Part A — The basics

1.1 These Terms of Use (“Terms”) are a legal agreement between you and Vantar Inc. They govern your access to and use of:

• vantar.co and any other website we operate
• the Vantar web app
• the Vantar mobile apps (published as “Vantar - Invest & Trade”)
• all content, data, tools, features and communications we make available through them

Together, these are the “Platform”.

1.2 By creating an account, selecting “I agree”, or accessing or using the Platform, you confirm that you have read, understood and agree to be bound by these Terms and our Privacy Policy. If you don’t agree, you must not use the Platform.

1.3 If you use the Platform on behalf of an organization, you represent and warrant that you have authority to bind that organization to these Terms. In that case, “you” refers to both you and the organization, and the organization is the account holder. If you do not have that authority, you must not use the Platform on its behalf, and you will be personally responsible for any losses we incur as a result. We may require evidence of your authority and information about the organization and its beneficial owners at any time.

1.4 Please keep a copy of these Terms. You can see the current version at any time at vantar.co/legal/terms.

In these Terms:

• “Account” means your Vantar profile and every account or service you can reach through it, including your brokerage account, any Auto-Invest account and your wallets.
• “Account Agreements” means the agreements that govern particular services, listed in section 4.
• “Alpaca” means Alpaca Securities LLC, member FINRA/SIPC.
• “Content” means any information, data, text, graphics, charts, prices, news, research, educational material, AI-generated summaries, software or other material on the Platform.
• “Securities” means stocks, exchange-traded funds and any other investment product made available through the Platform.
• “Vantar”, “we”, “us” and “our” mean Vantar Inc. and, where the context requires, its affiliates in the Gen Financial group.
• “Wyrr” means the Wyrr entity that provides your wallets and related payment services.
• “you” and “your” mean the person who uses the Platform or holds an Account.

3.1 Vantar Inc. operates the Platform. Vantar Inc. is registered with the U.S. Securities and Exchange Commission as an investment adviser. Registration doesn’t imply a certain level of skill or training.

3.2 Vantar Inc. is not a broker-dealer, a bank, a money transmitter or a payment service provider. Different companies provide the services you can reach through the Platform:

3.3 Protection. Securities in your brokerage account are protected by SIPC up to its limits. SIPC doesn’t protect against losses in market value. Cash in the Cash Sweep Program may be eligible for FDIC insurance at program banks, up to the limits described in the program terms. Wallet balances aren’t protected by SIPC or FDIC insurance.

4.1 These Terms apply alongside the following (the “Account Agreements”):

• the Alpaca Customer Agreement, Alpaca’s Form CRS and Alpaca’s disclosures
• the Auto-Invest Advisory Agreement, Vantar Inc.’s Form CRS and Form ADV Part 2A, if you use Auto-Invest
• the Cash Sweep Program terms
• the Wallet Terms, if you use a wallet
• our Electronic Communications Consent, Fee Schedule, Privacy Policy and Disclosures
• any additional terms shown to you for a particular feature, promotion or product

4.2 Order of precedence. If these Terms conflict with an Account Agreement, the Account Agreement governs for the service it covers. If these Terms conflict with additional terms for a feature, the additional terms govern for that feature.

6.1 One Account per person. You may hold only one individual Account unless we agree otherwise.

6.2 Account types. Depending on where you live and what you’re eligible for, your Account may include:

• Trading: a self-directed brokerage account
• Auto-Invest: a managed portfolio account
• Wallets: USD and NGN wallets

Other account types, such as Trading NGX and Vantar Wealth, may become available later under their own terms.

6.3 Verification. We, Alpaca and our service providers will verify your identity and screen you against sanctions, politically exposed person and fraud databases, at account opening and from time to time afterwards. We may ask for more information or documents at any time.

6.4 Keeping information up to date. You must promptly update your name, address, email, phone number, tax status, citizenship, residence, employment and financial information if they change. You must tell us without undue delay if you become a U.S. person, stop being a U.S. person, or move to another country. Moving may affect which services you can use.

6.5 Trusted contact. We encourage you to name a trusted contact.

7.1 Sign-in methods. You can sign in with Apple, with Google, or with a one-time code sent to your email address, and you can add a password. We may require additional verification, such as device approval or a one-time code, for sensitive actions.

7.2 Your responsibilities. You must:

• keep your devices, email account and sign-in methods secure, and not share them
• use a screen lock on your devices
• not let anyone else access or use your Account
• sign out of shared devices
• keep your operating system and the Vantar app up to date

7.3 Report problems immediately. Tell us at security@vantar.co, or through the app, if:

• you lose a device that has access to your Account
• you think someone has accessed your Account or learned your credentials
• you see a transaction you didn’t make

Telling us quickly helps limit losses.

7.4 Responsibility for activity. To the extent the law and the Account Agreements allow, you’re responsible for all activity carried out through your credentials, including by anyone you let use your device or email account. Your rights for unauthorized transactions are set out in the Account Agreements and under applicable law.

7.5 We’ll never ask for your codes. Vantar will never ask you for your password, one-time code or recovery details by email, text, WhatsApp, social media or phone. We don’t provide support by phone.

9.1 Information only. The Content on the Platform is general information. It isn’t an offer, a solicitation or a recommendation to buy, sell or hold any security, or to follow any strategy. This includes:

• lists, rankings, collections and categories, such as “top movers”, “popular” or themed lists
• charts, price data, ratings, news and research
• Pulse summaries
• watchlists and alerts
• educational material

How a security appears on the Platform, or the order in which it appears, isn’t an endorsement.

9.2 Self-directed accounts. In your self-directed brokerage account, you alone decide what to buy, sell or hold. Neither Vantar nor Alpaca recommends individual trades, reviews whether a trade suits you, or monitors your account for suitability. You’re solely responsible for your investment decisions and their results.

9.3 Advisory services. Vantar Inc. provides investment advice only under a written advisory agreement, such as the Auto-Invest Advisory Agreement, and only for the account that agreement covers. Vantar Inc.’s advisory duties are set out in that agreement and in its Form ADV.

9.4 No legal or tax advice. Nothing on the Platform is legal, tax or accounting advice. You’re responsible for your own tax obligations.

9.5 Risk. All investing involves risk, including the possible loss of principal. Past performance doesn’t guarantee future results. Before investing, read the Disclosures and the risk disclosures for each product, including those for fractional shares, extended-hours trading and leveraged and inverse ETFs.

10.1 Routing to Alpaca. Orders you place through the Platform are transmitted to Alpaca. Alpaca executes, clears and settles them under the Alpaca Customer Agreement and sends your trade confirmations and statements. Alpaca’s order routing and payment for order flow practices are disclosed in its order routing disclosures.

10.2 Acceptance. An order isn’t accepted until Alpaca accepts it. Entering an order in the app doesn’t guarantee it will be accepted or executed, or executed at a particular price.

10.3 Order types. The Platform offers the order types shown in the app, which may include market, limit, stop and stop-limit orders. They may vary by security, session and whether the order is for whole or fractional shares. To help protect you, market orders may be converted to limit orders with a price collar, as described in the app.

10.4 Prices and execution. Prices shown on the Platform may be delayed and may differ from the price at which your order executes, especially when:

• the market is volatile or moving fast
• a security trades thinly
• trading is happening outside regular hours
• the order is for fractional shares

Partial fills can happen.

10.5 Fractional shares. Fractional shares are available only for eligible securities. They can’t be transferred to another broker and may have to be sold before an account transfer. Rights such as voting may be limited.

10.6 Extended-hours trading. Trading before and after regular market hours carries extra risks, including lower liquidity, wider spreads and greater volatility.

10.7 Cancellations. You can ask to cancel or change an open order, but a cancellation can’t take effect if the order has already executed. You’re responsible for orders that execute before a cancellation takes effect.

10.8 Restrictions. We or Alpaca may:

• restrict trading in a security
• refuse an order
• require you to acknowledge risk disclosures, for example before trading leveraged or inverse ETFs
• limit the size or number of orders
• halt trading on the Platform

We’ll do this where we consider it necessary for regulatory, risk, operational or market reasons, including trading halts, corporate actions or abnormal market conditions.

10.9 Errors and clearly erroneous trades. If an exchange or Alpaca cancels or adjusts a trade under clearly erroneous execution rules, or if a trade, price or balance is displayed or processed in error, the trade or entry may be cancelled, corrected or reversed. You must not benefit from an obvious error, and you agree to return any amount credited to you in error.

10.10 Pattern day trading. Frequent day trading may be subject to regulatory restrictions.

10.11 Corporate actions. Dividends, splits, mergers, tender offers and other corporate actions are processed by Alpaca under the Alpaca Customer Agreement. We’ll show voluntary corporate actions in the app where available. We can’t guarantee that every voluntary action will be offered to you.

11.1 Linked bank accounts (U.S.). We use Plaid to let you link a U.S. bank account in your own name. By linking an account, you authorize Plaid to share account information with us, and you agree to Plaid’s End User Privacy Policy. Deposits from your linked account to your buying power are made by ACH debit under an authorization you give to Alpaca.

11.2 Wallets. USD and NGN wallets, currency conversion and USDC funding are provided by Wyrr under the Wallet Terms. Funding options depend on where you live:

• customers in Nigeria fund their NGN wallet with naira
• USDC funds only the USD wallet, never buying power directly

11.3 Moving between wallets and investing. You can move money between your wallets and your buying power in the app. The movement is completed between Wyrr and Alpaca and appears in both records.

11.4 Wallet protection. Wallet balances aren’t protected by SIPC or FDIC insurance until you move them into your brokerage account.

11.5 USDC. USDC isn’t legal tender and isn’t insured by the FDIC or SIPC. USDC transfers can’t be reversed. If you send USDC on the wrong network or to the wrong address, you may lose it permanently.

11.6 Currency conversion. We show you the exchange rate and any fee before you confirm a conversion. Rates change constantly. Any example on our website is illustrative only.

11.7 Only your own money. You may fund your Account only from accounts in your own name. Third-party deposits may be returned, and we may restrict your Account.

11.8 Availability, holds and limits. Deposits may not be available immediately. We, Alpaca or Wyrr may:

• hold, delay, limit, reject or reverse a deposit, withdrawal or transfer to manage risk, prevent fraud or meet legal obligations
• set deposit, withdrawal and transfer limits, which may change

11.9 Returns, reversals and negative balances. If a deposit is returned or reversed, for example for insufficient funds or because the transfer was unauthorized, after you’ve used the funds to buy securities, you must immediately repay any shortfall. To the extent the Account Agreements allow, we and Alpaca may sell securities in your Account, without notice, to cover the shortfall, and you’re responsible for any remaining amount and the costs of collecting it.

11.10 Withdrawals. Withdrawals, including instant withdrawals, are subject to the timing, limits and fees shown in the app and in the Fee Schedule.

Uninvested cash in your brokerage account may be swept to one or more program banks under Alpaca’s FDIC Sweep Program. Swept cash may be eligible for FDIC insurance up to a total of $1,000,000, limited to $250,000 at each program bank. FDIC insurance covers a program bank’s failure, not market losses, and swept cash isn’t covered by SIPC. The interest rate is variable. Vantar is not a bank. See the Cash Sweep Program terms and the Program Banks list.

13.1 The Fee Schedule lists every fee. In summary, and subject to the Fee Schedule:

“Commission-free” refers only to the commission on eligible trades for U.S. customers. Other fees, spreads and pass-through charges may apply.

13.2 You authorize us, Alpaca and Wyrr, as applicable, to deduct fees from your Account as the Fee Schedule and the Account Agreements describe.

13.3 We’ll notify you of any fee increase before it takes effect, unless the law or an Account Agreement requires something different.

13.4 Taxes. You’re responsible for all taxes on your Account and transactions. You must certify your tax status on Form W-9 (U.S. persons) or Form W-8BEN (others). We and Alpaca may withhold tax as the law requires, including U.S. withholding on dividends paid to customers outside the U.S.

14.1 Alpaca provides trade confirmations and account statements, and we make them available on the Platform. Wyrr provides wallet transaction records.

14.2 Check your records promptly. You must tell us at hello@vantar.co within 14 days after we make a confirmation or statement available if you think it contains an error. Unless you do, the record may be treated as accurate, to the extent the law and the Account Agreements allow.

15.1 Market data, news, ratings and research on the Platform come from third-party providers. They may be delayed, incomplete or inaccurate. Neither we nor our providers guarantee their accuracy, completeness or timeliness, or accept liability for decisions based on them.

15.2 Market data is licensed for your personal, non-commercial use only. You must not copy, redistribute, display publicly, sell or create derivative works from it.

15.3 Professional status. Market data is provided on the basis that you’re a non-professional user. You must tell us if you’re registered or qualified as a securities professional, or if you use market data for business purposes. Different terms and fees may apply.

15.4 Third-party Content reflects the views of its authors, not Vantar’s.

16.1 Pulse and other Vantar AI features use artificial intelligence to summarize market news and information from third-party sources.

16.2 AI-generated Content can be incomplete, out of date, misleading or wrong. It may omit important context. It isn’t personalized and isn’t investment advice or a recommendation. Check the original source, and don’t rely on AI-generated Content alone when making investment decisions.

16.3 You must not use Vantar AI features to create unlawful, misleading or manipulative content. You must not try to extract the underlying models, prompts or data.

Price alerts, watchlist notifications and other alerts are a convenience. They may be delayed, may not be delivered, or may be inaccurate, for example because of network or device issues, market data delays or your device settings. Don’t rely on them to manage your Account.

18.1 Under the Electronic Communications Consent, we, Alpaca and Wyrr may deliver agreements, disclosures, confirmations, statements, tax documents and notices electronically: in the app, on the web or by email.

18.2 We’ll send service messages about your Account, security and changes to our terms. You can’t opt out of these while your Account is open. You can manage marketing messages as described in Communication Preferences.

18.3 A notice we send to the most recent email address or phone number you gave us, or post in the app, counts as delivered when we send or post it.

We may offer promotions, rewards or referral programs. Each is subject to its own terms, which govern if they conflict with these Terms. We may change or end a promotion as its terms allow. We may withhold or reverse a reward if we reasonably believe it was obtained through fraud, abuse or a breach of the promotion terms. Rewards may be taxable.

If you join a Vantar community, such as our WhatsApp groups, you must follow our Community Guidelines. Community posts, including posts by Vantar staff, aren’t investment advice.

22.1 Our rights. The Platform, its software, design, Content and the Vantar name, logos and trademarks belong to Vantar, its affiliates or its licensors, and are protected by intellectual property laws. Except for the licence in section 22.2, we keep all rights.

22.2 Your licence. As long as you comply with these Terms, we give you a limited, personal, non-exclusive, non-transferable, non-sublicensable, revocable licence to:

• access and use the Platform for your own personal, non-commercial use
• install the Vantar mobile apps on devices you own or control

22.3 Open-source components. The apps may include open-source software, which is licensed under its own terms. Those terms are available in the app.

22.4 Copyright complaints. If you believe Content on the Platform infringes your copyright, send a notice under the U.S. Digital Millennium Copyright Act to our designated agent at copyright@vantar.co, Vantar Inc., 8 The Green Suite B, Dover, Delaware. The notice must include the information the Act requires.

23.1 You’re responsible for any data or carrier charges for using the apps. To keep using the Platform, you may need to install updates.

23.2 Apple App Store. If you downloaded a Vantar app from Apple’s App Store:

• these Terms are between you and Vantar only, not Apple, and Vantar alone is responsible for the app and its content
• your licence is limited to use on Apple-branded products you own or control, as the App Store usage rules allow
• Apple has no obligation to provide maintenance or support for the app
• if the app fails to meet any applicable warranty, you may notify Apple and Apple will refund the purchase price, if any; to the extent the law allows, Apple has no other warranty obligation for the app
• Vantar, not Apple, is responsible for addressing any claims about the app, including product liability claims, claims that the app fails to meet legal or regulatory requirements, and claims under consumer protection, privacy or similar laws
• Vantar, not Apple, is responsible for investigating, defending, settling and discharging any claim that the app or your use of it infringes a third party’s intellectual property rights
• you confirm you’re not located in a country subject to a U.S. Government embargo or designated as “terrorist supporting”, and you’re not on any U.S. Government list of prohibited or restricted parties
• Apple and its subsidiaries are third-party beneficiaries of these Terms and, once you accept them, may enforce them against you

23.3 Google Play. If you downloaded a Vantar app from Google Play, Google’s terms of service also apply to your use of Google Play.

If you send us suggestions, ideas or feedback, you give us a perpetual, worldwide, royalty-free right to use them for any purpose without obligation to you.

The Platform relies on, and links to, services provided by third parties, including Alpaca, Wyrr, Plaid, our identity verification provider, app stores, Apple and Google sign-in, WhatsApp and market data providers. Their terms and privacy policies govern your use of their services. We aren’t responsible for third-party websites, services or content that we don’t control, and a link isn’t an endorsement.

Our Privacy Policy explains how we collect, use, share and protect your personal information and the rights you have. U.S. customers also receive our U.S. Consumer Privacy Notice.

27.1 Closing your Account. You can close your Account at any time.

27.2 Our right to act. We may, with or without notice where the law allows, restrict, suspend or close your Account, or your access to any feature, if we reasonably believe:

• you’ve broken these Terms or an Account Agreement
• your Account is involved in fraud, unauthorized access, money laundering, sanctions violations, market abuse or other unlawful activity
• you’re no longer eligible
• you’ve given us false or incomplete information, or haven’t given us information we asked for
• your Account has been inactive for an extended period
• action is needed to protect you, other customers, Vantar or our service providers
• the law, a court, a regulator or a service provider requires it

We may also close your Account for any other reason with at least 30 days’ notice.

27.3 What happens on closure. If your Account is closed:

• you must sell or transfer your investments and withdraw your balances, following the instructions we give you
• if you don’t act within a reasonable time, we and Alpaca may sell your investments and send the proceeds to your linked bank account or by another method the law allows, after deducting amounts you owe
• Wyrr will return wallet balances under the Wallet Terms

27.4 Legal process. If we or our service providers receive a subpoena, levy, garnishment, freeze order or other legal process about your Account, we may comply with it and restrict your Account. Where the law allows, we’ll tell you.

27.5 Death or incapacity. If an Account holder dies or loses capacity, we’ll work with the legal representative once we receive the documents we reasonably ask for. Until then, we may restrict the Account.

27.6 Inactive accounts and unclaimed property. If your Account is inactive and we can’t reach you, state or other law may require us or Alpaca to transfer your assets to the government as unclaimed property.

27.7 Survival. Sections 9, 10.9, 11.9, 13, 15, 16, 21, 22, 24 and 27 to 33 survive the end of these Terms, together with any other provision that by its nature should survive.

28.1 As is. To the extent the law allows, the Platform and all Content are provided “as is” and “as available”, without warranties of any kind, whether express, implied or statutory. These include warranties of merchantability, fitness for a particular purpose, title, non-infringement, accuracy and uninterrupted or error-free operation.

28.2 No guarantee of availability. We don’t guarantee that the Platform will always be available or will work without delay or interruption. Outages, maintenance, market volatility, high volumes, third-party failures and other events may prevent or delay access, order entry, execution or money movement. We recommend you keep contact details for Alpaca in case you can’t reach the Platform.

28.3 Assumption of risk. You understand that investing and using online and mobile services involve risks, including:

• market risk
• technology failures
• cyberattacks
• delays in market data or execution

You accept those risks.

28.4 Securities laws. Nothing in these Terms waives or limits any right you have under federal or state securities laws, or any duty Vantar Inc. owes you as an investment adviser that can’t be waived by law.

29.1 To the extent the law allows, and subject to section 29.4, Vantar, its affiliates and their directors, officers, employees, agents and licensors aren’t liable for:

• any indirect, incidental, special, consequential, exemplary or punitive damages
• loss of profits, revenue, data, goodwill or investment opportunity, or trading losses, arising from your use of, or inability to use, the Platform or any Content

This applies even if we’ve been told such damages are possible.

29.2 To the extent the law allows, and subject to section 29.4, we aren’t liable for any delay or failure caused by events beyond our reasonable control. These include:

• acts of God or natural disasters
• war, terrorism or civil unrest
• government action
• labor disputes
• failures of exchanges, market centers, clearing houses, banks, payment networks, telecommunications or internet providers, or cloud providers
• market volatility or trading halts
• cyberattacks we couldn’t reasonably prevent

29.3 To the extent the law allows, and subject to section 29.4, the total liability of Vantar and its Affiliates to you, taken together, for all claims relating to the Platform or these Terms is limited to the greater of:

• the total fees you paid to Vantar Inc. in the 12 months before the event that first gave rise to the claim; and
• US$100.

This limit applies to all claims in total, whether in contract, tort (including negligence) or otherwise. Bringing more than one claim does not increase it.

29.4 Nothing in these Terms limits or excludes liability for:

• fraud, gross negligence or willful misconduct
• death or personal injury caused by negligence
• any right under securities laws or the Advisers Act described in section 28.4
• any other liability that can’t be limited or excluded by law

To the extent the law allows, you agree to indemnify and hold harmless Vantar, its affiliates and their directors, officers, employees and agents from claims, losses, liabilities, damages, costs and expenses, including reasonable legal fees, arising from:

• your breach of these Terms or an Account Agreement
• your misuse of the Platform
• your violation of any law or the rights of a third party

This doesn’t apply to the extent a loss is caused by our own breach, negligence or misconduct.

32.1 We may update these Terms from time to time. The effective date at the top shows when they last changed.

32.2 We’ll notify you of any material change to these Terms before it takes effect, in the app or by email, unless the law or an Account Agreement requires something different. Changes required by law, or needed to address security, fraud or a new feature, may take effect sooner. In that case, we’ll tell you as soon as reasonably possible.

32.3 Material changes to section 31 won’t apply to Disputes you’ve already notified us about.

32.4 If you keep using the Platform after a change takes effect, you accept the updated Terms. If you don’t agree, you must stop using the Platform and may close your Account.

33.1 Entire agreement. These Terms, the Account Agreements and the documents they refer to form the entire agreement between you and Vantar about the Platform. They replace any prior agreements on the same subject.

33.2 Assignment. You may not assign or transfer your rights or obligations under these Terms without our written consent. We may assign them to an affiliate, or to a successor in a merger, acquisition, reorganization or sale of assets, with notice to you where required.

33.3 Severability. If any provision is held invalid or unenforceable, it’ll be enforced to the maximum extent permitted, and the rest of these Terms remain in effect. Section 31.8 has its own severability rule.

33.4 No waiver. If we don’t enforce a right, we don’t give it up.

33.5 Notices to us. Legal notices to Vantar must be sent to legal@vantar.co and to Vantar Inc., 8 The Green Suite B, Dover, Delaware.

33.6 Electronic signatures. Your electronic acceptance of these Terms and any Account Agreement has the same legal effect as a handwritten signature.

33.7 Language. These Terms are written in English. If we provide a translation, the English version governs to the extent the law allows.

33.8 Headings and interpretation. Headings and summaries are for convenience only. “Including” means “including without limitation”.

33.9 No third-party beneficiaries. Except as stated in section 23.2, and except that our affiliates and Alpaca may rely on sections that protect them, these Terms don’t give rights to anyone other than you and Vantar.

33.10 Export controls. You must comply with U.S. and other applicable export control and sanctions laws when you use the Platform.

33.11 U.S. Government users. The apps are “commercial items” as defined in FAR 2.101 and are provided to U.S. Government users only with the rights set out in these Terms.

33.12 Relationship. Nothing in these Terms creates a partnership, joint venture, agency, fiduciary or employment relationship. The exception is the advisory relationship under an Auto-Invest or other advisory agreement.

Vantar doesn’t offer support by phone. You can contact us through the app or by email at hello@vantar.co.