Terms and conditions

Terms & Conditions
Legal Agreement
1. This document is a legally binding agreement (the “Agreement”) between you and Propelle (Network) Limited. It regulates our provision of certain investment arranging and execution-only services to you and includes important information about those services. We will provide our services to you in respect of Products which we make available via the Propelle Platform. This agreement will apply to you from the date that you open your Propelle Account. We provide this agreement in English and will communicate to you in English going forward.
2. This agreement is governed by English law.
3. You should read this agreement carefully and ask for independent professional advice if anything is unclear or if you have any questions.
Default terms
1. Throughout this agreement, we use certain capitalised terms that have specific meanings as detailed below.
  1. “Additional Services” means the additional services provided other than the Investment Services, as set out more fully in the “Our Services” section below.
  2. “Available Funds” means the total amount of funds that you have available to invest in Products using the Propelle Platform, as displayed in your Propelle Account. These funds represent money held for you in WealthKernel’s client money account.
  3. “Custodian” means WealthKernel (or any other bank or other third party appointed by WealthKernel) from time to time to hold your Available Funds and/or Products that you have invested in through the Propelle Platform.
  4. “FCA” means the United Kingdom’s Financial Conduct Authority.
  5. “Force Majeure” means any delay or interruptions in fulfilling our obligations under these terms and conditions if the circumstances are beyond our reasonable control or the control of WealthKernel, or any third party. This includes problems with your telecommunications services, internet service provider, computer hardware and/or software, or difficulties in sending or receiving emails.
  6. “Investment Services” means the dealing and execution-only services that we will provide to you through the Propelle Platform, as set out more fully in the “Investment Services” section below.
  7. “Loss” means any allegation, claim, cost, expense, damage or other loss of whatever nature, and howsoever arising.
  8. “Minimum Cash Balance” means the minimum cash that must be held as part of your Available Funds for the purpose of paying any fees, costs and/or charges owed to us.
  9. “Orders” means any instruction that we receive from you through the Propelle Platform in which you request us to perform certain services, including an instruction to invest in a Product or to take action in relation to your investment in a Product.
  10. “Products” means any investment product that we make available to you via the Propelle Platform[, which may include, without limitation, investments in five sub-funds under the Vanguard “LifeStrategy” Funds® Investment Company with Variable Capital].
  11. “Propelle“, “we“, “our” or “us” means Propelle (Network) Limited, our details are set out in the “About Us” section below.
  12. “Propelle Account” means a personal record on the Propelle Platform that will: (i) contain a summary of your Orders that you have placed using the Propelle Platform and details regarding the Products you have invested in; and (ii) display the amount of your Available Funds.
  13. “Propelle Platform” means a customer user interface which enables you to submit instructions via our app or website in order to invest in Products and to take action in relation to Products that you have invested in.
  14. “Services” means both the Investment Services and the Additional Services that we will provide to you through the Propelle Platform, as set out more fully in the “Our Services” section below.
  15. “WealthKernel” means WealthKernel Limited (company number 09686970, registered office 41 Luke Street, London, United Kingdom, EC2A 4DP), the service provider nominated by us to provide to you services such as custody, bank account operation, or execution and clearing services.
  16. “WealthKernelAgreement” means an agreement entered into by Propelle with WealthKernel on behalf of themselves and you, whereby WealthKernel has agreed to provide you with the Investment Services.

When we use the term “including” or where we give examples, that does not mean that the specific items we mention are an exhaustive list or that we only mean those specific items.

About Us
1. Propelle (Network) Ltd (“Propelle”) is an Appointed Representative of RiskSave Technologies Ltd (“RiskSave”). RiskSave is authorised and regulated by the Financial Conduct Authority with FRN 775330.The FCA’s registered office is 12 Endeavour Square, London E20 1JN.
2. Propelle is a limited company incorporated in England (registration number 12106229), with registered address at 36 Scotts Road, Bromley, England, BR1 3QD.
3. As Propelle is an Appointed Representative, RiskSave will be responsible for The Investment Services provided by Propelle. Further details about the authorisation of RiskSave and status of Propelle can be found on the Financial Services Register.
4. Propelle has a partnership with SimpleCrowdFunding (SCF) in order to provide marketing materials and access to property investment deals.
Our Services

Investment Services

We will provide the following services:
1. transmitting instructions to WealthKernel to execute your Orders to invest in Products and to take subsequent investment-related actions in relation to the Products that you hold with WealthKernel; and
2. arranging the safeguarding and administration of your investments in the Products by WealthKernel,

(together the “Investment Services”).

We will provide our Investment Services on an execution-only basis. This means that our Investment Services are non-advised and so we will not provide you with any advice of any kind, nor will we provide a view as to whether a particular Product is suitable for you. You are solely responsible for the decisions you make in relation to your Orders in respect of the Funds.
We will treat you as a retail client in accordance with the FCA rules. You may request in writing a different client categorisation however we have the discretion to reject any such request.
As we do not provide execution services directly, we will transmit your Orders to WealthKernel. WealthKernel will be responsible for the execution of your Orders in respect of the Products.
In consideration of Investment Services available to you, you agree that:
1. Propelle is authorised to enter into the WealthKernel Agreement on your behalf as your agent and Introducer (as defined in the WealthKernel Agreement);
2. you are bound by the WealthKernel Agreement and acknowledge that the agreement constitutes a contract between you and WealthKernel. This is a separate agreement which you enter into directly with WealthKernel when opening a Propelle Account via the Propelle Platform.
3. Propelle is party to the WealthKernel Agreement as your agent solely for the purpose of confirming your agreement to be bound by the terms of the WealthKernel Agreement. Propelle has no other obligations as a party to the WealthKernel Agreement, either to you or to WealthKernel. You are solely responsible for the performance of your obligations under the WealthKernel Agreement;
4. We cannot control the execution of your Orders once we transmit them to WealthKernel and there is no guarantee that either we or WealthKernel will accept your order, but we will always try to best execute our customers orders as described in our Order Handling Policy ;
5. Propelle as your Introducer (as defined in the WealthKernel Agreement) is duly authorised to give instructions to WealthKernel on your behalf and to provide information concerning you to WealthKernel and WealthKernel shall be entitled to rely on any such instructions or information without further enquiry; and
6. WealthKernel is authorised to hold cash and investments on your behalf and is authorised to transfer cash or investments from the client money account and/or the custody account that WealthKernel maintains for you under the WealthKernel Agreement to meet your settlement or other obligations to WealthKernel.
Propelle does not hold your money. WealthKernel will arrange for your money to be held in accordance with applicable law and will be responsible for keeping it safe. Please refer to WealthKernel’s terms and conditions in the WealthKernel Agreement for further information.

Additional Services

In addition to the Investment Services, we will provide the following additional services (“Additional Services”):
1. access to a community based, financial technology platform that provides financial education content, community features and introductions to third party companies and individuals;
2. information (but not provide any advice or any form of express or implied opinion, as further explained this agreement) in respect of certain Products;
3. introductions to our property partner, Simple Crowdfunding, who are a property project platform and will allow us to provide access to their deals to our customers.
Further information and terms regarding the Additional Services are set out at section 15 below. In addition, the Additional Services do not involve the provision by us of any financial planning, accounting, investment advisory or tax advisory or planning advice. If you need financial advice please contact an independent financial advisor.
No investment or other advice
1. We do not provide or offer any investment or other advice, including advice on the suitability of any particular investment or investment strategy.
2. We do not offer tax advice. Please consult an independent tax adviser should you require any such advice.
3. You agree that, by using the Propelle Platform, you are responsible for your own investment decisions and investment strategy and that you have sufficient knowledge and experience to make those decisions, taking into account the risks associated with investments generally or those specific to a particular Product. If you are unsure of any investment or investment decision, you should seek the services of appropriately qualified and regulated financial adviser before you proceed with the investment or decision.
4. You confirm that for every Order that you place through the Propelle Platform, we will be entitled to assume that you have considered the risks and merits of the proposed Order and taken independent advice where necessary.
5. We may from time to time publish general or specific information or commentary on the Propelle Platform, in the general press, through communications with you or otherwise. You agree that none of that information or commentary will ever constitute investment advice by us, and you should never treat it as such.
Placing Orders
1. You will be able to place Orders once you have set up a Propelle Account. Orders must be placed via the Propelle Platform. We do not accept Orders via any other method.
2. The Propelle Platform allows you to invest in a specific number of Products, or to set an amount that you want to spend on investing in Products (in which case you may own fractions of Products).
3. It is your responsibility to ensure that your Orders are accurate and complete. We do not verify the accuracy of your Orders and you hereby agree that we may assume, at all times, that your Orders as submitted on the Propelle Platform are correct and reflect your requirements.
4. You will bear all risk of sending Orders to us, even if they are incorrect or do not reflect your requirements. You acknowledge and agree that we may arrange for the execution of your Orders exactly as we have received them.
Confirmation of Orders
1. You will be able to access confirmation of each Order that you have placed through the Propelle Platform, which will include a summary of the Order details. This confirmation will be displayed in your Propelle Account and made available within a reasonable time after the Order has been executed. However, there are many reasons why you may not receive a confirmation (for example, if there is a system or communications issue, or if you are unable to connect). The fact that you may not have received a confirmation of your Order does not mean the Order was not placed. If you don’t receive a confirmation email about your oder, please get in touch at support@propelle.io so that we can investigate the issue for you.
2. We will provide you with a summary of all Orders executed and the associated costs each quarter.
Order Handling Policy
1. All Orders will be executed in accordance with the terms set out WealthKernel’s Best Execution Policy, which can be found here, and in the WealthKernel Agreement. By entering into this Agreement, you confirm that you have read and consent to WealthKernel’s Best Execution Policy.
2. We accept Orders at our sole discretion and reserve the right to refuse to accept your Orders and/or to transmit them to WealthKernel for execution. We will use reasonable endeavours to notify you if we refuse to accept your Orders and/or if we decide not to transmit them to WealthKernel for execution, although there may be circumstances where we are unable or not allowed to do so, for example under certain applicable laws.
3. We will transmit your Orders placed through the Propelle Platform to WealthKernel for execution in accordance with this Agreement.

Your consent and authorisation

By using our Services and agreeing to this Agreement you consent to us arranging for the execution of your orders.
Further to paragraph 4.5 above, you confirm that Propelle as your Introducer (as defined in the WealthKernel Agreement) is duly authorised to give instructions to WealthKernel on your behalf and to provide information concerning you to WealthKernel and WealthKernel shall be entitled to rely on any such instructions or information without further enquiry.

Best execution

Our primary obligation is to ensure that your Orders are transmitted to WealthKernel promptly. Unless instructed otherwise by you or where prevailing market conditions prevent us from doing so, Orders will be transmitted to WealthKernel sequentially and promptly.
Further details on how the Orders will be executed are set out in Propelle’s Best Execution Policy.
By submitting an Order through the Propelle Platform you are deemed to have accepted this Agreement, including the terms on which the Orders are executed (including, where applicable, the WealthKernel Agreement).

Monitoring and review

Propelle undertakes to monitor execution performance, as well as periodically reviewing to ensure that we are delivering the best execution results for our clients. We will let you know about any important changes being made here.
Cancelling Orders
1. You can’t cancel an Order after it has been submitted to WelathKernel. Once you have inputted the details of your Order on the Propelle Platform, you will be shown a summary of those details before you proceed with placing the Order
2. You will also be shown the price of the relevant Product and all associated fees, costs, taxes and other deductibles that you will need to pay in connection with the investment of the Product.
3. It is important to ensure that you enter the details of your Order correctly and that you are willing and able to enter into a binding commitment to invest in a Product when you submit your Order.
Our fees and costs
1. The fees that we charge for the provision of the Investment Services are described in a separate “Fees” guide on our website, details of which can be found at [ex ante doc].
2. WealthKernel will deduct our fees from your Available Funds and settle them with us directly. The amount of our fees, as well as the nature of our fees, may change from time to time and we will provide you with 30 days’ notice of any such changes.
3. Before you proceed with placing an Order through the Propelle Platform, you will be shown a breakdown of any fees that we will charge you in connection with the Order.
Pre-investment disclosure requirements
1. You should ensure that you are aware of additional fees and charges imposed by the providers of the Products that you wish to invest, before investing in those Products. These fees are automatically debited during the execution of an Order. Information regarding this will be made available in the relevant prospectus documents and on the websites of the providers of the Products. While Propelle may facilitate access to this information (for example via links to the relevant documents from the Propelle Platform), please note that we are not responsible for nor do we have any control over the contents of the information contained in those documents.
Risk warnings
1. You acknowledge and understand that we do not carry out any risk assessment before we allow you to use the Propelle Platform or before we will act on your Order. You also acknowledge and understand that we do not perform any suitability checks with respect to any investment in funds you may undertake on the Propelle Platform.
2. Before investing in Products you must ensure that you fully understand the risks involved. There are risks associated with investing generally and also specific risks attached to certain Products (for example, liquidity and insolvency risks). Please read the risk section in the relevant prospectus for each Product (if any) that you seek to invest in before placing an Order through the Propelle Platform.
3. By using the Propelle Platform, you acknowledge and understand that: (i) the Products available to you through the Propelle Platform may not be suitable for everyone, (ii) the value of your investments in the Products may go up and may go down, (iii) investment carries an inherent risk that you may lose some or all of the monies that you have invested; and (iv) your liability to tax is dependent on your personal circumstances and independent advice should be sought if required. Past performance of a Product is not indicative of future performance.
4. Investing in Products may also give rise to currency risk. For example, where your Products are denominated in currencies other than your default currency which you use to invest in the Products, fluctuations in foreign exchange rates may impact your profits and losses connected to your trading in such Products.
5. We take all reasonable steps to identify conflicts of interest (including any potential conflicts of interest) between us and our clients, or between one client and another, that arise through the provision of our Investment Services. For further information, please get in touch with us
Products
1. The Products that are available for investment via the Propelle Platform may change from time to time. We do not guarantee that any specific Products or types of Products that may be available at any given point in time will always remain available or accessible through the Propelle Platform. If we remove a Product from the Propelle Platform, it will mean that you will no longer be able to place Orders for that Product. Provided we are not prevented from doing so (for example, where investment in that Product has been suspended), we will allow you to place Orders in relation to that Product that you have invested in through the Propelle Platform.
Use of Custodians
1. We do not, as part of our Investment Services, hold or offer to hold your Products (including share certificates or similar instruments) on your behalf. We do not hold or control your money.
2. WealthKernel will hold your money (including your Available Funds) and Products. We will require WealthKernel to hold your Available Funds and Products in accordance with all applicable laws, including that all cash should be held in a segregated and designated client money bank account.
Additional Services
1. In respect of the Additional Services provided on the Propelle Platform, and as described in section 4, these Additional Services do not involve the provision by us of any financial planning, accounting, investment advisory or tax advisory or planning advice. If you need financial advice please contact an independent financial advisor.

Introductions to third parties

As part of our Additional Service, we may facilitate introductions to a number of partners, including Simple Crowdfunding. Simple Crowdfunding is a trading name for both Focus 2020 Limited and Simple Property Ltd. Focus 2020 Limited (FRN 727214) is authorised and regulated by the Financial Conduct Authority. Simple Property Ltd (FRN 747022) is an appointed representative of Share In Ltd (FRN 603332), authorised and regulated by the Financial Conduct Authority. Focus 2020 Limited (Number 04016517) and Simple Property Ltd (Number 08317754) are registered companies in England and Wales .Any introductions to third parties do not amount to any arranging or recommendations as to investment, financial planning, accounting, investment advisory or tax advisory or planning advice.

Free Services and Trials

Your right to access and use any free Propelle Platform features is not guaranteed for any period of time and we reserve the right, in our sole discretion, to limit or terminate your use of any free versions of any Platform features by any individual or entity. If you are using the Propelle Platform on a trial or promotional basis (“Trial Period”), your Trial Period and access to the Propelle Platform will terminate (i) at the end of the Trial Period stated in any order that you place with us, (ii) if no date is specified, 30 days after your initial access to the Propelle Platform, or (iii) upon your conversion to a paid subscription, whichever is earliest. During the Trial Period, to the extent permitted by law, we provide the Propelle Platform “As Is” and without warranty or indemnity, and all other terms otherwise apply. We may modify or discontinue any trials or promotions at any time without notice.

Beta Services

We may offer you access to beta services that are being provided prior to general release, but we do not make any guarantees that these services will be made generally available (“Beta Services”). You understand and agree that the Beta Services may contain bugs, errors and other defects, and use of the Beta Services is at your sole risk. You acknowledge that your use of Beta Services is on a voluntary and optional basis, and we have no obligation to provide technical support and we may discontinue the provision of Beta Services for business or operational reasons at any time in our sole discretion and without prior. We will try to give you reasonable notice to youof any suspension or withdrawal of the Beta Services. These Beta Services are offered “As-Is”, and to the extent permitted by applicable law, we disclaim any liability, warranties, indemnities, and conditions, whether express, implied, statutory or otherwise. If you are using Beta Services, you agree to receive related correspondence and updates from us and acknowledge that opting out may result in cancellation of your access to the Beta Services. If you provide feedback (“Feedback”) about the Beta Service, you agree that we own any Feedback that you share with us. For the Beta Services only, these Terms and Conditions supersede any conflicting terms and conditions in the Agreement, but only to the extent necessary to resolve conflict. You grant us a worldwide, non-exclusive, royalty-free, transferable licence to use, reproduce, distribute, prepare derivative works of, display, and perform that Feedback in connection with the Propelle Platform and across different media, including to promote the Propelle Platform forever.

Third-party links, sites and services

Our Platform may contain links to third-party web sites or services that are not owned or controlled by Propelle. These links are provided for your information only. Propelle has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third-party web sites or services. You further acknowledge and agree that Propelle shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such web sites or services.
The content on the Propelle Platform is provided for general information purposes only and although we make reasonable efforts to update the information on the Propelle Platform, we make no representations, warranties or guarantees, whether express or implied, that the content on our Platform is accurate, complete or up-to-date. The content made available through the Propelle Platform is not intended to amount to financial or other professional advice on which you should rely. You must obtain financial or other professional advice if you require it before taking, or refraining from, any action on the basis of the content on the Propelle Platform.

Market data

As part of our Additional Service, the Propelle Platform will display real-time or near real-time market data to you, including the then-current market price for various Products. This data will be displayed on the Propelle Platform exactly as we receive it from third party providers of that data. This type of data is subject to constant change and will be updated frequently. This data may be delayed, and should not be solely relied on for your investment decisions.
The market data displayed is highly confidential and made available to you on the condition that you will not use that data for any purpose other than in connection with investment in the Products via the Propelle Platform. In particular, but without limitation, you hereby agree not to:
1. use any of the data that we provide for commercial purposes;
2. make that data available to any other person (whether for free or otherwise);
3. publish that data anywhere; or
4. provide access to that data to anyone else through your account.
Use of the Propelle Platform
1. Investing through the Propelle Platform is available to individuals only (and not companies, partnerships or other entities), who are over 18 years and who trade for their own account. Investing in funds will only be available to UK tax residents.
2. By using the Propelle Platform, you expressly confirm and warrant to us as follows:
  1. you are doing so in your personal capacity,
  2. you will use our Services only for your own account and not for, or for the benefit of, anyone else,
  3. you are over 18 years of age,
  4. you will immediately stop using the Propelle Platform if you are no longer doing so in your personal capacity, or you wish to use the Propelle Platform for the benefit of someone else.
3. Propelle will perform certain customer due diligence checks on you prior to providing you with the Investment Services and access to the Propelle Platform and, at our discretion, on subsequent occasions. You will not be able to Place an Order using the Propelle Platform unless Propelle has been able to verify your identity and source of funds. You acknowledge and agree that you will provide us with all necessary information which we may reasonably request from you for the purpose of verifying your identity. WealthKernel may also request additional information in order to conduct its own customer due diligence checks.
Warranty, Indemnification and Limitation on Liability
1. The Propelle Platform is provided “as is”, and we can’t guarantee it will be safe or secure or will work perfectly all the time.
2. To the extent permitted by applicable law, we disclaim all warranties, whether express or implied. Without limiting the generality of the forgoing, although we make reasonable efforts to update the information on the Propelle Platform, we do not make any representation or warranty of any kind relating to the accuracy, service availability, completeness, informational content, error-free operation, results to be obtained from use, or non-infringement of the Propelle Platform. Access and use of the Propelle Platform may be unavailable during periods of peak demand, system upgrades, malfunctions or scheduled or unscheduled maintenance or for other reasons.
3. We only provide our service for domestic and private use. You agree not to use our Services for any commercial or business purposes and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
4. We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
5. We cannot guarantee that the Propelle Platform or its content is free from any virus, distributed denial-of-service attack, or other technologically harmful material. [We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to use of our Platform or to your downloading of any content on it, or on any website linked to it.
6. You are responsible for all losses, legal claims and demands that may arise in connection with your use or misuse of the Propelle Platform in breach of this Agreement including those suffered by Propelle and its affiliates unless it is caused by Propelle or its affiliates. We reserve the right to select our own legal counsel.
Propelle is not liable for any damages that may occur to you as a result of your misuse of the Propelle Platform.
Confidentiality and data protection
1. Propelle will take all reasonable steps to ensure that your personal information is handled securely and in line with our privacy policy, a copy of which can be found here. We will record and store all communications with you. Any personal information that we collect will be processed in accordance with our privacy policy. We may collect personal information for the purposes of conducting customer due diligence checks and may send any data (including personal information) that you submit via the Propelle Platform to WealthKernel in order to provide our Investment Services to you which include arranging for the execution of your Orders and for the safeguarding of your investments in the Products and money. WealthKernel’s privacy policy can be found here.
2. By continuing to use our website and web application, you agree to our use of cookies. For more information about cookies and how to manage your preferences, please refer to our Cookie Policy here.
Changes to our Services
1. Our Services and access to them through the Propelle Platform may change from time to time. These changes could include, by way of example: (i) adding and/or removing certain features or functionality to the Propelle Platform; (ii) changing the design of the Propelle Platform; (iii) changing the way in which we deliver our Services through the Propelle Platform; (iv) changing the systems that we use to deliver the Propelle Platform; and (v) changing the third parties we use or rely on to be able to deliver the Services through the Propelle Platform. This is not an exhaustive list of the types of changes that we may make.
2. We will provide you with 30 calendar days’ notice of any material changes to our Services and/or the Propelle Platform. You will not necessarily be notified of any immaterial changes before we make them, or before they take effect, so you should always make sure that the Propelle Platform remains suitable to your specific needs and circumstances, and to stop using the Propelle Platform if that is no longer the case.
3. If we do make changes and, as a result, we are no longer able to offer our Services and/or the Propelle Platform to you, we will notify you of this (by email, through the Propelle Platform or through other means) at least 30 days before the change takes effect.
4. Your right to use the Propelle Platform will cease immediately and automatically from the moment that our Services are changed in such a way that we can no longer provide them to you. In such an event, we may freeze your access to the Propelle Platform (which means that you will no longer be able to issue Orders to us) and/or your Propelle Account (please refer to the section on Consequences of Termination for further details).
Availability of Services
1. While we aim to have the Propelle Platform available without interruption, we cannot guarantee that it will always be accessible and available.
2. We may, from time to time, suspend the Propelle Platform to perform routine or emergency maintenance or to upgrade or replace our systems. Where this is the case, we will use reasonable endeavours to notify you of any planned downtime, however we may not always be able to provide you with advance notice.
3. If the Propelle Platform is unavailable for whatever reason, this may affect your ability to place an Order, cancel Orders before they are executed and/or otherwise send us instructions.
Technical requirements
1. We do not guarantee that our site will be secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software.
Account security
1. You are responsible for ensuring that your login and password details for accessing the Propelle Platform and Propelle Account cannot be accessed by third parties. We are entitled to assume that any instruction received by us through the Propelle Platform is a valid instruction, issued by you – even if the instruction was issued by someone who gained unauthorised access to your Propelle Account.
2. You must keep your login details and passwords that you use to access the Propelle Platform and Propelle Account, safe and secure and not allow any other person to know or obtain those details. If you have lost your login or password details, or you suspect your login or password details have been compromised, you should immediately inform us and change your details via the Propelle Platform.
3. We recommend that you use appropriate, up-to-date security software and definitions to reduce the risk that your system will be susceptible to unauthorised access and intrusion.
4. You must install the latest version of any mobile applications that we publish from time to time. These updates often include improved security or fixes for recently discovered vulnerabilities.
5. We will take reasonable steps consistent with our legal duties to protect your Propelle Account and secure it, however we are not liable for security breaches that may occur where we have complied with those obligations.
Suspension of access
1. We (and/or WealthKernel) may suspend your access to the Propelle Platform, Propelle Account and/or the execution of any Orders before they have been executed, at any time and without notice to you, in exceptional circumstances, including: (i) if we have good reason to believe that you have not complied with this agreement; (ii) if we are required or requested to do so by any regulator, law or other authority; (iii) if we have good reason to believe that your use of the Propelle Platform is harmful to us or our software, systems or hardware; (iv) if we have good reason to believe that your Propelle Account has been compromised; (v) if we have good reason to we believe the Order did not originate from you or, if implemented, would contravene any applicable law, regulation or guidance; or (vi) if we have good reason to believe that our continued association with you would bring us into disrepute or cause us to breach any applicable law, rule or regulation.
2. We (and/or WealthKernel) may also decide to close or suspend your access to the Propelle Platform and Propelle Account for other reasons. We would contact you through the Propelle Platform at least 30 days before doing so.
Your general obligations
1. You agree that you will use the Propelle Platform in accordance with all applicable laws and regulations at all times. You will, in particular, but without limitation, not:
  1. engage in any practice that is considered to be market abuse;
  2. use the Propelle Platform or issue any instructions in connection with any attempt to launder money or avoid applicable sanctions against any person, company or country;
  3. provide any false or otherwise misleading information in relation to your identity or personal circumstances that we request in order to provide you with access to the Propelle Platform;
  4. use the Propelle Platform in an unlawful manner or for an unlawful purpose, in a manner inconsistent with these terms or act fraudulently or maliciously, for example, by hacking into or inserting malicious code, such as viruses, or harmful data into the Propelle Platform or any operating system;
  5. use the Propelle Platform in a way that could damage, disable, overburden, impair or compromise our systems or Productor interfere with other users;
  6. attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site.
Termination
1. Propelle and you are each able to terminate this Agreement by giving 30 business days’ written notice of such termination. Such notice may be provided by email. Notice of termination will not affect any open Orders that have yet to be executed – we will continue to arrange for the execution of those Orders in accordance with the terms of this Agreement.
2. Additionally, we may terminate or suspend this Agreement in exceptional circumstances. Exceptional circumstances include the following:
  1. if we have good reason to suspect that you are behaving fraudulently or otherwise criminally;
  2. if you have not given us any information that we or WealthKernel needs, or we have good reason to believe that information you have provided is incorrect or not true;
  3. if you have broken these terms in a serious or persistent way and you have not put the matter right within a reasonable time when asked you to;
  4. if we have good reason to believe that continuing to provide the Services to you could damage our reputation or goodwill;
  5. if you’ve been declared bankrupt; or
  6. if we have to do so under any law, regulation, court order or supervisory authority instruction.
3. We may also decide to terminate or suspend your Account for other reasons. We will contact you at least 30 business days before we does this.
4. In addition, WealthKernel may choose to terminate the WealthKernel Agreement in accordance with the terms of it (see clause 22 of the WealthKernel Agreement).
5. This Agreement will survive termination of the WealthKernel Agreement. However, if this Agreement is terminated, for whatever reason, then the WealthKernel Agreement will also be terminated.
6. Once your access to the Propelle Platform has been terminated, we will not accept any further Orders from you.
7. We may retain a copy of all records related to your Propelle Account and Orders you have sent to us, in accordance with our data retention policies and otherwise as required by any applicable law or regulation.
Getting in touch with us
1. If you need to get in touch with us about anything, you can email us at support@Propelle.io We do not currently offer a dedicated phone helpline.
2. We will do our best to respond to any emails as soon as we are able to, and aim to reply to all emails within five business days. However, there may be times when it takes us longer to reply to email, and sometimes emails get delayed or lost through no fault of ours, so if your query is urgent please use our chat function instead (or in addition to an email).
3. You can make a complaint by email at support@Propelle.io. We will acknowledge your complaint within 24 hours and investigate your complaint and endeavour to respond to you within three business days. Where we are unable to respond within this timeframe, we will notify you of the longer procedure within three business days and will aim to complete our investigation within eight weeks. We will then provide you with a written response. You can find additional information in our complaints policy.
4. You may be entitled to compensation from the Financial Services Compensation (“FSCS”) Scheme. As we are an appointed representative, we are not a member of the FSCS. Our principal, RiskSave is a member and further details regarding the FSCS can be found here.
Changes to this Agreement
1. We may, from time to time, update or make other changes to the terms and conditions of this agreement. We will provide you with 30 days’ notice of any material changes, which may include notifying you by email or through the Propelle Platform. If you do not agree with those changes, you should stop using the Propelle Platform and terminate this agreement. We will assume you agree with changes to this agreement if you continue to use the Propelle Platform after those changes have taken effect.
Liability
1. We do not guarantee the performance or profitability of any Products that you invest in through the Propelle Platform.
2. We will not be liable to you for any Loss which you may suffer that:
  1. relates to the investment in any Products which were Ordered and subsequently executed using the Propelle Platform, including for any market movements in price between the time that an Order was placed and the time it was executed;
  2. are business losses rather than personal losses;
  3. arise from any act or omission caused by circumstances beyond our control, including unavailability of the Propelle Platform caused by disruption to or failure of market infrastructure, communications networks or technology systems;
  4. arises from any Force Majeure;
  5. are caused by a third party, for example, WealthKernel;
  6. are caused by your own failure to comply with your obligations under this agreement; or
  7. are caused by any of our acts or omissions necessary under applicable law or regulation.
3. Nothing in this agreement limits or excludes our liability for: (i) death or personal injury caused by our negligence; (ii) our own fraud; or (iii) Loss that we cannot limit or exclude under applicable law and regulation.
4. You agree that we will under no circumstances be liable for any: (i) consequential, indirect, incidental or special Loss; or (ii) economic loss, loss of profit, loss of business, loss of revenue or trading losses of whatever nature, in each case that result from or relate to your use of the Propelle Platform, even if you have advised us of the possibility of such Loss.
Whole Agreement
1. This Agreement constitutes the entire agreement between you and us, to the exclusion of any warranties, conditions or terms implied by applicable law.