies Policy” (together, the "Agreement”) set out the terms upon which the

Company will offer Services to the Client. In addition, the various documents above set out the matters

which the Company is required to disclose to the Client under the Applicable Laws and Regulations.

1.4. The Agreement overrides any other agreements, arrangements, express or implied statements made by

the Company or any Introducer(s).

1.5. The Agreement shall be binding upon and shall inure to the benefit of the parties and their permitted

successors and assigns. In particular, if the Client is non-face-to-face and all communication with the

Client is done through he website, over the telephone or via written correspondence (including email),

then the Distance Marketing of Financial Services Law N.242(I)/2004 applies. The said law does not

require the Agreement to be physically signed by either the Client or the Company in order for both of

the Parties to be legally bound by it. The terms contained in the Agreement shall apply to the initial as

well as to any subsequent activity entered into between the Company and the Client.

eFinno is owned and operated by Streams Financial Services LTD, a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus

Securities and Exchange Commission (CySEC), with CIF license number 376/19 and company registration number HE 387124, located at

16th June 1943, Gladstonos Court No16, Office 101, 3022, Limassol, Cyprus

16th June 1943, Gladstonos Court No16,

Office 101, 3022, Limassol, Cyprus

1.6. You hereby expressly acknowledge and agree that: (a) by completing and submitting to the Company

the Account Opening Application Form and/or by clicking on the appropriate space or on “I have read

and agree to the Terms and Conditions” statement or any similar buttons/confirmation statements

designated to show us your approval and acceptance of this agreement and/or (b) by accessing or

using and/or by continuing to access or use the services provided by the Company, you fully agree to

abide by and to be bound by all the Terms and Conditions set our in the agreement, as they may apply

to you.

1.7. If your signature or acknowledgement is required/requested with respect to any documentation and

you “click” in the appropriate space, or on the “Accept”/”Submit” buttons, or any other similar buttons

in this respect showing your approval and acceptance thereof, you will be deemed to have “signed”

and/or acknowledged the document to the same extent and with the same effect as if you had signed

the document manually. Further to this, to the extent permitted under applicable mandatory law, you

hereby waive any rights or requirements under the applicable laws/regulations of any jurisdiction

which require an original (non-electronic) signature or delivery or retention of non-electronic records.

Despite this, upon prior written notice to the Company, you have the right to withdraw your consent

to the electronic delivery and signature of documentation that we may provide to you, however, upon

such withdrawal the Company may, at its sole discretion and without any obligation to provide any

further explanations, restrict or terminate the business relationship.

1.8. For your benefit and protection, please ensure you take sufficient time to read the Agreement as well

as any other additional documentation and information available to you via the Company’s website

prior to opening an account and/or carrying out any activity with us. You should contact us for any

further clarification or seek independent professional advice (if necessary).

2. Interpretation of Terms

In this Agreement:

"Access Data” shall mean the Login and Password of the Client, which are required so as to have access

on and use the Platform(s), the telephone password which is required so as to place Orders via phone

and any other secret codes issued by the Company to the Client.

"Account Opening Application Form” shall mean the application form/questionnaire completed by the

Client in order to apply for the Company’s Services under this Agreement and a Client Account, via

which form/questionnaire the Company will obtain, among other things, information for the Client’s

identification and due diligence, his categorization and appropriateness or suitability (as applicable) in

accordance with the Applicable Laws and Regulations.

eFinno is owned and operated by Streams Financial Services LTD, a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus

Securities and Exchange Commission (CySEC), with CIF license number 376/19 and company registration number HE 387124, located at

16th June 1943, Gladstonos Court No16, Office 101, 3022, Limassol, Cyprus

16th June 1943, Gladstonos Court No16,

Office 101, 3022, Limassol, Cyprus

"Affiliate” shall mean in relation to the Company, any entity which directly or indirectly controls or is

controlled by the Company, or any entity directly or indirectly under common control with the

Company; and "control” means the power to direct or the presence of ground to manage the affairs

of the Company or entity.

"Agreement” shall mean this "Client Agreement” together the following policies traced on the

Company’s website: Client Categorisation Policy, Investor Compensation Fund, Conflicts of Interest

Policy, Best Interest and Order Execution Policy, Risk Disclosure and Warnings Notice, Complaints

Handling Procedure, Cookies Policy and Privacy Policy, as amended from time to time.

"Applicable Laws and Regulations” shall mean the Cyprus Law 87(I)/2017 regarding the provision of

investment services, the exercise of investment activities and the operation of regulated markets as

subsequently amended or replaced from time to time, implementing “MiFID II” in Cyprus Law,

Regulation (EU) 600/2014 (MiFIR), as the same may be subsequently amended or modified from time

to time but also in general:

a) CySEC Rules or any other rules of a relevant regulatory authority having powers over the

Company;

b) The Rules of the relevant Market;

c) All other applicable laws, rules and regulations of Cyprus or of the European Union.

"Ask” shall mean the higher price in a Quote at which the price the Client may buy.

"Authorized Representative” shall mean the person of paragraph 12.2 and 38 Of the Client Agreement.

"Balance” shall mean the total financial result in the Client Account after the last Completed

Transaction and depositing/withdrawal operation at any period of time.

"Base Currency” shall mean the first currency in the Currency Pair against which the Client buys or

sells the Quote Currency.

"Bid” shall mean the lower price in a Quote at which the Client may sell.

"Business Day” shall mean any day, other than a Saturday or a Sunday, or the 25th of December, or

the 1st of January or any other Cyprus or International holidays.

"Client Account” shall mean the unique personalized account of the Client consisting of all Completed

Transactions, Open Positions and Orders in the Platform, the Balance of the Client funds and

deposit/withdrawal transactions of the Client funds.

"Closed Position” shall mean the opposite of an Open Position.

eFinno is owned and operated by Streams Financial Services LTD, a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus

Securities and Exchange Commission (CySEC), with CIF license number 376/19 and company registration number HE 387124, located at

16th June 1943, Gladstonos Court No16, Office 101, 3022, Limassol, Cyprus

16th June 1943, Gladstonos Court No16,

Office 101, 3022, Limassol, Cyprus

"Completed Transaction” in a CFD shall mean two counter deals of the same size (opening a position

and closing a position): buy then sell and vice versa.

"Contract for Difference” ("CFD”) shall mean a contract, which is a contract for differences by

reference to variations in the price of an Underlying Asset. A CFD is a Financial Instrument.

"Contract Specifications” shall mean the principal trading terms in CFD (for example Spreads, Swaps,

Lot Size, Initial Margin, Necessary Margin, Hedged Margin, the minimum level for placing Stop Loss,

Take Profit and Limit Orders, financing charges, charges etc.) for each type of CFD as determined by

the Company from time to time.

"Currency of the Client Account” shall mean the currency that the Client Account is denominated in,

which may be Euro or US Dollars, or any other currency as offered by the Company from time to time.

"Currency Pair” shall mean the object or Underlying Asset of a CFD Transaction based on the change

in the value of one currency against the other. A Currency Pair consists of two currencies (the Quote

Currency and the Base Currency) and shows how much of the Quote currency is needed to purchase

one unit of the Base Currency.

"CySEC” shall mean the Cyprus Securities and Exchange Commission, which is the Company’s

supervisory authority.

"CySEC Rules” shall mean the Rules, Directives, Regulations, Guidance notes, opinions or

recommendations of CySEC.

"Equity” shall mean the Balance, plus or minus, and Floating Profit or Loss which derives from an Open

Position and shall be calculated as: Equity = Balance + Floating Profit ‐ Floating Loss.

"Essential Details” shall mean the required details in order for the Company to be able to place the

Order, for example but not limited to; the type of Financial Instrument, the type of Order, type of

Underlying Asset, if the Client places a Pending Order (limit or stop) the Client will indicate the

intended price in which the Order will go in the market and any Stop Loss and or Take Profit etc.

"Event of Default” shall have the meaning given in paragraph 15.1. of the Client Agreement.

"Expert Advisor (EA)” shall mean a mechanical online trading system designed to automate trading

activities on an electronic trading platform. It can be programmed to alert the Client of a trading

opportunity and can also trade his account automatically managing all aspects of trading operations

from sending orders directly to the Platform to automatically adjusting stop loss, trailing stops and

take profit levels. The Company does not provide such a feature for clients and any use of such is

prohibited. EA also refers to automatically copying trades from other traders, brokers and/or trading

eFinno is owned and operated by Streams Financial Services LTD, a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus

Securities and Exchange Commission (CySEC), with CIF license number 376/19 and company registration number HE 387124, located at

16th June 1943, Gladstonos Court No16, Office 101, 3022, Limassol, Cyprus

16th June 1943, Gladstonos Court No16,

Office 101, 3022, Limassol, Cyprus

automatically via third party Signal Providers. The Company may at, its sole discretion, cancel and/or

suspend any Client Account should the use of any EA be suspected or identified.

"Financial Instrument” shall mean the Financial Instruments under the Company’s CIF license which

can be found in the document "Company Information”.

"Floating Profit/Loss” in a CFD shall mean current profit/loss on Open Positions calculated at the currentQuotes

(added any commissions or fees if applicable).

"Force Majeure Event” shall have the meaning as set out in paragraph 28.1 of the Client Agreement.

"Free Margin” shall mean the amount of funds available in the Client Account, which may be used to

open a position or maintain an Open Position. Free Margin shall be calculated as: Equity less (minus)

Necessary Margin [Free margin = Equity‐ Necessary Margin].

"Hedged Margin” for CFD trading shall mean the necessary margin required by the Company so as to

open and maintain Matched Positions.

"Initial Margin” for CFD trading shall mean the necessary margin required by the Company so as to

open a position.

"Introducer” shall have the meaning as set put in paragraph 37.1 of the Client Agreement.

"Leverage” for CFD trading shall mean a ratio in respect of Transaction Size and Initial Margin. 1:100

ratio means that in order to open a position, the Initial Margin is one hundred times less than the

Transactions Size.

"Long Position” for CFD trading shall mean a buy position that appreciates in value if underlying

market prices increase. For example, in respect of Currency Pairs; buying the Base Currency against

the Quote Currency.

"Lot” shall mean a unit measuring the Transaction amount specified for each Underlying Asset of a

CFD.

"Lot Size” shall mean the number Underlying Assets in one Lot in a CFD.

The 1 (one) standard lot size is the measurement unit specified for each CFD. The Company may offer

standard lots, micro‐lots and mini‐lots, in its discretion, as defined from time to time in the Contract

Specifications or the Company’s Website.

"Margin” shall mean the necessary guaranteed funds so as to open or maintain Open Positions in a

CFD Transaction.

eFinno is owned and operated by Streams Financial Services LTD, a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus

Securities and Exchange Commission (CySEC), with CIF license number 376/19 and company registration number HE 387124, located at

16th June 1943, Gladstonos Court No16, Office 101, 3022, Limassol, Cyprus

16th June 1943, Gladstonos Court No16,

Office 101, 3022, Limassol, Cyprus

"Margin Call” shall mean the situation when the Company informs the Client to deposit additional

Margin when the Client does not have enough Margin to open or maintain open positions.

"Маrgin Level” for CFD trading shall mean the percentage of Equity to Necessary Margin ratio.

It is calculated as: Margin Level = (Equity / Necessary Margin) x 100%.

"Margin Trading” for CFD trading shall mean Leverage trading when the Client may make Transactions

having less funds on the Client Account in comparison with the Transaction Size.

"Matched Positions” for CFD trading shall mean long and Short Positions of the same Transaction Size

opened on the Client Account for the same CFD.

"Necessary Margin” for CFD trading shall mean the necessary margin required by the Company so as

to maintain Open Positions.

"Normal Market Size” for CFD trading shall mean the maximum number of units of the Underlying

Asset that are transmitted by the Company for execution.

"Open Position” shall mean any open option contract (call and / or put) which has not been closed. In

relation to CFD trading this may be a Long Position or a Short Position which is not a Completed

Transaction.

"Order” shall mean an instruction from the Client to trade in CFDs as the case may be.

"Parties” shall mean the parties to this Client Agreement –i.e. the Company and the Client.

"Platform” shall mean the electronic mechanism operated and maintained by the Company, consisting

of a trading platform, computer devices, software, databases, telecommunication hardware,

programs and technical facilities, which facilitates trading activity of the Client in Financial Instruments

via the Client Account.

"Politically Exposed Persons” shall mean:

a) Natural Persons who are or have been entrusted with prominent public functions, which means:

Heads of State, Heads of government, Ministers and Deputy or Assistant Ministers; Members of

Parliaments or similar legislative bodies; members of the governing bodies of political parties;

Members of Supreme Courts, of Constitutional Courts or of other high‐ level Judicial Bodies

whose decisions are not subject to further appeal, excluding exceptional circumstances;

Members of Courts of Auditors or of the Boards of Central Banks; Ambassadors, Chargés

d’Affaires and High‐ranking Officers in the armed forces; Members of the Administrative,

Management or Supervisory Bodies of State‐owned enterprises; Directors, Deputy Directors and

eFinno is owned and operated by Streams Financial Services LTD, a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus

Securities and Exchange Commission (CySEC), with CIF license number 376/19 and company registration number HE 387124, located at

16th June 1943, Gladstonos Court No16, Office 101, 3022, Limassol, Cyprus

16th June 1943, Gladstonos Court No16,

Office 101, 3022, Limassol, Cyprus

Members of the Board or equivalent function of an international organisation; Mayors. None of

the categories set out in the above shall be understood as covering middle ranking or more

junior officials. Furthermore, where a person has ceased to be entrusted with a prominent public

function within the meaning of the above definition for a period of at least one year in any

country, such persons shall not be considered a Politically Exposed Person.

b) The immediate family members of such persons as set out under definition A, which means: the

spouse; any partner considered by national law as equivalent to the spouse; the children and

their spouses or partners considered by national law as equivalent to the spouse; and the

parents.

c) Persons known to be close associates of such persons as set out under definition A, which

means: any natural person who is known to have joint beneficial ownership of legal entities or

legal arrangements, or any other close business relations, with a person referred to in definition

A; any natural person who has sole beneficial ownership of a legal entity or legal arrangement

which is known to have been set up for the benefit de facto of the person referred to in definition

"Professional Client” shall mean a "Professional Client” for the purposes of CySEC Rules, as specified

in the document "Client Classification Policy”.

"Order Level” for CFD trading shall mean the price indicated in the Order

"Quote” shall mean the information of the current price for a specific Underlying Asset, in the form of

the Bid and Ask prices.

"Quote Currency” shall mean the second currency in the Currency Pair which can be bought or sold

by the Client for the Base Currency.

"Quotes Base” in relation to CFD trading shall mean Quotes Flow information stored on the Server.

"Quotes Flow” shall mean the stream of Quotes in the Platform for each CFD.

"Retail Client” shall mean a "Retail Client” for the purposes of the CySEC Rules, as specified in the

document "Client Classification Policy”.

"Services” shall mean the services to be offered by the Company to the Client under this Agreement,

as set out in paragraph 7.1. Of the Client Agreement.

"Short Position” for CFD trading shall mean a sell position that appreciates in value if underlying

market prices fall. For example, in respect of Currency Pairs; selling the Base Currency against the

Quote Currency. Short Position is the opposite of a Long Position.

eFinno is owned and operated by Streams Financial Services LTD, a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus

Securities and Exchange Commission (CySEC), with CIF license number 376/19 and company registration number HE 387124, located at

16th June 1943, Gladstonos Court No16, Office 101, 3022, Limassol, Cyprus

16th June 1943, Gladstonos Court No16,

Office 101, 3022, Limassol, Cyprus

"Slippage” shall mean the difference between the expected price of a Transaction in a CFD, and the

price the Transaction is actually executed at. Slippage often occurs during periods of higher volatility

(for example due to news events) making an Order at a specific price impossible to execute, when

market orders are used, and also when large Orders are executed when there may not be enough

interest at the desired price level to maintain the expected price of trade.

"Spread” for CFD trading shall mean the difference between Ask and Bid of an Underlying Asset in a

CFD at that same moment.

"Swap or Rollover” for CFD trading shall mean the interest added or deducted for holding a position

open overnight.

"Swap Free Client Account” is a type of Client Account available for CFD trading and shall have the

meaning set out in paragraph 45.

"Trailing Stop” in CFD trading shall mean a stop‐loss order set at a percentage level below the market

price ‐ for a long position. The trailing stop price is adjusted as the price fluctuates. A sell trailing stop

order sets the stop price at a fixed amount below the market price with an attached "trailing" amount.

As the market price rises, the stop price rises by the trail amount, but if the pair price falls, the stop

loss price doesn't change, and a market order is submitted when the stop price is hit.

"Transaction” shall mean transaction of the Client in a CFD.

"Transaction Size” for CFD trading shall mean Lot Size multiplied by number of Lots.

"Underlying Asset” shall mean the object or underlying asset in a CFD which may be Currency Pairs,

Futures, Metals, Equity Indices, Stocks, Commodities or as determined by the Company from time to

time and made available on its Website.

"Underlying Market” shall mean the relevant market where the Underlying Asset of a CFD is traded.

"Website” shall mean the Company’s website at efinno.com such other website as the Company may

maintain from time to time.

"Written Notice” shall have the meaning set out in paragraphs 23.3 and 23.4 of the Client Agreement.

2.1. Words importing the singular shall import the plural and vice versa. Words importing the masculine shall

import the feminine and vice versa. Words denoting persons include corporations, partnerships, other

unincorporated bodies and all other legal entities and vice versa.

2.2. Paragraph headings are for ease of reference only.