1. Introduction

These Terms and Conditions (“Terms”) govern your use of the services provided by FINTRA Securities Limited (“Fintra” or the “Company”), a Bangladesh-based brokerage and financial technology firm. Fintra is a licensed stock broker regulated by the Bangladesh Securities and Exchange Commission (BSEC) and a Trading Right Entitlement Certificate (TREC) holder (No. 084) of the Dhaka Stock Exchange (DSE). By creating an account with Fintra or using any of our platforms, mobile applications, websites, or services, you acknowledge that you have read, understood, and agree to be bound by these Terms, along with any other rules or policies referenced herein. Fintra reserves the right to change or modify these Terms, and any features or services, at any time for any reason, without prior notice. Your continued use of Fintra’s services after any modifications constitutes acceptance of the revised Terms.

2. Definitions

2.1 “Fintra” (also referred to as “we”, “us” or “the Company”) means FINTRA Securities Limited, a company incorporated in Bangladesh having its registered address at Cotton House (Level 1), House 02, Road 113/A, Gulshan-2, Dhaka-1212, Bangladesh. Fintra is a member of DSE and is authorized by BSEC to provide brokerage services.

2.2 “Client” or “User” (also referred to as “you”) means any individual or legal entity that registers for or uses Fintra’s services, including retail investors and institutional clients

2.3 “Services” refers to all services and features provided by Fintra, including but not limited to digital trading facilities, portfolio research and analytical tools, margin loan and bridging loan facilities, and any related financial technology services or content offered through Fintra’s platforms

2.4 “Account” means a brokerage account and associated Beneficiary Owner (BO) account opened with Fintra for trading securities through DSE and for utilizing Fintra’s services.

2.5 “BO Account” refers to the Beneficiary Owner account maintained with the Central Depository Bangladesh Limited (CDBL) for holding securities in electronic (dematerialized) form. Each Client must have a valid BO account (opened through Fintra or transferred to Fintra’s management) to trade securities via Fintra

2.6 “Margin Loan” refers to a financing facility provided by Fintra that allows Clients to borrow funds to purchase securities, with the loan secured by the securities and cash in the Client’s account (margin collateral).

2.7 “Bridging Loan” refers to a short-term credit facility that may be offered by Fintra to bridge settlement gaps or provide temporary financing for transactions, subject to specific terms and repayment from incoming funds (such as sale proceeds).

2.8 “Porichoy API” refers to the government-endorsed digital Know-Your-Customer (KYC) identity verification system in Bangladesh (Porichoy e-KYC), which Fintra uses to verify Client identities against national ID databases.

2.9 “bKash” refers to bKash Limited, a licensed payment service provider in Bangladesh, whose mobile financial services platform is integrated with Fintra for payment and fund transfer purposes.

2.10 Other Terms: In these Terms, “BSEC” means the Bangladesh Securities and Exchange Commission; “DSE” means the Dhaka Stock Exchange; “CSE” means the Chittagong Stock Exchange (if applicable); “CDBL” means Central Depository Bangladesh Limited; “TREC” means Trading Right Entitlement Certificate (stock exchange membership license); “Business Day” means a day on which DSE is open for trading and banks in Bangladesh are operational.

3. Account Creation and Eligibility

3.1 Eligibility Criteria: To be eligible to open and maintain an account with Fintra, you must be at least 18 years old (or the age of majority under Bangladeshi law), of sound mind and legal capacity, and a Bangladeshi citizen/resident or otherwise legally permitted to invest in Bangladesh’s capital market. For institutional Clients, the account must be opened by an authorized representative with the requisite corporate authorizations. Fintra’s services are intended for users who meet regulatory requirements (including any experience or asset thresholds imposed by BSEC for certain facilities, such as margin trading). We reserve the right to refuse to open or continue any account at our sole discretion if eligibility criteria are not met or if opening an account would violate any law or regulation.

3.2 Account Registration: You must provide true, accurate, current, and complete information during the account opening process, including your full name, National ID number, contact information, bank account details, and any other information Fintra may require. By submitting registration information, you represent and warrant that all information provided is correct and pertains to you (or the entity you represent) and that you will update Fintra promptly with any changes. Account creation may be subject to approval and verification processes described in Section 4 (KYC and Verification). If we discover that you have provided false, misleading, or fraudulent information, Fintra reserves the right to reject the application or terminate the account immediately.

3.3 One Account; Non-Transferability: Each Client is generally allowed to open one trading account (and the corresponding BO account) with Fintra, unless explicitly permitted otherwise. Your account is personal to you; you may not assign or transfer your account or any rights or obligations under these Terms to anyone else without Fintra’s prior written consent. You are responsible for all activities conducted under your account. Fintra shall not be liable for any loss or damage arising from unauthorized use of your account credentials (unless such unauthorized use is directly due to Fintra’s negligence).

3.4 Institutional and Joint Accounts: If you are opening an account on behalf of a legal entity (e.g., a company or fund), you represent that you are duly authorized to enter into this agreement on behalf of that entity and to bind the entity to these Terms. Additional documentation (such as board resolutions, corporate certificates, and authorized signatory lists) may be required. Joint accounts or nominee accounts are generally not permitted, except as allowed by BSEC regulations and subject to additional terms that Fintra may impose

3.5 Account Security: Upon successful account registration, you will set up login credentials (username, password, PIN, or other secure access methods). You are responsible for maintaining the confidentiality of your login credentials and for restricting access to your account. You agree to use strong passwords and enable any additional security features offered by Fintra (such as two-factor authentication) to protect your account You are fully responsible for all activities that occur under your account. If you suspect any unauthorized access or use of your account, or any other security breach, you must notify Fintra immediately. Fintra will not be liable for any loss you may incur from someone else using your account or password, with or without your knowledge, prior to you notifying Fintra of an unauthorized access or breach.

3.6 Digital Onboarding and Communication: By creating an account, you consent to receive communications from Fintra electronically (including via email, SMS, app notifications, or website postings). You agree that all agreements, notices, disclosures, and other communications that Fintra provides to you electronically satisfy any legal requirement that such communications be in writing. You are responsible for maintaining a valid email address and phone number in your account profile for receiving such communications.

4. Digital KYC and Verification

4.1 Know-Your-Customer (KYC) Compliance

Fintra is required by law and BSEC regulations to verify the identity of its Clients and conduct due diligence before allowing trading or financial transactions. You agree to provide all information and documentation that we request for KYC and ongoing compliance purposes, including but not limited to National Identification (NID) details, photographs, proof of address, bank account verification, source of funds declarations, and any other information mandated by regulators or our internal policies.

4.2 Porichoy e-KYC Integration: Fintra utilizes the Porichoy electronic KYC system and API for instant identity verification against the government’s national ID database. By applying for an account, you authorize Fintra to verify your identity through the Porichoy system or any similar government-authorized e-KYC service. This process may include validating your NID, performing face matching with provided photographs, and retrieving personal information from the National Identity database for the purpose of confirming your identity. All information obtained through Porichoy will be used solely for legitimate verification, record-keeping, and compliance purposes. Fintra will handle and store such data securely in accordance with our Privacy Policy (see Section 11) and applicable data protection laws.

4.3 Verification and Account Activation: Your account will not be fully activated (and you will not be permitted to execute trades or access certain services) until all required KYC steps are completed to Fintra’s satisfaction. This includes successful identity verification, linking a valid bank account and/or mobile financial service account (e.g., bKash) in your name, and, if required, providing a signature and other documents for BO account opening with CDBL. Fintra may, at its discretion, allow initial registration and limited access to the trading platform pending final verification, but reserves the right to block transactions or freeze any accounts where the verification has not been completed or if any provided information is suspect or requires further review.

4.4 Ongoing KYC and Monitoring: You acknowledge that Fintra will monitor transactions and account activity as part of its obligations under anti-money laundering (AML) and countering the financing of terrorism (CFT) laws. We may require you to periodically update your KYC information or provide additional documents (for example, if your identification documents expire or if there are changes in regulation). Fintra may also screen accounts against sanctions lists or other watchlists as mandated. If you or your transactions are flagged for any reason (e.g., high-risk profile, unusual activity), you may be required to provide additional information. Failure to comply with such requests can result in suspension of account access or reporting of the matter to the relevant authorities

4.5 Privacy of KYC Data: We understand the sensitivity of your personal data. Any information collected for KYC/AML purposes will be protected and used strictly in accordance with our Privacy Policy and applicable laws (see Section 11 for Data Privacy details). Fintra will not disclose your personal information to third parties except as required by law or regulatory directive, , or as necessary to provide our services (for example, sharing certain details with CDBL for BO account creation, or with payment providers to link your account).

4.6 Denial or Closure due to KYC/Compliance: Fintra, in its sole discretion and in compliance with regulatory guidelines, may refuse to open an account, or may restrict, suspend, or close an existing account, if any KYC or AML/CFT checks are failed or if the Client is found to be on any prohibited persons list, or if the Client’s activities pose a compliance risk. Fintra assumes no liability for any losses or inconveniences arising from our inability or refusal to provide services in such cases where compliance concerns exist.

5. Services Provided by Fintra

Fintra offers a suite of brokerage and financial technology services to its Clients. The following overview outlines our current offerings:

5.1 Digital Trading Services (Brokerage)

Fintra provides an online trading platform (accessible via web and mobile app) that enables retail and institutional Clients to buy and sell securities listed on the DSE in real time. Fintra acts as an intermediary facilitating the execution of your orders on the stock exchange. All trading is subject to the rules, regulations, and trading hours of the relevant exchange (primarily DSE, and CSE if applicable) and oversight by BSEC. When you place an order through Fintra’s platform, Fintra will route the order to the exchange matching engine for execution. Trade confirmations, contract notes, and account statements will be provided to you electronically. Fintra does not guarantee that any order you place will be executed, partially or in full, since execution depends on market conditions, availability of buyers/sellers, price limits, and exchange mechanisms. We will, however, use commercially reasonable efforts to execute orders promptly and fairly in accordance with applicable regulations and our Order Execution Policy

Trading Rules: By using Fintra’s trading services, you agree to abide by all exchange rules and securities laws. You are solely responsible for understanding the nature of the securities you trade and the risks involved. All trades executed through Fintra must comply with the rules and regulations of DSE and BSEC. Fintra reserves the right to reject or cancel any order that, in our judgment, violates any laws, regulations, exchange rules or Fintra policies (for example, orders suspected to be part of market manipulation, insider trading, or other prohibited practices). If any such order is executed before detection, Fintra may take steps to unwind or correct the trade as required by regulators or the exchange. Fintra may also impose trading limits or filters (such as price collars, position limits, or risk limits) as part of its risk management or as mandated by the exchange/BSEC.

No Investment Advice: Fintra may provide market data, news, research analyses, educational content, or portfolio analysis tools as part of the trading platform. These are provided for informational purposes only and should not be construed as investment advice or an endorsement of any security or strategy. Fintra is not an investment adviser; we do not provide personalized investment advice or recommendations to buy or sell any securities. Any investment decision you make is at your own discretion and risk. You acknowledge that you are solely responsible for your investment decisions and Fintra is not liable for any trading losses you may incur.

Market Data: Quotes, charts, and other market data or statistical information provided through Fintra’s platform may be obtained from third-party sources (including the stock exchanges or data vendors). While we strive to provide accurate and timely data, Fintra does not guarantee the accuracy, currency, reliability, or completeness of any market data. Fintra shall not be liable for any errors, delays, or interruptions in the transmission of data, or for any actions taken by you in reliance on any market information presented on our platform.

5.2 Portfolio Research and Analytics Tools

Fintra offers portfolio tracking, research and analytics tools to help Clients make informed investment decisions. These tools may include stock screeners, financial calculators, analytics dashboards, market research reports, educational articles, webinars, and other content related to the capital markets. All such offerings are provided on an “as-is” basis for your convenience. Fintra makes no warranty as to the accuracy or applicability of research and analytical tools for your particular situation. Any models, simulations, or projections are hypothetical and for illustrative purposes only; past performance metrics or back-tested results included in research tools do not guarantee future results.

No Reliance and No Liability: You must use your own judgment before relying on any information obtained from Fintra’s research tools. Fintra will not be responsible for any losses or damages resulting from your use of or reliance on such research or analytical content, as Fintra is not responsible for third-party data or content that might be part of these tools. The research and educational materials do not constitute tailored investment advice. By using these tools, you agree that Fintra is not liable for decisions you make based on the information obtained through them.

Intellectual Property: The portfolio analysis and research content provided may be proprietary to Fintra or licensed from third parties. These are for your personal use in connection with Fintra’s services. You agree not to redistribute, reproduce, or republish research reports or data in any form without Fintra’s prior written consent

5.3 Margin Loan Facilities

Fintra may provide Margin Loan facilities to eligible Clients, allowing you to purchase securities on margin by borrowing funds from Fintra. Margin trading can amplify both gains and losses and carries significant risk. The availability of margin loans is subject to strict regulatory guidelines and Fintra’s internal credit policies. Key terms of the margin facility include:

• Eligibility for Margin: Not all Clients or transactions qualify for margin financing. Fintra will determine eligibility based on BSEC’s margin rules and Fintra’s risk assessment. For example, BSEC’s guidelines may require that a Client have a minimum equity investment amount and a regular income to qualify for margin. Fintra may require you to have maintained a minimum account balance (e.g., at least BDT 500,000 in investments, as per applicable regulations) and a minimum trading experience (such as one year) before approving a margin account. We may also require you to sign a separate Margin Agreement detailing specific terms.
• Marginable Securities: Not all securities can be bought on margin. Fintra will maintain a list of eligible securities as per BSEC rules (for instance, margin loans might be disallowed for certain categories of stocks or newly listed securities until they meet criteria). You are responsible for ensuring that a security is margin-eligible before executing a margin trade. If you attempt to use margin for an ineligible security, Fintra may reject the order or treat it as a cash (non-margin) order.
• When you purchase securities on margin, you must provide collateral (cash or securities in your account) to secure the loan. Fintra will typically finance a portion of the purchase, and you must contribute the rest as equity. The ratio of loan to equity (margin requirement) will be determined by Fintra within regulatory limits (e.g., regulators may cap margin loans to a certain percentage of the portfolio value). Fintra will inform you of the initial margin requirement for each transaction and the maintenance margin you must uphold. You must maintain a sufficient level of equity in your account; if the value of your portfolio falls, Fintra may require you to deposit additional funds or sell assets to maintain the required margin (a “margin call”). For instance, regulatory draft rules suggest that if a portfolio’s value falls to 175% of the loan value, a margin call is triggered, and if it falls below 150%, a forced sale must occur to protect against further loss. While specific thresholds may vary, Fintra will generally issue a margin call notification if your equity falls below the maintenance requirement. You agree to promptly meet any margin calls by depositing additional collateral as needed.
• Margin Calls and Liquidation: If you fail to meet a margin call or if your account balance falls below required levels, Fintra has the right, without further notice to you, to liquidate part or all of your positions to reduce or satisfy the loan. Fintra may decide which securities to sell, and the timing and order of liquidation, at its discretion and on a best-effort basis given market conditions. We will not be liable for any losses incurred due to such liquidation, and any costs or losses arising from such actions will be borne by you. You will remain responsible for any deficiency balance if the proceeds of liquidation are insufficient to cover what you owe (including accrued interest, fees, and any market losses).
• Interest and Charges: Borrowing on margin incurs interest and possibly other charges. The interest rate and method of calculation for margin loans will be communicated to you (for example, a daily or annual interest rate on the borrowed amount, which may accrue daily and be charged to your account monthly). Fintra reserves the right to change the interest rate and will notify you of any changes as required by law or in your Margin Agreement. You agree to pay all interest and associated charges for margin usage. If interest or charges remain unpaid, they will be added to your outstanding loan balance, and may liquidate assets to recover unpaid interest similar to unpaid principal. Other charges may include arrangement fees, processing fees, or regulatory levies (e.g., stamp duties or taxes on loan transactions) as applicable.
• Fintra’s Rights regarding Margin Loans: Fintra reserves the right to refuse to provide margin financing to any Client, or for any particular transaction, at our discretion. Even if you have an approved margin account, each transaction is subject to approval. We may also suspend or terminate the Margin Loan facility at any time (for instance, if required by changes in law or if we assess heightened risk), and in such case, we may require you to promptly repay all outstanding loan amounts and charges. If you do not do so, we may liquidate collateral as described above. We will endeavor to inform you if we withdraw margin facilities, but in urgent scenarios (e.g., rapid market declines or regulatory orders), we may act without prior notice to protect our and your interests.
• Client Acknowledgements: By using the margin facility, you acknowledge and agree that margin trading is highly risky. You may lose more than your invested capital since you are trading with borrowed funds. Market conditions can change rapidly and you may not have the opportunity to deposit additional funds before Fintra acts to protect its interests (and by extension, your account’s solvency). Fintra’s enforcement of margin requirements (including forced liquidation) is to comply with regulatory obligations and to prevent the account from falling into a negative equity position. You accept responsibility for monitoring your account and ensuring compliance with margin requirements at all times, and you will not hold Fintra liable for executing margin calls or liquidations, or for losses that result from such actions or market volatility. Fintra will report required details of your margin positions to exchanges or regulators as needed, and you consent to such reporting.
• Additional Margin Terms: Additional detailed terms governing margin trading (such as specific rights and obligations of broker and client, as mandated by BSEC or exchanges) will be provided to you in the Margin Loan agreement or disclosure documents. Those additional terms are incorporated herein by reference. In the event of any conflict between these general Terms and the specific Margin Loan agreement, the latter will prevail for issues relating to margin trading.

5.4 Bridging Loan Facilities

Fintra may offer Bridging Loans as a short-term credit facility to bridge gaps in settlement or to facilitate certain time-sensitive transactions for Clients. Bridging loans are typically of short duration and are intended to be repaid from predictable incoming funds (for example, to provide you funds immediately upon selling securities, rather than waiting for the T+2 settlement, or to allow you to make a time-sensitive investment pending liquidation of another asset). The following outlines the bridging loan service:

• Use Cases: Bridging loans can be used to bridge settlement timing differences or meet short-term liquidity needs related to trading. For instance, if you sell shares and need the proceeds immediately (before the standard settlement completes), a bridging loan might advance a portion of the sale proceeds. Alternatively, if you have applied for an IPO or need to pay for a purchase but your funds are tied up for a few days, a bridging loan might cover the interim period. Fintra will specify the approved purposes for any bridging loan and may require documentation of the pending funds it is bridging.
• Term and Repayment: Bridging loans are short-term by nature, often requiring repayment within a very brief period (such as within a few days or weeks, or upon the occurrence of a specified event like settlement completion). The loan will typically be automatically repaid from the incoming funds it is bridging. For example, if bridging a stock sale, the loan plus interest may be automatically deducted from the sale proceeds once settlement occurs and the funds arrive. If the expected funds do not materialize (e.g., a sale fails or an expected payment is delayed or canceled), you are still fully responsible for repaying the bridging loan from your own resources by the due date.
• Interest and Fees: Bridging loans generally carry interest or fees which may be higher (on an annualized basis) than standard loans, given their short tenure. Fintra will disclose the interest rate (which may be a fixed fee for the period or a daily interest rate) before you accept the loan. Interest may be calculated on a daily basis for the number of days the loan is outstanding. There may also be processing fees or administrative charges. You agree to pay all interest and fees as specified. If you repay early, interest may still be charged for a minimum period as per the loan terms (if applicable). If you fail to repay on time, penalty interest rates or late fees may apply, and Fintra may exercise rights against any collateral (e.g., securities in your account) to recover the dues.
• Security and Collateral: A bridging loan will typically be secured against the assets or funds that are expected to come in or other assets in your trading account. By accepting a bridging loan, you grant Fintra the right to lien or hold such collateral. For example, if you take a bridging loan expecting funds from a share sale, the shares sold (or the sale receivable) or other holdings in your account may serve as collateral. Fintra may refrain from releasing certain securities or funds to you (even if otherwise withdrawable) if they are earmarked for a bridging loan repayment.
• Default on Bridging Loan: If you do not repay a bridging loan by the agreed time (for instance, if the anticipated incoming funds do not cover it and you do not cover the shortfall), Fintra will consider this a default. In such event, Fintra is entitled to take necessary actions to recover the loan , including but not limited to liquidating securities or other assets in your account to cover the owed amount (similar to a margin liquidation) and/or taking legal action for debt recovery. You will be responsible for any shortfall after liquidation, as well as any costs associated with collection.
• Availability and Discretion: Bridging loans are offered at Fintra’s discretion and are not a guaranteed service. We assess each request or transaction on a case-by-case basis. Fintra reserves the right to decline to offer a bridging loan to you, or to specify a lower amount than requested, based on our risk assessment and prevailing regulatory or internal limits. We may also suspend or discontinue the bridging loan facility entirely at any time. Future availability of bridging loans could depend on regulatory permissions and Fintra’s business decisions.
• Client Responsibilities and Risk: By using a bridging loan, you acknowledge that it is your responsibility to ensure the anticipated funds or liquidity event will occur. Any risk that the expected funds might be delayed or fail to arrive lies with you. You should have a backup plan to repay the loan if the primary source fails. Fintra’s provision of a bridging loan does not in any way guarantee or make Fintra responsible for the underlying transaction (e.g., if an issuer fails to deliver IPO refund money or if a buyer fails to pay for a sale – those are outside Fintra’s control). Fintra will not be liable for any losses or damages you suffer due to your reliance on receiving a bridging loan or due to any consequences of not receiving one . This facility is meant for convenience and is not an endorsement that such borrowing is prudent for your situation. You should carefully consider the costs and risks of borrowing

6. Client Obligations and Use of Services

By using Fintra’s services, you agree to the following obligations and understandings regarding acceptable use and your responsibilities:

6.1 Lawful and Personal Use: You shall use Fintra’s platforms and services solely for lawful purposes and in compliance with all applicable laws and regulations of Bangladesh (and any other jurisdiction, if you are subject to other laws). You may not use the service for any illegal, fraudulent, or unauthorized purpose, including but not limited to money laundering, terrorist financing, insider trading, market manipulation, abusive trading practices, or misrepresentation of identity. The account is provided for your personal (or your organization’s internal) use only. You shall not allow any other person to use your account or identity to access Fintra’s services, and you will not use any other person’s account.

6.2 Compliance with Rules: You must follow all rules established by regulatory authorities and self-regulatory organizations applicable to trading. This includes BSEC regulations, DSE/CSE trading regulations, and CDBL depository rules. For example, you agree not to engage in activities like circular trading, spoofing, layering, or any act that could be considered market manipulation or a violation of fair trading norms. If you are an insider or connected person for any listed company, you acknowledge the obligation to refrain from trading during restricted periods and to make any required disclosures as per law. Fintra may monitor trading patterns for compliance and reserves the right to report any suspicious activities to BSEC, the Bangladesh Financial Intelligence Unit (BFIU), or other appropriate authorities as required.

6.3 Information and Updates: You must promptly inform Fintra of any changes to your personal or contact information or any material changes in your circumstances (for instance, change of address, change in bank account, change in employment that might affect your investment profile, etc.). Fintra relies on the information provided by you to service your account and to comply with regulatory reporting (such as proper tax identification and withholding). Any incorrect or outdated information could lead to service disruptions or compliance issues for which you would be responsible.

6.4 Account Funding and Payment Obligations: You agree to fund your account in a timely manner for your purchase transactions. When you buy securities, you are obligated to pay the purchase price plus any applicable fees by the settlement date. Failure to pay on time could result in Fintra selling out the purchased securities (“autoforce sell” for settlement failure) and charging you any consequential loss. Similarly, if you place a sell order, you must ensure the securities are available/transferable in your BO account for delivery; failure to deliver securities could cause Fintra to purchase the equivalent securities from the market to cover the short position, and you would be liable for any difference in cost and penalties. You are responsible for all fees, commissions, taxes, and charges related to your trading and use of services as detailed in Section 7.

6.5 No Unauthorized Activities: You shall not abuse or misuse Fintra’s platforms. This includes no attempts to circumvent security measures, no introducing of malicious code (viruses, worms), no data scraping or automated data extraction beyond what is allowed via provided APIs or tools, and no actions that impair the functionality of our services or the experience of other users. You must not attempt to gain unauthorized access to any portion of our systems or another client’s information. If you become aware of any system error, glitch, or security vulnerability, you agree to notify Fintra and not to exploit it. Fintra may pursue legal action and damages against any user who engages in such prohibited activities.

6.6 Third-Party Access: If you use any third-party software or service (such as a financial aggregator or trading algorithm) in conjunction with Fintra’s services, you are solely responsible for ensuring that such use is authorized and does not violate any laws or these Terms. Fintra will not be responsible for data or orders transmitted through any third-party tool that you use at your own risk. You should manage and review any permissions you grant to third parties regarding your Fintra account (for example, if Fintra enables API access for your account, any keys or tokens must be safeguarded by you).

6.7 Device and Connectivity: You are responsible for the equipment (computer, mobile device) and internet or network connection required to access Fintra’s online services. Fintra is not liable for any failure in service or data inaccuracies due to your equipment malfunction, connectivity issues, or other technical reasons outside our control (such as power outages or internet downtime on your side). You must use only compatible and trusted devices and software, and keep them free of malware, to securely access Fintra’s services.

6.8 Cooperation with Compliance Reviews: From time to time, Fintra or its regulators may conduct compliance audits or inquiries related to your account (for example, unusual transaction reviews, insider trading inquiries, or tax-related information requests). You agree to cooperate fully with any such review and to provide information or documentation as reasonably requested. Non-cooperation could be deemed a serious breach of these Terms.

6.9 Client’s Acknowledgment of Risks: You acknowledge that you understand the general risks of investing in securities, which include the potential loss of principal, volatility of prices, liquidity risk, and regulatory or economic changes that can affect investments. (See Section 19 “Risk Disclosure” for more detail.) You confirm that you will exercise due care and judgment in your trading activities. If you have any doubt about the suitability of an investment or the meaning of any information or terms, you should seek independent advice.

6.10 No Misuse of Content: Any content provided to you by Fintra (including research data, educational materials, platform interface elements, etc.) is for your personal use related to Fintra’s services. You shall not resell, redistribute, or use Fintra’s content for competitive purposes. You also agree not to use Fintra’s platform to disseminate any false, misleading, or unsolicited communications (for example, you will not use any chat or forum, if provided by Fintra, to spam or harass others).

6.11 Responsibility for Communications: Any instructions or orders placed through your account, whether initiated by you or by an authorized person using your credentials, are deemed to be your communications. Fintra may act upon those instructions without further verification. Be mindful that once executed, trades typically cannot be reversed. If you believe an order was placed in error, you must contact Fintra immediately, but we cannot guarantee that a remedy will be available.

6.12 Indemnification for Breach: You agree to indemnify and hold harmless Fintra, its affiliates, directors, officers, employees, and agents from any and all claims, damages, losses, liabilities, costs, and expenses (including legal fees) arising out of or related to your violation of these Terms or any applicable law, or your misuse of the services. This means if your actions cause any loss to Fintra or if a third-party or regulator brings a claim or fine against Fintra due to your conduct, you will be responsible for the costs and consequences.

7. Fees, Commissions, and Charges

7.1 Brokerage Commission: By using Fintra’s brokerage services, you agree to pay brokerage commissions on your trades. The commission rate will be as per Fintra’s schedule or as mandated by BSEC/DSE regulations. Currently, brokerage commission rates are subject to BSEC-set caps and industry standards. Fintra’s commission may be a percentage of the transaction value or a fixed amount per trade, as disclosed to you. This commission is charged on both buy and sell transactions (unless specifically waived in promotions). A schedule of our current fees is available on our website and within the app.

7.2 Exchange and Depository Fees: In addition to Fintra’s own commission, certain fees imposed by the exchange and depository will be passed through to you. These include, for example, DSE/CSE trading fees, CDBL charges for settlement, and any clearing fees. When you trade, these fees are added to your cost (for purchases) or deducted from your proceeds (for sales). Fintra will itemize these in contract notes or statements where possible. You agree to pay all such statutory or regulatory fees, which may change from time to time. For reference, you may incur DSE transaction fees and CDBL fees on each trade. Government charges like stamp duty on share transfers may also apply.

7.3 Margin and Loan Charges: If you utilize margin loans or bridging loans (Sections 5.3 and 5.4), you will incur interest and possibly other charges as described earlier. These costs will either be debited from your account or included in the loan balance, as per the arrangement. Interest rates for margin/bridging loans will be communicated and are subject to change with notice. You should review the specific loan agreement or disclosure for details. All applicable interest, service charges, and processing fees for such facilities must be paid by you; otherwise, they will accrue and your obligations will increase accordingly.

7.4 Other Account Service Fees: Fintra may charge fees for certain ancillary services, such as: account maintenance fees, annual fees for BO accounts, withdrawal or fund transfer fees (if any beyond direct costs), fees for dishonored payments (e.g., bounced cheques or failed direct debits), or fees for additional statements or certificate issuance. Fintra will maintain a fee schedule that outlines these potential charges. For example, if Fintra provides SMS alert services or real-time data subscriptions, there might be subscription fees, which will be clearly informed to you before activation.

7.5 Payment of Fees: You authorize Fintra to deduct any fees, charges, commissions, interest, or taxes you owe from your account balance. We may deduct amounts from any cash in your trading account or from any credits due to you (such as sale proceeds or dividends). If your account does not have sufficient cash, we may sell some of your securities to cover the charges, after providing notice if required by regulation. In case any fees remain unpaid (e.g., a debit balance arises), that amount will be treated as a debt you owe us, and Fintra reserves the right to take necessary action to collect it (which could include legal action or involving a collections agency, and reporting the delinquency to the regulator or credit bureaus if applicable).

7.6 Taxes: All fees and charges are generally quoted exclusive of any applicable taxes (unless specified). If any Value Added Tax (VAT), financial transaction tax, or any other tax is applicable to the fees or to transactions, you agree to pay such taxes. For instance, under Bangladeshi law, VAT may be levied on brokerage commissions or certain service fees. Fintra will collect such taxes and remit them to the government as required. We will reflect tax deductions in your statements. Additionally, certain taxes like capital gains tax or taxes on dividend income might be withheld at source as per law — Fintra will deduct and deposit such taxes as required, and the net amount will be credited to your account.

7.7 Changes to Fees: Fintra reserves the right to change its fee structure or introduce new fees with at least such notice as is required by law or regulation. We will notify you of fee changes through the app, website, or email. If you continue to use the services after the fee change takes effect, that constitutes your acceptance of the new fees. If you object to any fee change, you may cease using the service and close your account in accordance with Section 15, subject to settling any outstanding obligations.

7.8 No Refund Policy: Generally, fees, commissions, and charges once incurred are non-refundable. For example, if a trade is executed and later canceled or amended due to any reason, the fees for the original execution may still be payable (though Fintra will follow exchange rules regarding any fee adjustments for canceled trades). If you believe an incorrect fee has been charged, you must notify Fintra promptly and we will review the matter. Any agreed refund or adjustment will be at Fintra’s discretion or as mandated by rules.

8. Deposits, Withdrawals, and Payments Integration

8.1 Funding Your Account: To trade or use certain services, you need to deposit funds into your Fintra trading account. Fintra supports multiple payment methods for depositing Bangladeshi Taka (BDT) funds, including bank transfers, bKash (mobile wallet) payments, and other payment gateways or services as made available. Deposits must originate from an account or source in your own name – we do not accept third-party payments for your account, in order to comply with AML regulations. When you initiate a deposit, you must follow the instructions provided (e.g. using your unique client reference when transferring to our designated bank account, or using the in-app bKash integration to push funds). Fintra will credit your trading account after confirming receipt of funds. Credit for trading might be given only after funds have cleared (for bank transfers) or immediately for real-time methods like bKash, subject to hold as described below.

8.2 bKash and Mobile Payments: If you use bKash to deposit funds, you agree to the terms and procedures of bKash’s payment service. bKash acts solely as a payment method and is not responsible for the delivery of Fintra’s services. Fintra integrates bKash’s payment gateway for your convenience. When you make a payment via bKash, the funds may be subject to bKash’s processing. In some cases, bKash or Fintra might hold the payment in a pending state until certain confirmations are completed. For example, if there’s a need to verify the availability of funds or to prevent fraud, the credit to your account might not be instantaneous. If a deposit via bKash is held or delayed, Fintra is not liable for any trading opportunity loss or inconvenience because the funding was not available yet. In the event a payment is not completed or is reversed by bKash (for instance, if you did not confirm the transaction or if bKash’s system failed), Fintra will not credit your account and is not responsible for any consequences of non-payment. You should contact bKash customer care for issues specific to the payment processing (dial 16247 or relevant support), though Fintra will assist to the extent possible in reconciling transactions.

8.3 Withdrawal of Funds: You may request to withdraw available cash funds from your Fintra account at any time, subject to settlement periods and any hold on funds. Withdrawals will generally be processed via the same route as deposits: e.g., to your linked bank account or to your bKash wallet, as per your instruction (Fintra may restrict withdrawals to verified accounts in your name only, to prevent third-party transfers). Fintra will attempt to process withdrawal requests promptly; however, we do not guarantee immediate withdrawal as processing times can depend on banking hours, bKash processing, or additional verification if needed. Typically, if you sell securities, the sale proceeds are only withdrawable after the settlement date (T+2 days for equities, or as per exchange rules). If you have recently deposited funds, Fintra may hold withdrawals until the deposit is cleared or not subject to reversal (this could be a few banking days, especially for large transfers or first-time deposits).

8.4 Withdrawal Limits and Procedures: Fintra may set daily or per-transaction limits on withdrawals for security or regulatory reasons. For example, there might be a maximum amount you can withdraw via bKash in a single transaction or per day in line with bKash limits. If you need to withdraw a large amount, a bank transfer might be required. We may also require additional identity verification for large withdrawals or unusual withdrawal requests (as part of fraud prevention). Fintra reserves the right to refuse or delay a withdrawal request if we suspect unauthorized activity or if your account is under review. We will inform you if any additional steps are needed. You are responsible for any fees charged by third-party institutions on withdrawals (Fintra itself may not charge a withdrawal fee, but your bank or bKash might impose a fee which is typically borne by the sender/receiver as per their policy).

8.5 Segregation of Client Funds: Fintra will maintain client funds (your deposits) in a segregated account as required by BSEC regulations. This means your money is kept separate from Fintra’s own corporate funds. However, note that the funds may be co-mingled in one or more client omnibus accounts (with proper records of each client’s balance) as per common practice, but they are not used for Fintra’s operating purposes. Fintra does not pay interest on any cash balances in your trading account, unless explicitly stated or required by law.

8.6 Errors and Reversals: If we credit your account in error (for example, a duplicate deposit, or a bank reversal after we gave credit), we reserve the right to reverse those credits. You authorize Fintra to deduct any such erroneously credited amounts from your account, or, if insufficient, you agree to repay the outstanding amount immediately upon notice. Conversely, if a deposit you made does not reflect, and it’s due to a mistake on Fintra’s part, we will correct it and credit your account with the appropriate value date if feasible.

8.7 Payment Disputes: If you believe there has been an error in processing any deposit or withdrawal, you must contact Fintra promptly (and in any case, within 7 days of the date of the transaction in question). We will investigate and attempt to resolve the issue. If the error is on Fintra’s side, we will rectify it; if the issue lies with a third-party (e.g., the bank or bKash), it may take additional time to liaise with them. Fintra’s liability for any payment error will be limited – for instance, if a withdrawal is delayed due to Fintra’s fault, our liability will not exceed restoring the funds to you or completing the transaction; we will not be responsible for indirect consequences, such as lost interest or missed investment opportunities, due to payment delays.

8.8 Integration with Other Payment Services: Fintra may integrate or support additional payment services in the future (such as other Mobile Financial Services, payment gateways, credit/debit card payments for account funding, etc.). Use of any such method implies your agreement to the terms and conditions of those service providers, in addition to these Terms. Fintra will not be responsible for failures on part of those services. For example, if in future a service like Nagad or bank EFT (Electronic Funds Transfer) is supported, any issues or delays on the banking network’s side are beyond Fintra’s control.

8.9 Anti-Money Laundering and Limits: We are required to report certain high-value or suspicious transactions to regulators. Fintra may impose deposit or withdrawal limits if needed to comply with AML laws (for example, we might ask questions about the source of a very large deposit or require evidence of the destination for a large withdrawal). We appreciate your cooperation in keeping the financial system secure.

9. Data Privacy and Security

9.1 Collection of Personal Data: Fintra collects and maintains personal data about you in order to provide our services and to comply with legal obligations. This data includes information you provide during account opening (such as name, contact details, identification information, financial information, etc.), as well as data gathered through your use of our services (such as transaction history, device information, location data if you use our app, and communication records). By agreeing to these Terms, you also acknowledge Fintra’s Privacy Policy (available on our website or upon request), which details how we handle your personal information.

9.2 Use of Personal Data: We use your personal data to operate and improve our services, including processing your transactions, verifying your identity, personalizing your user experience, and sending service-related communications. We also use data to comply with regulations (such as reporting to BSEC or tax authorities) and to prevent fraud or illicit activities. Fintra will use your information to provide services, process transactions, and comply with legal and regulatory obligations. For instance, we may use your national ID and financial info to report trades for taxation or to screen for insider trading as required by law.

9.3 Data Sharing: Fintra treats your personal data with confidentiality. We do not sell or rent your personal information to third parties for their marketing purposes. We may share data with third parties in certain circumstances: - Regulators and Authorities: We will disclose information to BSEC, DSE, CDBL, Bangladesh Bank, BFIU, or other government authorities if required by law or regulation. For example, trade and account details might be reported to exchanges, or suspicious activities to BFIU. - Service Providers: We share necessary data with trusted third-party service providers under contract, who help us in running our business (for example, IT infrastructure providers, data storage services, payment processors, KYC verification services like Porichoy, etc.). They are bound to keep data secure and use it only for the intended purposes. - Business Partners: If Fintra offers services in conjunction with partners (for example, a partner providing an educational tool or loyalty program), data may be shared to the extent needed to fulfill those services, but subject to appropriate confidentiality. - Legal Requests: If required by a court order, law enforcement request, or legal process, we may disclose relevant information. - Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of Fintra’s business (in whole or part), client information may be transferred to the successor entity as part of due diligence or actual transfer, under obligations of confidentiality and consistent data protection.

Other than the above, Fintra would only share your data with your consent or at your direction.

9.4 Protection of Data: Fintra employs administrative, technical, and physical safeguards to protect your personal and financial data. This includes encryption of sensitive data, secure servers, access controls, and regular security audits. While we strive to protect your information, you acknowledge that no system is completely immune to cyber threats. Fintra cannot guarantee absolute security of data against all possible threats, especially if there are vulnerabilities in networks or devices not under our control. We implement industry-standard security measures, but you acknowledge that no system is completely safe from hacking or cyber attacks[35]. In the event of a data breach that affects your personal information, Fintra will follow applicable laws in notifying you and addressing the breach.

9.5 Client Responsibilities for Security: You play a key role in maintaining security. Protect your account credentials, use strong passwords, and do not share your login information. Always use Fintra’s official platforms and be cautious of phishing attempts (e.g., fake websites or emails pretending to be Fintra). We will never ask for your password via phone or email. If you suspect your personal data or account is compromised, contact us immediately.

9.6 Data Retention: Fintra will retain your personal data for as long as your account is active and thereafter for as long as needed to comply with legal retention requirements or for legitimate business purposes. For example, BSEC rules might require us to keep transaction records for a number of years. When data is no longer required, we will securely delete or anonymize it.

9.7 Your Rights: Subject to applicable law, you may have the right to access, correct, or request deletion of certain personal data we hold about you. You may also have the right to object to or restrict certain data processing. However, please note that some data may be exempt from such requests (for example, we cannot delete your transaction records which regulators require us to keep). If you wish to exercise any data subject rights, you should contact our support or data protection officer as listed in the Privacy Policy. We will respond as required by law.

9.8 Behavioral and Marketing Communications: Fintra may use your contact information to send you service updates, legally required communications, and marketing or promotional content related to our services. If you prefer not to receive marketing communications, you can opt-out through your account settings or by following the unsubscribe instructions in the message. (Service and transaction-related communications cannot be opted out of, as they are essential for the use of the service.)

9.9 Cookie and Tracking Technologies: Our online services may use cookies or similar technologies to enhance user experience, analyze site usage, and for security. Our Privacy Policy or a Cookie Policy (if separate) provides details on this. By using our website/app, you consent to such use of cookies.

You can control cookies through your browser settings but disabling them may affect functionality.

9.10 Cross-Border Data Transfer: Fintra primarily stores and processes data in Bangladesh. If we use cloud providers or service providers that are in other jurisdictions, we will ensure that appropriate protections are in place. By using our services, you consent to the transfer of your data to, and processing in, other jurisdictions as may be necessary (with the understanding that those jurisdictions may have different data protection standards, but we will contractually ensure protection).

10. Third-Party Services and Links

10.1 Integration with Third Parties: Fintra’s platform may integrate with or provide links to third-party services to enrich your experience. Examples include: - Payment services like bKash or banks (as discussed) for fund transfers. - Identity verification services like Porichoy for KYC. - Market data feeds or news providers for information. - Possible future integrations like analytical tools, or partner platforms offering complementary services (e.g., tax calculators, portfolio management, etc.).

While we strive to work with reputable providers, Fintra does not endorse or assume responsibility for any third-party services or content that are outside our control. These services are provided either as a convenience to you or as part of our regulatory obligations (like KYC). If you access third-party websites or services through our platform, you do so at your own risk. Fintra makes no guarantee as to the quality or security of third-party services, and any issues or losses arising from their use are between you and that third-party (except as explicitly provided by law or separate agreement).

10.2 No Liability for Third-Party Failures: Fintra shall not be liable for any losses, damages, or interruptions caused by the failure of third-party systems or services. This includes, for instance, if the stock exchange’s trading platform faces downtime, if CDBL’s systems encounter issues processing settlements, if the Porichoy API is unavailable or produces erroneous verification, or if bKash’s network is down during a transaction. GoZayaan (as an example of a service intermediary) is not responsible for issues arising from third-party services, and likewise Fintra is not responsible for the acts or omissions of external providers. However, we will make reasonable efforts to assist you in remedying issues that involve third-parties, to the extent we are able (for example, providing you with transaction references to follow up with a payment provider).

10.3 Third-Party Content: Our services might include or display information, content, or features from third-party sources, such as stock quotes, analyst reports, news articles, educational content from partners, or social media feeds. Such content is provided “as is” for your convenience. Fintra does not verify or guarantee the accuracy or completeness of third-party content. Opinions or statements expressed in third-party content are those of the third-party and not of Fintra. Fintra is not liable for any decisions you make based on third-party information presented via our platform.

10.4 Links to External Sites: Fintra’s website or app may contain hyperlinks to external websites or resources for your reference (for example, links to DSE or BSEC websites, links to educational resources, or partner promotions). These links do not signify an endorsement of those websites or their content. Fintra has no control over the nature, content, and availability of those external sites. You should review the terms and privacy policies of any third-party sites you visit. Fintra will not be liable for any loss or damage that may arise from your use of external sites.

10.5 Use of Software and Licenses: If Fintra provides you with software or enables integration (like an API or a downloadable application), any third-party software components included may be subject to their own licenses. Fintra disclaims responsibility for any open-source or third-party software embedded in our offerings, beyond ensuring we have the right to use it.

10.6 Third-Party Advertising: Fintra’s platform is primarily a financial service, and we currently do not display third-party advertisements as part of our trading interface. If that changes (for instance, if we include any sponsored content or partner offers), such content will be identified and you will have the choice to engage or ignore it. We will not share your personal information with third-party advertisers without your consent.

10.7 Transactions with Third Parties: Any dealings you have with third parties (including other users or external merchants) through Fintra’s service are solely between you and the third party. For example, if Fintra facilitates a referral to a partner providing financial planning, any contract you enter with that partner is outside the scope of these Terms, and Fintra bears no responsibility for it. You agree that Fintra is not responsible for any loss or claim you may have against a third party.

10.8 Feedback and External Platforms: If Fintra’s platform allows you to share content to or from external platforms (such as sharing your investment achievements to Facebook, or logging in via a Google account), note that those platforms’ terms will govern the use of their services. Fintra disclaims liability for any personal data or content that gets shared to external platforms at your initiation. Use such features only if you understand the external platform’s policies.

11. Intellectual Property and Platform Use

11.1 Ownership: All content, trademarks, logos, graphics, interfaces, and software provided by Fintra in connection with the services are the property of Fintra or its licensors and are protected by intellectual property laws. FINTRA, the Fintra logo, and any other Fintra trade names or slogans are trademarks of Fintra. The structure and layout of the trading platform, including the software and code that powers it, are proprietary. By using Fintra’s services, no ownership rights are transferred to you. You are granted a revocable, limited, non-exclusive, non-transferable license to use Fintra’s platform and content for the sole purpose of using the services as permitted by these Terms.

11.2 Authorized Use: You may use the Fintra website and mobile applications, and any materials provided, only for their intended purpose – i.e., managing your account and investments. Any commercial use of our platform or content (other than by institutional clients managing their internal portfolios) is prohibited without our written consent. You agree not to copy, modify, distribute, perform, display, create derivative works of, reverse engineer, or attempt to extract the source code of our software, except to the extent you are expressly permitted by law (and, if so, with notice to us). Likewise, you may not remove or obscure any copyright, trademark, or other proprietary notices on the platform.

11.3 Client Content: In certain areas, Fintra might allow you to submit content (for instance, participating in a discussion forum, providing feedback, or uploading documents for verification or other purposes). By submitting any content or feedback to Fintra, you grant Fintra a worldwide, royalty-free, sublicensable license to use, reproduce, adapt, modify, publish, and distribute such content for the purpose of operating or improving the service. For example, if you provide a testimonial or suggestion, we can use it to promote or refine our services. Do not submit any content that infringes someone else’s rights or is illegal. Fintra reserves the right (but not obligation) to monitor and remove any user-submitted content that we deem inappropriate, in violation of these Terms, or harmful to our operations or reputation.

11.4 Fintra Marks and Reputation: You must not use Fintra’s name, logos, or trademarks in any way that could confuse others or imply an endorsement or partnership where none exists. If you refer to Fintra (for example in a blog or article), you should do so truthfully and not misuse our marks. Any goodwill generated from use of Fintra’s trademarks inures to Fintra. If you wish to use Fintra branding in any promotional context, you must seek our permission.

11.5 Third-Party IP: Some content or features on Fintra might be licensed from third parties (e.g., charting libraries, market data, news feeds). Their intellectual property remains with them. Fintra provides you a right to use such content within our service, but you may not extract and use it outside Fintra. For example, you cannot re-sell real-time market data from Fintra’s app to others. If any third-party terms apply to your use of certain data or software, Fintra will make you aware (for instance, exchanges often have data usage policies that users implicitly agree to by using market data).

11.6 Infringement Claims: If you believe that any content on Fintra’s platform infringes your copyright or other IP rights, you should notify us with details. Fintra has a policy of responding to claims of intellectual property infringement in accordance with applicable law. We reserve the right to remove or disable content alleged to be infringing and to terminate accounts of repeat infringers, if any.

11.7 Software Updates: Fintra may from time to time update the software of its platform or require you to install updates to continue accessing the services (especially for mobile apps). These updates are meant to improve, enhance, and further develop the services and may take the form of bug fixes, enhanced functions, new software modules, or completely new versions. By using Fintra’s services, you agree to receive such updates. If you do not install updates, certain features may not function properly or security could be compromised, for which Fintra will not be responsible.

11.8 Usage Data: Fintra may collect and use aggregate or de-identified data relating to the use of our services (e.g., trading volumes, frequency of feature use, etc.) for analytics and improvement purposes. This does not include personal data that identifies you, and such usage data is the property of Fintra. We ensure that usage analytics do not compromise your privacy.

12. Disclaimers of Warranties

12.1 “As Is” and “As Available” Service: Fintra’s services, including the trading platform, website, mobile app, and all content and functionality, are provided to you on an “AS IS” and “AS AVAILABLE” basis, without any warranty of any kind. Fintra makes no representation or warranty that the services will meet all of your requirements or expectations, or that they will be uninterrupted, timely, secure, or error-free. While we aim for high availability and accuracy, we do not guarantee that the platform will be free from downtime, delays, or imperfections. You assume all risk in using the services.

12.2 No Warranty on Information: Any information or data provided through Fintra is for convenience and should not be relied upon as official or guaranteed. Fintra disclaims any warranty regarding the accuracy, reliability, or completeness of any information (including market data, analytics, account balance information, etc.) obtained through the service. We especially highlight that delays or errors in quote feeds or account balances can occur and you should verify critical information via official sources when needed.

12.3 No Implied Warranties: To the fullest extent permitted by law, Fintra disclaims all warranties and conditions of any kind, whether express or implied, including, but not limited to, any implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, and any arising from course of dealing or usage of trade. For example, Fintra does not warrant that:

• - The service will result in any particular financial outcome or profit for you (we explicitly do not guarantee any profits or returns from trading – you acknowledge the risk of losses).
• - The quality of any products, services, or information obtained through our platform will meet your expectations.
• - Any software bugs or errors will be identified or corrected (though we work to fix known issues, we make no warranty that the service is completely error-free or immune to technical glitches).

12.4 Technology Disclaimer: You understand and agree that any material or data downloaded or otherwise obtained through the use of Fintra’s services is done at your own discretion and risk. Fintra does not warrant that files, software, or any digital components available for download will be free of viruses, malware, or destructive features. We are not responsible for any damage to your computer, device, or data that results from download or use of our services.

12.5 No Duty to Update: Except as required by law, Fintra has no obligation to update or correct any information provided on the platform. Past performance information, historical data, or any forward-looking statements are as of their dates and Fintra makes no representation that they remain accurate or that they will be updated.

12.6 Professional Advice: Fintra is not providing legal, tax, or accounting advice. Any financial calculators or tools are for illustrative purposes. You may need to consult professional advisors for guidance tailored to your circumstances. Fintra disclaims any warranty that using the service will ensure compliance with laws or financial goals.

12.7 Beta Services: If Fintra offers any beta or trial features (services not yet officially released), you understand they are experimental and provided “as is” without any warranties whatsoever. They may be changed or discontinued at any time without notice. Use beta features only if you accept the risk of possible malfunctions.

12.8 External Factors: Fintra does not warrant that it can predict, or that the service can shield you from, external factors that affect markets or your ability to use the platform. For example, things like regulatory trading halts, stock exchange outages, telecommunications failures, force majeure events (see Section 20), or third-party actions are beyond our control and are not warranted against.

12.9 No Warranty on Third-Party Services: As noted, Fintra makes no warranties regarding any third-party services integrated with or accessible through our platform. Use of third-party services is solely at your risk and subject to their terms.

12.10 Consumer Rights: If you are considered a “consumer” under certain laws, you may have statutory rights that are not disclaimed. These Terms are not intended to override any non-waivable rights you might have under law. In such cases, the scope and duration of any statutory warranty is limited to the minimum permitted by law.

In summary, Fintra provides its innovative financial gateway services in good faith and with diligence, but we cannot promise perfection or outcomes. All warranties not expressly stated are disclaimed to the extent permissible by law.

13. Limitation of Liability

13.1 Exclusion of Certain Damages: To the maximum extent permitted by applicable law, Fintra (including its directors, officers, employees, and agents) shall not be liable for any indirect, incidental, special, consequential, or punitive damages whatsoever, arising out of or in connection with your use of (or inability to use) any Fintra service or these Terms. This exclusion applies regardless of the cause of action (whether in contract, tort (including negligence), strict liability, or any other theory). Such excluded damages include, but are not limited to: lost profits, lost or delayed trading opportunities, loss of revenue, loss of data, trading losses, loss of goodwill, or the cost of obtaining substitute services. For example: - Fintra will not be liable for your losses if the platform was unavailable or slow at a moment you intended to execute a trade and you claim a missed opportunity. - Fintra is not liable for losses due to market movements, even if those movements were exacerbated by a forced sale or technical glitch. - If unauthorized access to your account occurs (e.g., through hacking or your own credential compromise) and results in loss, our liability is limited as per this Section and Section 3.5, unless law states otherwise. - Fintra will not be liable for consequential effects of any service suspension, termination, or changes as described in these Terms.

13.2 Cap on Liability: Fintra’s total cumulative liability to you for any and all claims arising from or related to the service or these Terms shall not exceed the amount of fees you have paid to Fintra for services in the six (6) months immediately preceding the event giving rise to the claim [40] (or BDT 10,000, whichever is lower, if no fees were paid, as an agreed reasonable pre-estimate of any possible loss). If the claim relates to a specific transaction, Fintra’s liability shall not exceed the commission earned by Fintra on that transaction. This limitation applies to all claims of every kind, whether based on warranty, contract, statute, tort (including negligence) or otherwise.

13.3 Exceptions: The above limitations of liability shall apply to the fullest extent permitted by law. However, some jurisdictions do not allow the exclusion or limitation of certain warranties or liabilities, so some of the above disclaimers or limitations may not apply to you if prohibited by law. In such cases, Fintra’s liability will be limited to the smallest amount permitted by law. Nothing in these Terms shall limit or exclude Fintra’s liability for gross negligence, willful misconduct, or fraud, or for any other liability that cannot be excluded under Bangladeshi law.

13.4 No Liability for Force Majeure: Fintra shall not be liable for any failure or delay in performing its obligations under these Terms due to causes beyond its reasonable control (force majeure events), as further described in Section 20.4.

13.5 Reliance on Disclaimers: You acknowledge that Fintra has set its fees and provides access to its services in reliance on the disclaimers of warranty and the limitations of liability set forth herein, and that these terms fairly allocate risk between us. In the absence of such limitations, the fees for using Fintra’s services or the conditions of offering might have been different.

13.6 User’s Responsibility: You assume full responsibility for any decisions you make based on information obtained through the platform, and you use the platform at your own risk. If you are dissatisfied with any aspect of Fintra’s service, your sole and exclusive remedy is to discontinue use of the services (subject to settling any obligations). The limited remedies in these Terms are intended to apply even if they fail of their essential purpose.

14. Indemnification

You agree to indemnify, defend, and hold harmless Fintra, its parent company, subsidiaries, affiliates, and their respective directors, officers, employees, agents, and licensors (the "Indemnified Parties") from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable legal fees) arising out of or in any way connected with:

• Your access to or use of the services, including any actions taken through your account.
• Your violation of these Terms or any applicable law, regulation, or rule.
• Your infringement of any intellectual property or other rights of Fintra or any third party.
• Any misrepresentation or misleading information provided by you to Fintra.
• Any trading activity or investment decisions made by you.

Fintra reserves the right, at its own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you will cooperate with Fintra in asserting any available defenses. This indemnification obligation will survive the termination of these Terms and your use of the service.

14. Indemnification

You agree to indemnify, defend, and hold harmless Fintra, its parent, affiliates, and their respective officers, directors, employees, and agents (each an “Indemnified Party”), from and against any and all losses, liabilities, claims, demands, damages, costs, and expenses (including reasonable attorneys’ fees and court costs) arising out of or related to:

• 14.1 Your breach of any provision of these Terms or any other agreement you have with Fintra (including the breach of any representations or warranties you have made herein).
• 14.2 Your violation of any applicable law or regulation in connection with your use of Fintra’s services, or your violation of any rights of a third party (for example, any actual or alleged infringement of a third party’s intellectual property or privacy rights due to content you provided).
• 14.3 Any misuse of Fintra’s platform by you or someone using your account (for instance, using the platform in an unauthorized way to harm Fintra or others, introducing viruses, performing attacks, etc.).
• 14.4 Any third-party claims brought against Fintra as a result of your actions. For example, if another person or entity sues Fintra because of something you did (such as an illegal trade, defamatory content you posted, or a fraudulent act), you will cover all costs and liabilities arising from that claim.
• 14.5 Any transaction dispute or issue between you and a third-party (such as a payment provider, or another user if such interactions exist) where Fintra is dragged into the dispute due to your conduct.

Under this indemnity, you agree to reimburse each Indemnified Party on demand for any costs or liabilities such party incurs in connection with any such claims. Fintra reserves the right to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you will cooperate with Fintra in asserting any available defenses. This indemnity will survive the termination of your Fintra account or of these Terms.

15. Suspension and Termination of Service

15.1 Suspension or Restriction by Fintra: Fintra may, at its discretion and at any time, suspend, block, limit, or restrict your access to the services or certain features without prior notice, under the following circumstances (among others): - If we suspect that you have violated any provision of these Terms or any applicable law or regulation. - If your account is subject to an ongoing investigation for fraudulent or suspicious activities, or if we detect unusual trading patterns that warrant review. - If required by a regulatory authority, law enforcement, or court order (for example, upon receiving a BSEC directive to freeze assets, or a court injunction). - If you have not complied with requests for information or documentation (e.g., failure to update KYC, or to respond to margin calls as described). - If maintaining your account or transaction would expose Fintra to a regulatory or financial risk (for example, if you are identified as a sanctioned person or if you file for bankruptcy). - In cases of technical emergencies or security incidents (e.g., we might temporarily suspend login if we suspect a breach, until the issue is resolved). During suspension, you may be unable to execute trades, withdraw funds, or access the account. Fintra will endeavor to notify you (after the fact or as permitted) of any such suspension and the reason, unless legally restricted from doing so. Suspension is intended to protect you, Fintra, and the market, and Fintra shall not be liable for any losses due to suspension in accordance with this provision, as it may be mandated or necessary.

15.2 Account Termination by Fintra: Fintra reserves the right to terminate your account and this Agreement by providing notice (in writing or electronically) under the following circumstances: - Breach: If you materially breach these Terms or other agreements with Fintra and fail to rectify the breach within any reasonable timeframe specified by us (if the breach is rectifiable). - Prolonged Inactivity: If your account remains inactive (no logins or transactions) for a very long period (e.g., 12+ months) and has a zero balance, we may close the account after notice. (Accounts with assets won’t be closed without exhausting efforts to contact you or escheatment procedures as per law.) - Regulatory Requirement: If laws change or regulatory actions require Fintra to cease providing services to you (for example, if you move to a jurisdiction where we’re not permitted to offer service, or if BSEC revokes our ability to service you). - Business Decision: If Fintra decides to discontinue offering the brokerage services entirely or in your jurisdiction (e.g., Fintra exits the business or merges). In such cases, we will give you advance notice to withdraw assets or transfer to another broker. - Risk/Abuse: If we determine that continuing our relationship with you exposes us to undue risk or brand damage (e.g., if you are found engaging in fraud, abusive behavior towards our staff, or other misconduct). When Fintra terminates an account, we will lift any suspension to allow you to withdraw any remaining eligible funds or securities (except to the extent they may be held or frozen due to disputes or legal reasons). You will be given instructions on how to transfer your securities (e.g., transferring your BO account to another broker) and withdraw your cash. If you do not act within the time specified in the notice, Fintra may take steps to return assets via cheque to your address on file, or as per regulatory guidance (for instance, unclaimed assets might be transferred to a government-designated fund after a certain time as per law).

15.3 Account Closure by Client: You have the right to close your Fintra account at any time, provided that: - You have no pending obligations – all trades have settled, any loans (margin/bridging) are fully repaid, and there are no disputes or investigations ongoing related to your account. - You submit an account closure request in the prescribed manner (this may include submitting a written request or using an in-app feature, and completing any required form for BO account closure or transfer). Upon receiving your request, Fintra will guide you to withdraw any remaining cash and transfer out or sell any securities. Note that closing your account will not affect any rights or obligations accrued prior to closure. Any provisions of these Terms which by their nature should survive termination (such as indemnities, limitation of liability, outstanding payment obligations, dispute resolution clauses, etc.) will survive the closure of your account.

15.4 Effect of Termination/Suspension: Upon termination of your account, your right to use Fintra’s services will cease. Any outstanding transactions or orders may be cancelled. Any open positions you have might be closed out (especially if termination is due to breach or risk concerns). Fintra will not be liable to you for any losses resulting directly from the closure of positions due to account termination (for instance, if we sell your securities at prevailing market price during termination because you did not transfer them out). We will send you a closing statement reflecting the disposition of assets.

15.5 Dormant Accounts: If your account has a positive balance of cash or securities but you have not logged in or responded to communications for an extended period (as defined by Fintra’s policy or regulation, e.g. 2-3 years), Fintra may classify the account as dormant. Dormant accounts might be subject to additional verification upon reactivation. Fintra will attempt to reach out via last known contact details. If required by law, unclaimed assets in dormant accounts may eventually be reported or remitted to a government authority after a prescribed dormancy period – we will comply with such laws while attempting to protect your rights.

15.6 Recovery of Costs: If Fintra terminates or suspends your account due to your breach or illegal activity, we reserve the right to recover any direct costs we incur as a result of your actions. This might include costs of investigation, legal fees, or losses we suffered from handling your trades contrary to rules.

15.7 No Affect on Transactions Prior to Termination: Termination does not retroactively affect valid transactions that occurred prior to termination, or any rights, remedies, or obligations that may have arisen prior to termination. For example, if you executed a trade and then your account was terminated, you are still entitled to receive the securities or proceeds of that trade, or conversely still obligated to settle it.

15.8 Suspension of Specific Services: Instead of full account suspension, Fintra may suspend specific services or features. For example, Fintra could suspend your margin facility (requiring you to operate on cash-only basis) without suspending overall trading, if you breach margin terms but otherwise behave well. Similarly, Fintra might disable the use of certain payment methods for you if issues are detected, etc. The terms of suspension can vary case by case.

15.9 Appeals: If you believe your account was suspended or terminated in error, you may contact Fintra’s customer support or compliance department to appeal the decision. We will review your appeal in good faith, but our determination will be final. If a suspension is lifted as a result, you will regain access per our instructions.

16. Service Modifications and Future Features

16.1 Right to Modify or Discontinue Services: Fintra is a dynamic platform and we continually seek to innovate. We reserve the right to add, modify, suspend, or discontinue any aspect of our services or features at any time. This includes existing core features of the trading platform as well as ancillary offerings. Changes may be due to technological upgrades, changes in law, shifts in business strategy, or user feedback. Fintra may modify or discontinue services with or without notice, without liability to you or any third party for service changes. However, where feasible and significant, we will endeavor to provide advance notice (for example, if we plan to discontinue a popular feature or an entire line of service, we will notify users via email or in-app alert).

16.2 Introduction of New Services: Fintra may introduce new features or programs to enhance user experience, such as: - Loyalty or Rewards Programs: e.g., schemes offering benefits for frequent traders or long-term clients (points, discounts, priority support, etc.). - Educational Tools: e.g., new learning modules, investor forums, webinars, or simulation trading for educational purposes. - Advisory or Managed Services: e.g., robo-advisory, model portfolios, or access to human advisors for premium clients. - Expanded Financial Products: e.g., new asset classes (bonds, mutual funds, derivatives) if Fintra obtains relevant licenses or partnerships. Each new service may come with its own terms and conditions or require acceptance of an addendum to these Terms. We will make those terms available and by opting into use of those new features, you agree to any additional terms. If any new service terms conflict with these Terms, the specific terms for the new service will govern for that service to the extent of the conflict.

16.3 Discontinuation of Features: Fintra’s right to discontinue features also extends to the above new services. For example, if Fintra launches a loyalty program as a trial, we may later decide to modify or withdraw it. Similarly, if an educational tool is not widely used, we might remove it or replace it. If an advisory service is introduced but later regulatory environment changes, we might suspend it. We will not be liable for the removal of or disabling of access to any such offerings, except to ensure that any of your vested benefits or funds tied up in the feature are appropriately handled (for instance, if we were to discontinue a particular savings or interest feature, any funds of yours in that feature would be returned to your main account).

16.4 Updates and Software Changes: Fintra may deploy changes to its user interface, trading engine, order types, or other software components. These changes could alter the user experience. We may add or remove support for certain device platforms or operating systems. Users are expected to stay updated with the latest version of the application for optimal security and performance. If a change materially alters how you use the service (for instance, a new order type or a new layout), we may provide a tutorial or guide, but it is ultimately your responsibility to familiarize yourself with updated functionalities. We will not be responsible for losses that occur due to unawareness of a modified process when we have reasonably notified users or provided documentation.

16.5 Temporary Features: Some features might be launched in beta or promotional phase (e.g., a limited-time zero commission trading offer, or a beta test of a new charting tool). These can be changed into paid features or removed after the trial. Fintra is not obligated to continue a feature at a particular price or free forever unless explicitly promised. We also reserve the right to charge fees for new features or services that were initially free, with appropriate notice to you. (For example, if we introduce an advanced analytics suite free for a year, we may later include it as part of a premium subscription).

16.6 Service Limits: Fintra may impose limits on certain features (e.g., number of watchlists you can create, number of API calls if we provide an API, etc.) and can change those limits. Such modifications are in place to ensure the stability and fairness of use among all users.

16.7 Communication of Changes: Any significant changes to services or introduction/discontinuation of features will be communicated through one or more channels: posting on our website, in-app notifications, and/or email to your registered address. We will notify you of any major changes through the app, our website, or via email. It is important that you keep your contact information up to date to receive such notices.

16.8 Client’s Recourse: If you are dissatisfied with a modification or discontinuation of a service, your sole recourse may be to cease using that service or close your account. Fintra will not be liable for compensation due to changes in business offerings, as this is an inherent aspect of the technology and financial service industry.

17. Amendments to Terms

17.1 Right to Amend: Fintra has the right to amend, update, or change these Terms at any time. As our business and regulatory environment evolves, we may need to make changes to reflect new services, new laws, or new conditions. Mika Securities’ terms explicitly note they reserve the right to amend terms at any time, and similarly Fintra reserves such right. Any amendment will become effective once the updated Terms are posted on our website or otherwise communicated to you, unless otherwise specified by Fintra.

17.2 Notification of Changes: When we update these Terms, we will take appropriate measures to inform you. This may include: - Posting the revised Terms on Fintra’s website or app (with a new “Last Updated” date). - Sending an email to your registered email address summarizing the changes or indicating that terms have changed. - Providing a notification upon login requiring you to review the new Terms. For material changes (those that affect your rights or obligations significantly), we will endeavor to give advance notice if feasible. Minor changes (clarifications, typographical corrections, enhancements that do not negatively impact user rights) may be made with or without direct notice, by posting the updated Terms.

17.3 Acceptance of Changes: After we update the Terms, your continued use of Fintra’s services will constitute acceptance of the updated Terms. If you do not agree with the changes, you must cease using the services and may terminate your account as per Section 15. Always review notices of changes carefully. If required by law, we might obtain your explicit agreement for certain types of material changes (for example, if a change involves a new consent for data use, or introducing arbitration clause, etc. in jurisdictions requiring opt-in).

17.4 Regulatory Changes: In some cases, changes to these Terms may be driven by new laws or directives by regulatory authorities. Such changes might need to be implemented on short notice to ensure compliance. Fintra’s compliance with law will take precedence – if any provision of these Terms is required to change to conform to law, it can be changed effective immediately, with retrospective effect if necessary/mandated.

17.5 Historic Versions: For transparency, Fintra may maintain archives of previous versions of these Terms. You have the right to request a copy of prior terms you agreed to, if needed for reference. However, the latest version will govern the relationship going forward.

17.6 No Oral Amendments: Any amendment to these Terms must be made by Fintra through the formal process described. Fintra employees or agents (e.g., customer support staff) are not authorized to modify the Terms via oral or email statements. If you believe you have an arrangement with Fintra that alters these standard Terms, it must be documented in a written agreement signed by an authorized officer of Fintra.

17.7 Severability and Conflict: If any changes to Terms conflict with earlier provisions or other documents, the most current Terms (or any specifically negotiated agreement you have with Fintra) will prevail. If any part of the updated Terms is declared invalid, the rest remains enforceable as detailed later in Section 20.2.

18. Governing Law and Dispute Resolution

18.1 Governing Law: These Terms and any disputes arising under or related to these Terms or the use of Fintra’s services will be governed by and construed in accordance with the laws of the People’s Republic of Bangladesh, without regard to its conflict of laws principles. The governing law clause means Bangladeshi law will apply to interpret this contract and to adjudicate any disputes, even if you access the services from outside Bangladesh (noting that Fintra primarily serves the Bangladesh market). If you are using the services from another jurisdiction, you are responsible for compliance with local laws, but the agreement between you and Fintra remains under Bangladesh law.

18.2 Jurisdiction: You agree that any dispute, controversy, or claim arising out of or in connection with these Terms, including any question regarding their existence, validity, or termination, shall be subject to the exclusive jurisdiction of the courts of Bangladesh[43]. Typically, major legal actions will be brought in the courts of Dhaka, Bangladesh, given that is where Fintra’s headquarters and principal operations are located, unless otherwise required by law. By agreeing to these Terms, you waive any objection to the venue and jurisdiction of these courts on the grounds of inconvenience or otherwise.

18.3 Alternative Dispute Resolution (ADR): Fintra may encourage resolving disputes amicably. We and you agree to attempt to resolve disputes or grievances through good faith negotiations or mediation before resorting to litigation[44]. If a dispute arises, the complaining party should notify the other in writing, summarizing the issue and desired remedy. The parties shall then attempt to negotiate in good faith. If those negotiations do not resolve the matter, they might consider mediation by a neutral third-party in Dhaka (if both sides agree). However, this clause does not preclude either party from seeking immediate injunctive relief from a court if necessary to prevent significant harm. (for example, if you misappropriate our intellectual property or we need to freeze an account due to legal order, etc.)

18.4 Investor Complaint and Arbitration (if any): The Bangladesh Securities and Exchange Commission and stock exchanges may have an investor complaint resolution forum. For instance, DSE has an Investor Complaint cell and an Arbitration mechanism for broker-client disputes. If such a mechanism is available and applicable to your case, you may opt to use it. Fintra will abide by the dispute resolution mechanisms mandated by BSEC and exchanges. Some disputes (especially relating to trades, settlements) might be resolved through DSE’s arbitration as per their regulations. Utilizing an exchange’s arbitration or dispute resolution forum does not waive your right to go to court, but the decisions from such forums may be binding as per the regulations you agreed to when opening a BO account and trading (commonly, the BO account opening forms incorporate clauses about dispute resolution via the exchange). You should refer to your BO account Terms or consult with us if you have a question on this.

18.5 Legal Fees and Costs: In any litigation or arbitration between you and Fintra, the prevailing party shall be entitled to recover its reasonable attorneys’ fees and other costs (including court fees, arbitration fees) from the other party. This discourages frivolous claims by ensuring the losing party bears the financial burden of dispute resolution.

18.6 Time Limit to Bring Claims: To the extent permitted by law, any claim or cause of action arising out of or related to the use of Fintra’s services or these Terms must be filed within one (1) year after such claim or cause of action arose, or be forever barred. (For example, if there was an unauthorized trade on your account on January 1, 2025 and you discovered it then, any claim relating to it should be brought by January 1, 2026.)

18.7 Waiver of Jury Trial (if applicable): As an extension of the jurisdiction clause, and to the extent allowed by Bangladeshi law, if there were to be a judicial proceeding, both parties knowingly waive any right to a trial by jury, ensuring any case is decided by a judge.

18.8 Public Injunctive Relief Waiver (if applicable): These Terms are between you and Fintra only, and you cannot seek to act as a private attorney general or in any other representative capacity in court, nor seek remedies that affect users other than you.

18.9 Enforcement of Judgments: Any judgment or order obtained from the courts of Bangladesh may be enforced in any other jurisdiction as needed. Conversely, if you are a foreign national and a judgment is obtained against you, Fintra may seek to enforce it in your home country or any jurisdiction where you have assets.

18.10 Acknowledgment: You acknowledge that the venue and jurisdiction provision is a material term to Fintra (a Bangladesh-based service) offering services to you, and that by agreeing to these Terms, you have taken into account the possible inconvenience of litigating in Bangladesh and are willing to proceed regardless.

19. Risk Disclosure and Acknowledgement

Trading in securities and using leveraged facilities involves significant risk. By using Fintra’s services, you acknowledge and agree to the following risk disclosures:

19.1 Market Risk: The value of securities (stocks, bonds, etc.) is subject to market fluctuations. Prices can rise or fall rapidly and unpredictably. There is no guarantee that you will make a profit on your investments; you may incur losses, including possibly losing your entire principal. Past performance of any security or the market is not indicative of future results.

19.2 Volatility and Liquidity: Some stocks or instruments may be very volatile or thinly traded. You may not be able to sell your holdings at your desired price or time due to lack of liquidity or trading halts. Sudden news or events (earnings reports, political events, regulatory changes) can lead to sharp price movements. You must be prepared for the possibility of sharp losses.

19.3 No Guaranteed Returns: Fintra does not guarantee any profits or returns. Any suggestions of potential upside (through research tools or otherwise) are speculative. Trading and investment carry risk, and there are no assurances of success. Beware of anyone (inside or outside Fintra) making “get rich quick” claims; they are not sanctioned by Fintra.

19.4 Margin and Leverage Risks: If you engage in margin trading or take loans: - Magnified Losses: Margin amplifies both gains and losses. A small market movement against you can have a big impact on your equity. If the value of your securities falls, you may owe more money than you invested. - Margin Calls: Fintra may issue margin calls that require you to add funds or sell assets on short notice. If you do not or cannot, Fintra will liquidate positions and you are responsible for any remaining debt. These liquidations could occur at unfavorable prices. - Interest and Costs: Borrowing costs will reduce your returns (or increase losses). High interest over time can eat away profits. - Eligibility and Liquidation: By using margin, you confirm you meet eligibility (e.g., sufficient experience and capital as per regulations) and accept that Fintra can liquidate without additional consent to protect loan integrity.

19.5 Systemic and Unsystematic Risk: There are macro-level risks (recession, regulatory changes, war, etc.) that can affect the entire market or multiple asset classes. There are also company-specific risks (management failure, fraud, sector downturns). Diversification can mitigate some unsystematic risks but not all. Even diversified portfolios can lose value in broad market downturns.

19.6 Trading Systems Risk: Using an electronic trading platform like Fintra carries technology-related risks: - Execution Risk: Orders might not execute at the expected time or price due to latency, system outages, or market conditions (fast markets, gaps). - Connectivity Risk: If you lose internet connectivity or the platform faces downtime, you may not be able to place or modify orders. You should have alternative ways to contact us (like phone broking as a backup if provided) in such cases. - Data Errors: Market data displayed might lag or have errors. You should use caution especially in volatile conditions where prices move quickly. - Cybersecurity Risk: Though Fintra secures its systems, no system is immune to hacking. A breach could, in worst case, impact your account (we mitigate heavily, but risk is theoretical). - Force Majeure: Technical failures, communication failures, or other events (fire, natural disasters) could disrupt trading.

19.7 Regulatory and Political Risk: Laws and regulations can change, potentially affecting your investments (e.g., a new tax on stock trades, or a sector being restricted). Political instability or government actions (like demonetization, changes in monetary policy) can influence the markets adversely.

19.8 Currency Risk: If you are an investor dealing in instruments or companies that have currency exposure (for instance, a company earning in foreign currency), currency exchange rate fluctuations can impact values. For foreign investors using Fintra (if permitted), changes in currency exchange rates between your home currency and BDT will affect your actual returns.

19.9 Fraud/Scam Risk: There is risk of fraudulent schemes in the market (pump-and-dump schemes, ponzi schemes disguised as stock tips, etc.). You should be wary of unsolicited advice or tips. Validate information through credible sources. Fintra’s platform may give you tools, but cannot prevent you from falling prey to external scams if you choose to follow them.

19.10 Fintra Platform Limitations: Fintra strives to provide quality tools (e.g., stop-loss orders to manage risk, portfolio analytics to see exposure), but using them correctly is your responsibility. A stop-loss order is not guaranteed to execute exactly at the price set; if the market gaps down, you could sell at a much lower price. Similarly, our analytics may not account for all scenarios. Use all tools as aids, not guarantees.

19.11 Knowledge and Suitability: By trading, you confirm that you understand the basics of the market and the particular securities you invest in. Some products might be more complex (if Fintra ever offers derivatives or otherwise). Ensure you only trade what you understand. Fintra generally does not assess suitability on each trade (unless required by law for certain products), so the onus is on you to ensure an investment is right for you.

19.12 No Protective Insurance: Funds and securities in your Fintra account are not covered by any depositor insurance scheme (like bank deposits are). While your assets are held in your BO account at CDBL, which is segregated, if, for example, there is broker misconduct or insolvency, the recovery might depend on legal processes. There is an Investor Protection Fund maintained by exchanges for broker defaults, but it has limits. Understand that investing risk includes the small risk of intermediary failure.

19.13 Communication Risks: Instructions or communications you send to Fintra (via email, chat, etc.) may face delays or might not reach us. For urgent matters, always confirm we received and acknowledged. Fintra is not responsible for acting on instructions that we did not actually receive or were delayed in transit.

By acknowledging these risks, you confirm that you are entering the market with eyes open to potential losses and are not relying on Fintra to prevent or warn you of all risks. Fintra provides a gateway and tools, but the decisions and the consequences are ultimately yours. We encourage you to invest prudently, consider your risk tolerance, and invest only funds you can afford to risk.

20. Miscellaneous Provisions

20.1 Entire Agreement: These Terms (along with any additional rules, policies, or agreements expressly incorporated by reference or provided to you in the context of specific services) constitute the entire agreement between you and Fintra regarding the services. It supersedes and replaces any prior or contemporaneous understandings, agreements, or communications (whether oral or written) relating to the subject matter. You acknowledge that you have not relied on any statement, representation, or warranty that is not expressly set out in these Terms. (For instance, any assurances made by any Fintra sales or support personnel that contradict the Terms are not binding).

20.2 Severability: If any provision of these Terms is held to be invalid, illegal, or unenforceable under applicable law by a court of competent jurisdiction, that provision shall be deemed severed (removed) to the minimum extent necessary, and the remaining provisions shall continue in full force and effect. The parties shall endeavor in good faith to replace any invalid or unenforceable provision with a valid one that, to the extent possible, achieves the original business purpose and intent. For example, if a court finds the limitation of liability excessive in a certain scenario, it might enforce it to the extent it deems reasonable, and the rest of the Terms remain valid.

20.3 No Waiver: No failure or delay by Fintra in exercising any right, power, or remedy under these Terms shall operate as a waiver thereof. Any waiver or modification of a provision of these Terms will be effective only if in writing and signed by Fintra (or communicated by us in an authorized manner, like an updated Terms version). If Fintra overlooks a breach by you of these Terms, it does not mean we waive our rights to enforce that or any subsequent breach. Similarly, specific waiver of one condition does not mean waiver of any other.

20.4 Force Majeure: Fintra shall not be liable for any delays or failure to perform any obligation under these Terms if such delay or failure results from events or circumstances beyond our reasonable control, including but not limited to: acts of God (natural disasters, floods, earthquakes, fire, epidemic or pandemic (including COVID-19 related restrictions), acts of government or regulatory authorities (e.g., trading halts, currency controls), war, terrorism, civil unrest, labor strikes or disputes, power failures, or disruption of communication or information systems (including hacking, cyberattacks, internet outages). During such force majeure events, our obligations shall be suspended to the extent and for the duration that the performance is affected. We will make reasonable efforts to resume full performance as soon as practicable and may implement disaster recovery plans where appropriate.

20.5 Assignment: You may not assign or transfer any of your rights or obligations under these Terms to any third party without Fintra’s prior written consent. Any attempted assignment without consent will be null and void. Fintra may assign or transfer its rights and obligations under these Terms to an affiliate, successor-in-interest, or in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all assets related to the services, without requiring your consent. In the event of such assignment by Fintra, the Terms will continue to operate to the benefit of the successors or assigns.

20.6 Relationship of Parties: Nothing in these Terms shall be deemed to constitute either a partnership or agency relationship between you and Fintra. You and Fintra are independent contractors, and neither party is authorized to act as agent or bind the other party except as expressly stated in these Terms. For example, using our brokerage service does not make Fintra your agent in a fiduciary sense beyond executing your instructions (we act as your broker to the extent of executing trades, but we are not a trustee or advisor unless explicitly agreed).

20.7 No Third-Party Beneficiaries: These Terms are for the benefit of you and Fintra only. Except as expressly provided (for example, indemnified parties in Section 14), no other person or entity shall have any rights to enforce any term of this Agreement. In other words, a person who is not a party to these Terms (including any user’s family members, or any counterparty to a trade) has no right to rely upon or enforce any of these Terms.

20.8 Communication and Notices: - Electronic Notices: You agree that Fintra may provide notices or other communications to you electronically, such as by email to the address on record, via SMS to your registered mobile number, via in-app notifications, or by posting notices on our website/app. Electronic communications shall be deemed to be received by you when Fintra sends them or posts them, whether or not you actually read them, provided we sent to the contact information you provided. It is your responsibility to keep your contact details up to date. - Written Notices: If we ever require to send you a legal notice in paper form, we will use your last known physical address. Similarly, any notices you send to us in writing should be mailed to our head office address (Attention: Legal/Compliance Department) as listed in Section 21 or on our website. - Language: These Terms are drafted in English. If we provide translations in Bengali or other languages, it is for courtesy; in case of discrepancies, the English version shall prevail for interpreting these Terms. - Customer Support: For day-to-day communications (queries, complaints), refer to Section 21 for contact info.

20.9 Rights and Remedies: Except as otherwise provided, the rights and remedies of Fintra provided in these Terms are cumulative and not exclusive of any other rights or remedies that may be available under law. Any specific right or remedy mentioned does not preclude Fintra from exercising any other right or remedy.

20.10 Headings and Interpretation: Section headings in these Terms are for convenience only and do not affect the interpretation of any provision. In these Terms, “including” means “including without limitation”. References to statutes or regulations include all amendments. Words in singular include plural and vice versa.

20.11 Binding Effect: These Terms are binding upon and will inure to the benefit of the parties hereto and their respective successors and permitted assigns.

20.12 Execution and Acceptance: These Terms do not need to be separately signed. Your acceptance is confirmed by clicking an “I Agree” (or similar) button when creating an account, or by actually using the services after these Terms have been made available to you. Such action constitutes a valid execution of this Agreement, legally equivalent to a signed, written contract.

20.13 Records and Evidence: Fintra’s records (electronic or otherwise) of the transactions, orders, communications, and these Terms are considered accurate and binding. You shall not dispute the admissibility or enforceability of Fintra’s records in any legal proceeding on the basis that such records are electronic or not originals.

20.14 Survival: All provisions of these Terms which by their nature should survive termination of your account or these Terms (including, without limitation, accrued rights to payment, confidentiality obligations, warranty disclaimers, indemnities, and limitations of liability, dispute resolution clauses) shall survive and remain in effect after such termination.

20.15 Execution Time and Place: The contract between you and Fintra is deemed entered into at Fintra’s registered office in Dhaka, Bangladesh, and the time of acceptance is the time at which you first agreed to these Terms or first used the services (whichever earlier).

By using Fintra’s services, you confirm that you have read, understood, and agree to these Terms and Conditions. If you have any questions or require clarifications regarding these Terms, please contact us before proceeding.

21. Contact and Support Information

Fintra is committed to being a trusted and accessible financial gateway for our clients. If you have any questions, concerns, or require assistance regarding these Terms or any of our services, please do not hesitate to contact us:

• Customer Support Center: +8809606 268866 (Operating hours: 9 AM - 6 PM). You can call this number for trading assistance, technical support, or any inquiries. Our support staff can guide you or escalate issues as needed.
• Email Support: [[email protected]] (for general queries) or [[email protected]] (for queries regarding these Terms, legal, or compliance issues). Please use the email associated with your account when contacting us and include your account number or registered phone for verification.
• Head Office (Physical Address): FINTRA Securities Limited, Cotton House (Level 01), House No. 02, Road No. 113/A, Gulshan-2, Dhaka-1212, Bangladesh.
• Motijheel Branch: 9-E Motijheel C/A, 2nd Floor (North Side), Dhaka-1000, Bangladesh. (Note: Branch offices can provide in-person customer service, account opening help, and submission of documents.)
• Website: Visit our official website at www.fintra.com.bd for information, or the logged-in client portal for self-service options. The website includes sections like FAQ, How-to Guides, and announcement pages for any service updates.
• In-App Help: If you are using the Fintra mobile app or web portal, there is a help/support section where you can initiate a live chat or submit a ticket. Our customer service team typically responds within 48 hours.
• Social Media: Fintra maintains official support presence on platforms like Facebook (FINTRA Securities Limited page). While you can reach out for general queries via these channels, for account-specific issues we will direct you to secure channels.

Complaint Escalation: If you have a complaint that is not resolved to your satisfaction by our customer support, you may ask for the issue to be escalated to a manager or to our Compliance Department. Fintra has an internal dispute resolution mechanism to address client grievances promptly and fairly. We will provide a written response to formal complaints within a reasonable time. If you remain unsatisfied, you may consider lodging a complaint with the DSE or BSEC’s investor protection forums as appropriate.

Communication Language: We offer support in both English and Bengali (Bangla) for your convenience. Please let us know your preferred language when contacting us.

Documents and Notices: Should you need to deliver any legal notices or documents to Fintra (e.g., court orders, claims, or account closure forms), please send them to the Head Office address listed above, Attn: Legal Department. Also send a copy via email for faster acknowledgement.

Fintra values transparency and client trust. We encourage you to reach out with any questions about these Terms, as understanding your rights and obligations is crucial for a confident and secure trading experience with us.

Thank you for choosing Fintra as your innovative financial partner in Bangladesh’s capital market. We are here to support your trading journey with clarity, confidence, and compliance.