Moneybox

Terms & Conditions

Index

Summary of Key Terms & Conditions

Section 1: General Terms

Section 2: Platform Terms:

Part A: General Platform Terms

Part B: Additional ISA Terms

Part C: Additional JISA Terms

Part D: Additional LISA Terms

Section 3: Conflicts of Interest Policy

Section 4: Order Transmission Policy

Section 5: Client Investments and Risks

Section 6: Glossary

Appendix 1: Fees & Charges

Section 1 - General Terms

Important information
1. In these Terms, references to “Moneybox”, “us”, “our” and/or “we” means Digital Moneybox Limited. References to “client”, “you” and/or “your” means any person who opens a Moneybox Account with us References to “Platform Provider” means Greyfriars Asset Management LLP.
2. In these Terms, reference to a “Moneybox Account” means the account that we will open for you which will enable you to set aside money to invest through the mobile application (the “APP”) which allows us to provide the Moneybox Services (as defined in Section 6).
3. These Terms contain important information regarding the services that we and the Platform Provider provide to you so, for your own benefit and protection, please read these Terms carefully before accepting them. If there is anything contained in these Terms that you do not understand, please do not hesitate to get in touch with us. You can email us at: support@moneyboxapp.com or call our helpline on 0330 808 1866.
4. A glossary of defined terms used in these Terms is set out in Section 6.
Your agreement with us
1. These Terms, together with (a) the information we have provided to you via the APP about our services and our fees; and (b) the information you have provided to us via the APP and/or any other permitted means under these Terms in relation to your Moneybox Account constitutes the agreement (“the Moneybox Agreement”) between you and us in the provision of our services to you. We are authorised and regulated by the Financial Conduct Authority (“FCA”), whose address is 25 The North Colonnade, Canary Wharf, London E14 5HS. Our FCA registration number is 712935. Our registered address is at Suite 1.07, 1-2 Hatfields, London SE1 9PG (Companies House Company Registration no. 09597755).
Your agreement with the Platform Provider
1. We have selected Greyfriars Asset Management LLP (or any replacement firm we appoint in accordance with Section 10) (the “Platform Provider”) to provide the “Platform Products”, being the “General Investment Account” (or “GIA”) and the “Individual Savings Account” (or “ISA”) that are made available to our clients through their Moneybox Account.
2. These Terms (as they apply to the Platform Provider) and, in particular, Section 2, Part A (the “Platform General Terms” and, if applicable, Section 2, Part B (the “Additional ISA Terms”),Section 2, Part C (the “Additional JISA Terms”) and Section 2, Part D (the “Additional LISA Terms”)together with (a) the information we have provided to you via the APP about the Platform Provider’s services and costs and charges; and (b) the information you have provided to us via the APP and/or any other permitted means under these Terms in respect of the Platform Products (including declarations given by you which we transmit to the Platform Provider); and (c) any applicable Key Features constitute the agreement (the “Platform Provider Agreement”) between you and the Platform Provider. Greyfriars Asset Management LLP, is authorised and regulated by the FCA under registration number is 229285. Its registered address is at The Cedars, 11 High Street, Fleckney, Leicester, LE8 8AJ (Companies House LLP Registration No. OC304665).
Commencement and status of the Moneybox Agreement
1. The Moneybox Agreement will be legally binding when you accept these Terms. However, we will only start to provide our services to you after we have notified you that your Moneybox Account with us has been opened and, accordingly, those terms relating to your Moneybox Account will only be applicable after that time. The Moneybox Agreement has no minimum duration period.
2. The Moneybox Agreement is governed by the laws of England and Wales. If any provision of the Moneybox Agreement is or becomes invalid or unenforceable, the relevant provision will be treated as if it were not in the Moneybox Agreement, and the remaining provisions will still be valid and enforceable.
Commencement and status of the Platform Provider Agreement
1. The Platform Provider Agreement will be legally binding when you accept these Terms. However, the Platform Provider will only start to provide the Platform Services to you if and when you open a Platform Product and, accordingly, those terms relating to the Platform Product will only be applicable after that time. The Platform Provider Agreement has no minimum duration period.
2. The Platform Provider Agreement is governed by the laws of England and Wales. If any provision of the Platform Provider Agreement is or becomes invalid or unenforceable, the relevant provision will be treated as if it were not in the Platform Provider Agreement, and the remaining provisions will still be valid and enforceable.
Your right to cancel your Moneybox Account and Platform Products
1. You have a period of 30 calendar days within which to cancel your Moneybox Account and the applicable Platform Product(s) selected by you, beginning on the date on which we notify you that your Moneybox Account and the relevant Platform Product(s) is opened. If you decide to cancel, you must notify us within the cancellation period.
2. On notifying us that you wish to cancel, you agree that we may instruct the Platform Provider on your behalf to sell any investments that may have been made during the cancellation period and neither we nor the Platform Provider will be responsible for any losses that you may incur as a result.
Complaints
1. Should you have any complaints in relation to the services provided by either us or the Platform Provider then please notify us by email at: support@moneyboxapp.com or by calling our helpline on 0330 808 1866. We will acknowledge your complaint promptly, and arrange for the matter to be investigated in accordance with the rules of the FCA (the “FCA Rules”) and report the results to you.
2. If your complaint is unresolved or not settled to your satisfaction within 8 weeks from the date you first made the complaint, you may refer it directly to the Financial Ombudsman Service (“FOS”). The address of the FOS is Exchange Tower, London E14 9SR. You can also telephone the FOS at: 0800 023 4 567, or email the FOS at: complaint.info@financial-ombudsman.org.uk. You can find out further information about the FOS on its website: www.financial-ombudsman.org.uk.
Compensation
1. Both Moneybox and the Platform Provider are covered by the Financial Services Compensation Scheme (“FSCS”). You may be entitled to compensation from the FSCS in the event that we or the Platform Provider have ceased trading or have been declared to be in default and unable to meet our respective obligations. This depends upon the type of business and the circumstances of the claim. The FSCS offers different levels of cover for different types of business. Most types of investment business are covered currently for 100 per cent of the first £50,000 of financial loss per person. Further information about compensation arrangements is available from the FSCS (www.fscs.org.uk).
2. In the event that an investment is unable to meet its objectives or underperforms, this will not in itself entitle investors to compensation from the FSCS, as investment performance is not guaranteed.
Client Categorisation
1. Services provided to you under both the Moneybox Agreement and the Platform Provider Agreement will be on the basis that both Moneybox and the Platform Provider will treat you as a Retail Client under the FCA Rules. This means that you are entitled to certain protections that are required to be provided to Retail Clients under the FCA Rules and under applicable laws.
The Moneybox Account and the Moneybox Services
1. We will provide services (the “Moneybox Services”) to you in connection with the set up and operation of your Moneybox Account including the following:
  1. the provision of the APP or, in the unlikely event that the APP is not available, such alternative means as we may specify from time to time to allow you to:
    1. open your Moneybox Account, open Platform Products and manage your selected investments;
    2. receive your instructions to transact in investments in accordance with the investment selections you have made through your Moneybox Account;
    3. transmit your instructions to transact in investments in accordance with the investment selections you have made to the Platform Provider for it to execute;
  2. the provision of information about your Moneybox Account, Platform Product(s) and investments held (including the value of your portfolio) based on information provided to us by the Platform Provider;
  3. the provision of the Round up Services (as described in more detail below) and other features and services as we may specify from time to time that help you to make decisions and place instructions with or through the APP in relation to your savings; and
  4. make arrangements for you to be provided with dealing, safe-custody, settlement and post-execution transaction services from the Platform Provider.
2. We will provide the Moneybox Services to you in accordance with the Terms of the Moneybox Agreement, all applicable laws and the FCA Rules.
3. We will do our best to ensure the APP and your Moneybox Account is available and up and running for you to use at any time however, this is not something we can guarantee. There may be times where the APP and your Moneybox Account may not be available and where we may not be able to facilitate your investment instructions. There may be interruptions and/or delays to our services. If this happens we will do our best to contact you to let you know what you should do. You can also contact us by email at: support@moneyboxapp.com or by calling our helpline on 0330 808 1866.
4. We may suspend the operation of our services where we consider it necessary, including (but not limited to) where we have to suspend operations for technical problems, emergencies, maintenance, regulatory reasons, where we decide it is sensible for your protection, in periods of exceptional trading activity or to ensure the continued availability of other services. If this happens we will do our best to contact you to let you know what you should do.
Selecting investments
1. Through your Moneybox Account you are able to self-select and invest in a number of collective investment schemes, commonly known as “investment funds” (the “Funds”) that we have arranged for the Platform Provider to make available to our clients. Please see the FAQs for more information about the Funds and how we have selected them. Please note, however, that we do not provide financial advice to our clients and we will never make recommendations based on your personal circumstances. If you are not sure whether the Moneybox Account, the Moneybox Services, the Platform Products or the Funds are suitable for you then we recommend that you seek advice from a qualified financial adviser.
2. Prior to making any decision to invest you must read the “Key Investor Information Document” or “KIID” relating to the relevant Fund. The KIID contains important information of which you should be aware. You can access the KIID via the APP.
3. Neither we nor the Platform Provider will provide nor be responsible for providing you with any financial, legal or tax advice. Please note that certain provisions contained in the Moneybox Agreement, the Platform Provider Agreement, and the APP set out information relating to tax treatment. You should note that tax treatment depends on individual circumstances and our current understanding of law and HMRC practice, which may be subject to change in the future.
Your use of our APP
1. In addition to the Terms set out here, you acknowledge and confirm your continuing agreement to our Privacy Notice and the Website & App Terms relating to the use of our APP (together, the “Data Terms”). If there are any terms contained in the Data Terms that are inconsistent with or conflict with the terms, conditions and provisions set out in these Terms then, the relevant term, condition or provision set out in these Terms shall prevail.
2. Moneybox will provide you with security details to access your Moneybox Account. You must keep these details safe and confidential and notify Moneybox immediately if you think that someone else may know these details and/or may have unauthorised access to your Account (otherwise in accordance with these terms).
3. You must not undertake any action that could compromise the security or effective working of the Moneybox Services. Any such action will be considered a material breach of these Terms.
4. You are responsible for monitoring your Moneybox Account, ensuring that you read all messages that have been sent to you (whether through the in-APP secure notification centre, via the email address you have provided to us, or via any other means as agreed between us) and informing us if there is something wrong on your Moneybox Account or you suspect that it has been subject to unauthorised use.
5. You may download or print information and documents that we provide to you strictly for personal use provided that you keep intact all copyright and proprietary notices but you must not otherwise reproduce or distribute any material without our consent.
6. You acknowledge and agree that all intellectual property rights in the APP, all documents and related technology anywhere in the world belong to us or our licensors - you have no rights in or to the APP, the documents and related technology other than the right to use each of them in accordance with these Terms and the Data Terms.
Fees for the Moneybox Services
1. You shall pay to us those fees that are set out in the “Fees Document” attached at Appendix 1 in respect of our provision of the Moneybox Services. You will also pay any applicable VAT.
2. The Platform Provider shall facilitate the payment to us of the fees (plus VAT, if any) payable by you. Please see paragraph 4 of Section 2 below which explains in more detail how certain of your investments may be sold by the Platform Provider and the proceeds used to satisfy your obligation to pay our fees.
Selecting and appointing the Platform Provider on your behalf
1. We have entered into an agreement with the Platform Provider for each of our clients (including you) for the provision of the Platform Products and dealing, safe custody, settlement and post-execution services. The additional terms that apply to the services provided to you by the Platform Provider and the Platform Products are set out in Section 2, Part A (the “Platform General Terms”) of these Terms. Where you choose to invest in an ISA, the provisions in Section 2, Part B (the “Additional ISA Terms”) and where you choose to open a JISA, the provisions in Section 2, Part C (the “Additional JISA Terms”) and where you choose to open a LISA, the provisions in Section 2, Part D (the “Additional LISA Terms”) also apply. You agree that:
  1. we are authorised to appoint the Platform Provider and to agree and enter into the Platform Provider Agreement on your behalf as your agent (in accordance with your instructions);
  2. the Platform Provider Agreement forms a legally binding agreement between you and the Platform Provider. Accordingly, the Platform Provider (and not Moneybox) will be responsible for providing you the Platform Products and with safe custody, settlement and post-execution services;
  3. we are authorised to give instructions to the Platform Provider (as provided in these Terms, including the Platform Terms) and provide information concerning you to the Platform Provider, and the Platform Provider is entitled to rely on such instructions and information without contacting you directly;
  4. the Platform Provider is authorised to hold cash and investments on your behalf and is authorised to transfer cash and/or investments from your Platform Product to meet your settlement and other obligations under these Terms; and
  5. we are authorised as your agent to terminate the appointment of the Platform Provider and to instruct the Platform Provider to transfer the Platform Products and the assets and cash in relation to your Platform Products to an alternative provider selected and appointed by us, provided in doing so we act in your best interests and in accordance with the FCA Rules and all applicable laws.
2. This arrangement with the Platform Provider means that you will remain a client of ours, and we will continue to be responsible to you for the Moneybox Services. However, you will also be a client of the Platform Provider, and it will be directly responsible to you for the provision of the Platform Products and the related dealing, safe-custody, settlement and post-execution services. We shall not be responsible to you for the actions or failures of the Platform Provider and the Platform Provider shall not be responsible to you for our actions or failures.
3. We will notify you of the identity and terms of any replacement platform provider in good time before any changes are made.
The Round up Services
1. You may select to receive our round up services or any similar service which we may offer from time to time through the APP (our “Round up Services”) to help you make contributions to your Moneybox Account based on your spending. These Round up Services involve the provision of information to you about transactions undertaken on your selected bank account(s) and/or debit/credit card account(s) you hold with third party issuers (“Connected Accounts”). In order for us to provide the Round up Services, you will need to give to us, Yodlee Inc. and/or any other service provider we may appoint from time to time in connection with the Round up Services (the “Round up Service Provider”) certain authorities and other information in relation to those Connected Accounts which could include passwords and other security information (“Account Credentials”). This enables us and/or the Round up Service Provider to access your Connected Accounts on a “view only” basis in order to collect information and data about the transactions on your account (“Account Information”). We and/or the Round up Service Provider will collate the Account Information and make it available to you securely via the APP in order to help you make savings and investment decisions and place instructions with us.
2. You should check with the provider(s) of your Connected Accounts about the impact your use of the Round up Services may have on the provision of its services to you. In particular, you should check whether your use of the Round up Services (and, in particular, the disclosure to us and/or the Round up Service Provider of your Account Credentials) could result in you breaching the terms and conditions of your Connected Accounts or otherwise adversely affect or invalidate any claim you may otherwise have against the provider of your Connected Accounts in the event you suffer fraud or similar losses in respect of your Connected Accounts. Subject at all times to paragraph 11.11 below and paragraph 19 (liability), neither we nor our Round up Service Provider accept any liability for any losses you may suffer or incur as a result of your use of the Round up Services and any adverse impact on any claims you may otherwise have against the issuer of your Connected Accounts.
3. By selecting to receive our Round up Services you:
  1. authorise us and the Round up Service Provider to utilise your Account Credentials to obtain all necessary Account Information that may be required by us and the Round up Service Provider in order to provide the Round up Services;
  2. warrant and represent to both us and the Service Provider that the issuer of your Connected Account recognises, and is able to respond to, any and all duly provided account information requests which it may receive from either us or the Service Provider from time to time;
  3. acknowledge and agree that neither we nor the Round up Service Provider shall be liable to you in the event that the provider of your Connected Account delays in providing, or refuses to provide, either us or the Round up Service Provider with access to the Account Information;
  4. agree to provide true, accurate, current and complete information about yourself and your Connected Accounts maintained at other websites and you agree not to misrepresent your identity or your account information;
  5. agree to keep the Account Credentials provided to us and the Round up Service Provider in relation to the Connected Accounts up to date;
  6. agree that you shall not use content delivered to you through the Round up Services for any other purpose other than to use the services provided for under these Terms;
  7. agree not to copy, reproduce, distribute, or create derivative works from the content delivered to you through the Round up Services;
  8. agree that you shall not reverse engineer or reverse compile any of the services technology relating to Round up Services, including but not limited to, any Java applets associated with such services.
4. By selecting to use the Round up Services you are entering into a legally binding agreement under the terms of which you licence us and the Services Provider to use any information, data, passwords, materials or other content (collectively, “Content”) we obtain or collate through your use of the Round up Services in accordance with this Section 11. We and the Round up Service Provider may use, modify, display, distribute and create new material using such Content to provide the Services. We and the Round up Service Provider may also use, sell, license, reproduce, distribute and disclose to any Moneybox affiliate or third party, aggregated non-personally identifiable information that is derived through your use of the Round up Services. By submitting Content, you automatically agree, or promise that you and/or the owner of such Content has expressly agreed that, without any particular time limit, and without the payment of any fees, we and the Round up Service Provider may use the Content for the purposes set out above.
5. By selecting to use our Round up Services you hereby authorise us and the Round up Service Provider on a continuing basis to access third party sites designated by you, on your behalf, to retrieve information requested by you (or on your behalf), and to register for accounts requested by you. For all purposes hereof, you hereby grant to us a limited power of attorney, and you hereby appoint us and the Round up Service Provider as your attorney and agent, with full power of substitution and re-substitution, for you and in your name, place and stead, in any and all capacities, to access third party internet sites, servers or documents, retrieve information, and use your Account Credentials, all as described above, with the full power and authority to do and perform each and every act and thing requisite and necessary to be done in connection with such activities, as fully to all intents and purposes as you might or could do in person.
6. You acknowledge and agree that each time we or our Round up Service Providers use your Account Credentials to access and obtain Account Information from third party sites, we and our Round up Service Providers are acting as your agent and not the agent or on behalf of the third party. You agree that third party account providers shall be entitled to rely on the foregoing authorisation, agency and power of attorney granted by you. You understand and agree that the service is not endorsed or sponsored by any third party account providers accessible through the service.
7. Subject at all times to paragraph 11.11 below and paragraph 19 (liability), you expressly understand and agree that your use of the Round up Services and all information, products and other content (including that of third parties) included in or accessible from the Round up Services is at your sole risk. The Round up Services are provided on an “as is” and “as available” basis. Moneybox and the Round up Service Provider expressly disclaim all warranties of any kind as to the Round up Services and all information, products and other content (including that of third parties) included in or accessible from the Round up Services, whether express or implied, including, but not limited to the implied warranties of merchantability, fitness for a particular purpose and non-infringement.
8. Subject at all times to paragraph 11.11 below and paragraph 19 (liability), Moneybox and the Round up Service Provider make no warranty that (i) the Round up Services will meet your requirements, (ii) the Round up Services will be uninterrupted, timely, secure, or error-free, (iii) the results that may be obtained from the use of the Round up Services will be accurate or reliable, (iv) the quality of any products, services, information, or other material purchased or obtained by you through the Round up Services will meet your expectations, or (v) any errors in the technology will be corrected. Any material downloaded or otherwise obtained through the use of the Round up Services is done at your own discretion and risk and you are solely responsible for any damage to your computer system or loss of data that results from the download of any such material. No advice or information, whether oral or written, obtained by you from either Moneybox or the Round up Service Provider through or from the Round up Services will create any warranty not expressly stated in these terms.
9. Subject at all times to paragraph 11.11 below and paragraph 19 (liability), you agree that neither Moneybox nor the Round up Service Provider nor any of their affiliates, account providers or any of their affiliates will be liable for any losses whether direct, indirect, incidental, special, consequential or exemplary damages, including, but not limited to, damages for loss of profits, goodwill, use, data or other intangible losses, even if Moneybox or Round up Service Provider has been advised of the possibility of such damages, resulting from: (i) the use or the inability to use the service; (ii) the cost of getting substitute goods and services, (iii) any products, data, information or services purchased or obtained or messages received or transactions entered into, through or from the service; (iv) unauthorized access to or alteration of your transmissions or data; (v) statements or conduct of anyone on the service; (vi) the use, inability to use, unauthorized use, performance or non-performance of any third party account provider site, even if the provider has been advised previously of the possibility of such damages; or (vii) any other matter relating to the service.
10. Subject at all times to paragraph 11.11 below and paragraph 19 (liability),You agree to indemnify and keep indemnified Moneybox and the Round up Service Provider and their respective affiliates from any and all third party claims, liability, damages, expenses and costs (including, but not limited to, reasonable legal fees) caused by or arising from your use of the Round up Services, your breach of these Terms (insofar as they relate to the Round up Services) or your infringement, or infringement by any other user of your Moneybox Account, of any intellectual property or other right of anyone. You agree in accordance with paragraph 26 (Third Party Rights) that the Round up Service Provider is a third party beneficiary of the above provisions, with all rights to enforce such provisions as if the Round up Service Provider were a party to this Agreement.
11. The provisions contained in this paragraph 11 shall only apply to the extent such provisions may be applied without Moneybox being in breach of any applicable laws or being in breach of any rules, principles or directions of any applicable regulator including, without limitation, the FCA. All statutory rights that are or may be available to clients as against either Moneybox or the Round up Service Provider in respect of the provision of the Round up Services are preserved and shall remain unaffected.
Opening your Moneybox Account and making Contributions
1. Before we can open your Moneybox Account and provide the Moneybox Services to you, we are required to verify your identity in accordance with UK anti-money laundering legislation. We will use various third-party services to do this and you expressly authorise us to do this acknowledging that this will involve us transmitting your personal information to such third parties and carrying out credit checks that may affect your credit score.
2. Except where the Platform Product is a JISA, you warrant and represent to us and to the Platform Provider on an ongoing basis that:
  1. You are aged 18 or over;
  2. You are UK resident for tax purposes; and
  3. You are not a U.S Person.
  You agree to notify us immediately if any of the above warranties cease to be correct.
3. Contributions to your Platform Product may be single or regular and can only be paid in Sterling. These contributions may be made only by Direct Debit instruction provided to Moneybox via the Moneybox Account, or as otherwise prescribed in the specific terms relevant for each Platform Product. Contributions may be subject to certain minimums. We may change the minimum contributions from time to time and will notify you.
4. If you opened your Moneybox account on or after the Transfer Date, contributions will be debited from your bank account via Direct Debit, using an authorised payment institution (API) who provides Moneybox with payment services. Moneybox shall inform you (via the Moneybox in-APP secure notification centre) of the details of the Direct Debit on the day that we have advised the API to request payment from your bank. Contributions will be held in accordance with the Payment Services Regulations 2009, in a segregated account with a financial institution in the name of the API until cleared. Once cleared, contributions will be transferred to the Platform Provider’s Client Money Bank Account and held in accordance with Section 2 (Platform Terms), Part A (general platform terms), clause 4 (Cash and Investments) below.
5. If you opened your Moneybox account prior to the Transfer Date, and until the Transfer Date, your contributions will be collected in accordance with Section 2 (Platform Terms), Part A (General platform terms), paragraph 3 (Contributions and “Transfers In” to your Platform Product(s)).
Communications
1. We may communicate with you at any time using the information you have given us, including, when appropriate, by telephone, SMS text message, by email and via the APP.
2. It is your responsibility to ensure the contact information we have for you is up to date. In particular, you must ensure we have a current and valid email address for you so that we can notify you when important documents are delivered to you via the APP. You accept that where either we or the Platform Provider are required to provide you with written notice then this will be given to you by means of electronic correspondence.
3. We cannot guarantee that electronic communications will be successfully delivered, or that they will be secure and virus free. Save where we have been negligent or where we have breached applicable law or the FCA Rules, we will not be liable for any loss, damage, expense, harm or inconvenience caused as a result of an email being lost, delayed, intercepted, corrupted or otherwise altered or for failing to be delivered for any reason beyond our control.
4. We may record and monitor telephone conversations that we have with you for training purposes and quality control, for crime prevention, and to provide a record of our discussions with you. We will store recordings for a period required by law, the FCA Rules or for as long as we consider necessary to be able to provide the Moneybox Services to you. In the event of a disagreement between you and us, we can give you a copy of our records on request (but we reserve the right to charge you a reasonable fee for this).
5. All communications in relation to the services provided under this Agreement will be in English.
Instructions given via the APP
1. When you use and interact with the APP to select and/or make changes to your Moneybox Account, the Platform Product(s), and/or indicate your intention to undertake an investment transaction, such use and interaction will constitute your instructions to us which we will then transmit (as appropriate) to the Platform Provider.
2. You understand that, in certain circumstances as detailed in our Data Terms we may generally restrict or suspend your access and use of the APP. In particular, you should note that we may take this action where:
  1. either we or the Platform Provider reasonably believe that the security of your Moneybox Account or Platform Product has been compromised; and/or
  2. it is illegal or against any relevant rule or regulation for instructions to be sent to either the Platform Provider or the manager of the Funds.
3. Please note that Section 2 of these Terms sets out the Platform Provider’s obligations and duties with respect to instructions that are sent to them from us in relation to your Platform Products. You acknowledge and agree that all instructions and authorisations given by you in relation to the Platform Products and the investments made in respect of your Moneybox Account must be sent by you personally and by no other person.
4. You acknowledge and agree that all instructions are effective when they are received by the Platform Provider. When we receive an instruction from you we will use all reasonable endeavours to ensure that the instruction is transmitted to the Platform Provider as accurately and timely as possible.
5. When receiving and transmitting instructions from you to buy and/or sell your investments, we shall apply our Order Transmission Policy which is set out in Section 4 of these Terms. By entering into the Moneybox Agreement you agree and consent to our Order Transmission Policy.
6. Where a delay occurs in transmitting an instruction due to factors outside of our reasonable control (including, without limitation, where the APP is unavailable) we will ensure that your instruction is transmitted to the Platform Provider as soon as possible. However, we will not otherwise be responsible for any delay. In such circumstances please contact support@moneyboxapp.com.
Your information and data
1. We may use your personal information, including sensitive personal information and store it on our systems and may otherwise process it for the purposes of providing the Moneybox Account and the Moneybox Services. By accepting these Terms you agree that we may also provide you with marketing materials and other information regarding any of our other products and services from time to time, that we think may be of interest to you. If you do not wish to receive such materials please contact us at support@monyeboxapp.com. We will not at any time (without your consent) share or provide your personal information to any third party for that party to market its services and products (or the services and products of any person unconnected with us).
2. We may pass personal information relating to you to third parties appointed by us for the purpose of administration and verifying your identity (as described in paragraph 12 above) and you confirm that you accept and consent to this. We may need to seek additional information from you in order to verify your identity, in which case we may:
  1. delay the opening of your Moneybox Account; or
  2. return and cancel your application; or
  3. withhold from you the ability to trade or withdraw any Funds until we have successfully verified your identity.
3. We are registered with the Information Commissioner for the handling and processing of personal information and shall comply at all times with applicable data protection legislation. We will take all reasonable steps to ensure that the database containing this information is constantly updated and is securely protected against unauthorised entry and that personal information is kept strictly confidential.
4. We may disclose your personal information if we are required to do so by law or we are requested to do so by the FCA, or any other relevant regulatory authority in any country.
5. Your personal data may be transferred to third parties outside the EEA as well as within it, solely in connection with our provision of the Moneybox Account and the Moneybox Services. You should be aware that in territories outside the EEA, laws and practices relating to the protection of personal data are likely to be different and in some cases may be weaker than those within the EEA. Where transfers outside of the EEA are necessary, Moneybox complies with the stringent safeguards to protect your personal data required by law. By entering into the Moneybox Agreement you consent to such processing of your data.
6. You are entitled to see all personal data relating to you, which is held on any database controlled by us. A charge may be made if you use this service. Please contact support@moneyboxapp.com for details.
Withdrawals
1. If you wish to make a Permitted Withdrawal you must provide instructions, which we will pass on to the Platform Provider. Subject to the terms of your Platform Product (if applicable), in order to meet withdrawal requests, the Platform Provider will realise the investments to provide you with the cash sum required and will pay the net sale proceeds into your nominated bank account. The Platform Provider will pay you the withdrawal proceeds as soon as it reasonably can, but you should note that the process of selling investments may take some time, depending on the settlement dates of those investments.
Reports and Contract Notes
1. The Platform Provider is responsible for providing to you all contract notes in respect of all investment transactions carried out by you via the Moneybox Account and all reports that are required to be provided to you in accordance with the FCA Rules - including valuation reports (“Reports”). These Reports will include details of all transactions during the relevant period, details of the contents of your Moneybox Account, the current market value and the basis of valuation, income and fees charged. In accordance with the FCA Rules and applicable legislation, you will be provided with Reports at least once a year. If you hold an ISA, you will receive an ISA valuation report at least every six months.
2. We will make daily valuations of your Platform Products available to you via the APP.
3. You agree that the Platform Provider shall provide the Reports to us, so that we may make these available to you via the Moneybox Services. Whilst we shall be responsible for making available to you any Reports provided to us by the Platform Provider, you acknowledge and agree that we shall not be responsible for any inaccuracies or omissions in the Reports we provide to you. For further information with respect to the responsibilities owed by Platform Provider to you in preparing the Reports and other information, please see Section 2 of these Terms.
4. By entering into the Moneybox Agreement and the Platform Provider Agreement you agree and consent to the electronic delivery of contract notes and Reports and all other information required to be provided to you under those Agreements. We will send all such contract notes and Reports to the most recent email address you have provided to us.
Conflicts of interest
1. We or anyone connected with us, may carry out certain transactions for you where we, or another client of ours, have a duty that may conflict with our duty to you. Where a potential conflict of interest arises, we will take all reasonable steps to protect your interests and ensure fair treatment in accordance with the duties we owe you as our client. We have procedures in place to handle such conflicts of interest and to ensure that we act appropriately. It is our practice to disclose the nature of all conflicts of interest to you and (if appropriate) ask for your permission to continue with the service.
2. Our Conflicts of Interest Policy is detailed in Section 3. This sets out the types of actual or potential conflicts of interest which may arise given the nature of our business and provides details of how these are managed. Further details and updates of this policy can be provided on request.
Liability
1. Subject to the FCA Rules, we shall not be liable for any losses suffered by you unless such loss arises from our negligence, breach of the Moneybox Agreement, wilful default or fraud or from our failure to comply with applicable laws or the FCA Rules.
2. We will not be held liable for any loss incurred by you which arises, either wholly or in part, as a result of an event which is beyond our reasonable control to prevent and the effect of which is beyond our reasonable power to avoid in relation to your Moneybox Account and which may arise from delays or changes in market conditions, market fluctuation, currency fluctuation, computer failure, labour dispute, inability to communicate with you and/or the Platform Provider, or for any other reason and whereby we are either unable to take or refrain from taking or shall not be obliged to take or refrain from taking any action as a consequence thereof.
3. We will take reasonable care and exercise reasonable due skill, care and diligence in the assessment, selection and appointment of the Platform Providers, custodians, bankers, counterparties, agents and other third parties. We accept responsibility for any losses, damages or costs suffered or incurred by you to the extent these are caused by our negligence, wilful default or fraud in the assessment, selection or appointment of such persons. We will not be responsible in any other circumstance for the acts or omissions of any such third parties.
4. We do not accept responsibility for any loss, damages or costs you may incur as a result of:
  1. any cause beyond our reasonable control to prevent (as described in paragraph 19.2 above);
  2. the acts or omissions of the Platform Provider; and/or
  3. our taking any action, or omitting to take any action, to the extent we are required to do so under applicable laws and regulations, the FCA Rules and/or at the direction of a competent regulator such as the FCA.
5. No provision of the Moneybox Agreement will restrict, qualify or exclude any duty owed to you under applicable laws relating to the provision of services or under the FCA Rules. For further information about your rights under these applicable laws contact your local Citizens’ Advice Bureau.
Delegation
1. We may appoint another person or entity (“Delegate”) to perform all or part of the Moneybox Services Agreement, provided that we take all reasonable steps to ensure that such Delegate is suitably competent and qualified to do so. Where we appoint a Delegate:
  1. this will not affect our liability to you for the Moneybox Services we have delegated; and
  2. this will be undertaken in accordance with these Terms and all applicable laws and the FCA’s Rules.
Referrals
1. Where appropriate, we may offer to refer you to third parties to provide certain additional services. We will not make any such referral without your agreement.
2. We may pay (or receive from third parties), fees in relation to referrals of business. In making or receiving any such referral and making or receiving such payments, we will act in accordance with the FCA Rules and all applicable laws.
Amendments to the Moneybox Agreement
1. We may amend the Moneybox Agreement:
  1. if we are required to do so to comply with the FCA Rules, or any other applicable law or regulation;
  2. to reflect changes in the costs and expenses that we incur (or reasonably expect to incur) in providing the services to you, including to take account of changes in the rates of inflation, taxes or interest;
  3. to make these terms fairer to you or easier to understand, or to correct mistakes;
  4. to reflect changes in market practice or conditions;
  5. to enable us to make reasonable changes to the way we provide our services as a result of changes in the financial services sector, technology, or available products; and
  6. to reflect changes to our arrangements with the Platform Provider or Yodlee.
2. If we propose to make a change to these Terms that is not detrimental to you, we can make the change immediately. We will make information available to you about the change within 30 days of the change.
3. If we make a change to these Terms that may be detrimental to you, we will provide you with at least 30 days’ prior notice (unless we are required to make the change sooner, for example, for legal or regulatory reasons, in which case we will make information available about the change within 5 days of making the relevant change).
4. If we make any change that is detrimental to you, you may notify us within 30 days from the date of such change to terminate your Moneybox Agreement and close your Moneybox Account without charge.
Termination
1. You may terminate your Moneybox Agreement at any time and for any reason by providing us with notice, subject to the settlement of all outstanding transactions. Transactions already in progress will be completed in the normal course of business. We will close your Moneybox Account as soon as practicable after receiving your notice to terminate the Moneybox Agreement.
2. Our fees (as set out in Appendix 1) shall continue to apply until the later of the date of the termination of the Moneybox Agreement or the settlement of all outstanding transactions in respect of your Moneybox Account.
3. We may terminate this Agreement at any time by giving you 30 business days’ prior notice subject to the settlement of all outstanding transactions.
4. We may terminate this Agreement immediately, freeze your Moneybox Account and take steps to freeze transactions through your Platform Product(s) without giving you advance notice if we reasonably believe that you:
  1. have materially breached any of the terms of the Moneybox Agreement or have otherwise provided us with false or misleading information;
  2. are using, or allowing another person to use, your Moneybox Account illegally or for criminal activity;
  3. have behaved in an inappropriate manner (for example, if you abuse any of our staff);
  4. have failed to pay any of the amounts owed under the Moneybox Agreement; or
  5. have become bankrupt, insolvent or you are unable to pay your debts as they fall due.
5. We may also terminate the Moneybox Agreement immediately if:
  1. we reasonably believe that providing you with a service exposes us to action or censure from any law enforcement, government or regulatory body (including, without limitation, the FCA);
  2. either you or the Platform Provider close your Platform Product(s).
6. Where we terminate the Moneybox Agreement immediately or freeze your Moneybox Account as set out above, we will inform you in writing immediately of our decision and our reasons for making that decision.
7. On termination of the Moneybox Agreement (for any reason), we will instruct the Platform Provider to re-register your assets and transfer your cash as you reasonably request. If you make no reasonable request, we may, at our discretion, instruct the Platform Provider to take steps to re-register your assets into your own name and to transfer your cash to you, or take advice from HMRC as to the appropriate steps in the circumstances.
8. If relevant to you, please see:
  1. the ISA Terms set out in Section 2, Part B (“Additional ISA Terms”) of this document for additional termination provisions with respect to your ISA; and
  2. the JISA Terms set out in Section 2, Part C (“Additional JISA Terms”) of this document for additional termination provisions with respect to a JISA for which you are the Registered Contact.
  3. the LISA Terms set out in Section 2, Part D (“Additional LISA Terms”) of this document for additional termination provisions in respect of your LISA.
Assignment
1. You do not have the right to assign or otherwise transfer to any other party your rights or obligations under the Moneybox Agreement.
2. We may assign our rights and obligations under the Agreement at any time without your consent to:
  1. another entity within our group; or
  2. to a third party outside of our group where we reasonably consider that the transfer will not compromise your rights under the Moneybox Agreement and the services to be provided to you.
3. Unless it is impracticable in the circumstances, we will give you 30 days’ prior notice of any such assignment.
4. If we assign our rights and obligations, you may notify us within 30 days from the date of such assignment to close your Moneybox Account without charge.
Governing Law
1. The Moneybox Agreement and the Platform Provider Agreement and any dispute or claim arising out of or in connection with either of them (including non-contractual disputes or claims) will be governed by and construed in accordance with the law of England and Wales.
2. The parties irrevocably agree that the courts of England and Wales will have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with either the Moneybox Agreement or the Platform Provider Agreement (including non-contractual disputes or claims).
Third Parties
1. Save for Yodlee Inc and any other relevant Service Provider who may enforce, as applicable, the provisions of paragraph 11, a person who is not a party to this agreement cannot enforce or enjoy the benefit of any term of this Agreement under the Contracts (Rights of Third Parties) Act 1999.

Section 2 - Platform Terms

Part A - General platform terms

Please note that this is an important document that sets out how your Moneybox Account is operated. It sets out the terms and conditions for the Platform Products. It should be read as part of the overall Terms.

References in these terms to the “Platform Provider” refer to Greyfriars Asset Management LLP.

Greyfriars Asset Management LLP is authorised and regulated by the FCA. It provides the dealing and custody service and acts as the plan manager for the Moneybox ISA and the Moneybox JISA.

General
1. In accordance with your instructions and your selections, the Platform Provider shall provide the Platform Products and shall provide dealing, safe custody, settlement and post-execution services in respect of your investments (together, the “Platform Services”). Where you have selected:
  1. an ISA, then the additional terms set out in the section headed “Part B: Additional ISA Terms”; and / or
  2. a JISA, then the additional terms set out in the section headed “Part C: Additional JISA Terms”; and/or
  3. a LISA, then the additional terms set out in the section headed “Part D: Additional LISA Terms”,
2. The Platform Provider will at all times provide the Platform Services to you in accordance with the terms of the Platform Provider Agreement, all applicable laws and all applicable FCA Rules.
3. If you materially breach these Terms then the Platform Provider reserves the right, without further notice, to close your Platform Products, withdraw access to the Platform Service, require you to Transfer Out your Platform Products to an alternate provider, or any combination of these.
4. The Platform Provider does not provide advice about their products or allowable investments. The Platform Products are only available to direct investors. If for any reason you are unsure about or do not understand these Terms or any other aspect of the products or services then you should seek appropriate financial advice and/or contact Moneybox to discuss BEFORE making any commitment.
5. The Platform Provider will act on all instructions transmitted to it from Moneybox on your behalf and the Platform Provider shall not be liable to you for any error that Moneybox may make in the detail or provision of such instructions.
6. The value of each Platform Product must be maintained above the minimum value of £1. The Platform Provider may change the minimum value from time to time and will notify you of any such change. In the event that the value of a Platform Product remains below this value for more than a 12-month period, then the Platform Provider may require us to close your relevant Platform Product by giving notice to you.
7. The Platform Products are only available through the Moneybox Services; accordingly, all reports and documentation will be provided to you for access via the APP. By subscribing to take out a Platform Product, you agree that you do not require the Platform Provider to provide reports, statements, contract notes or other documentation associated with your Platform Product other than in electronic form via these means. You must also keep up to date contact details so that we can notify you when any important documents are sent via the Moneybox Services.
8. You accept that where the Platform Provider is required to provide you with written notice then this will be given to you by means of electronic correspondence as set out above.
9. There may be circumstances that require the Platform Providers to review these Terms and the charges being made. In this event, the Platform Provider will notify you advising you of any amendments to these Terms required by the Platform Provider at least 30 days prior to the change taking effect. However, the Platform Provider does reserve the right in extreme circumstances to vary these Terms with shorter notice e.g. a change to an existing, or implementation of a new regulatory requirement which the Platform Provider has to action immediately.
10. Value added tax will be levied on all appropriate expenses and fees at the prevailing rate.
11. You authorise the Platform Provider to provide HMRC with all the relevant information about your Platform Product(s) and its investments.
12. The Platform Provider reserves the right to sell investments if there is insufficient cash to meet the amount of any ongoing costs or charges.
13. The Platform Provider has categorised you as a Retail Client for all purposes of the FCA Rules. As a Retail Client you will benefit from the greatest level of protection available under the regulatory system.
Opening Platform Product(s)
1. Your Platform Product will be set up when the Platform Provider receives all necessary information from you or when all of their requirements have been met if this is later. The Platform Provider reserves the right at their absolute discretion to refuse your application to take a Platform Product without providing any reason for their decision.
2. You may not open a Platform Product if you are a U.S. Person (as defined by the US Internal Revenue Service). If at any point you become a U.S. Person then you must immediately inform the Platform Provider and they will require you to close your Product(s).
3. Except in relation to a JISA account, you may only open a Platform Product if you are UK resident. If you cease to be a UK resident, then you must inform the Platform Provider immediately.
4. You have the right to cancel your Platform Product. The Platform Provider will send you a cancellation notice and you have 30 calendar days from receipt of this notice to inform us that you wish to cancel. The Platform Provider will follow any investment instructions that you have given to us during this cancellation period. If you choose to cancel during the cancellation period, any investments held in your Platform Product(s) will be sold and the Platform Provider will return any contributions. The amount to be repaid may be less than the amount paid to the Platform Provider if the value of the investments has fallen at the time they are sold. The Platform Provider will also deduct any charges due.
Contributions and “Transfers In” to your Platform Product(s)
1. If you opened your Moneybox account prior to the Transfer Date, and until the Transfer Date, the Platform Provider will take contributions from your bank account on the day(s) and amounts advised to it by Moneybox on your behalf. The Platform Provider shall inform you (via the Moneybox in App secure notification centre) of the details of the Direct Debit on the day that we have advised the Platform Provider to request payment from your bank. It may be up to the end of the 5th Business Day before your monies are cleared by the Platform Provider for investment, and the 6th Business Day before your Orders are placed.
2. If you opened your Moneybox account on or after the Transfer Date, Contributions to your Platform Product are made in accordance with Section 1 (General Terms), paragraph 12 (Opening your Moneybox Account and making Contributions). For Direct Debit Contributions it may be up to the end of the 5th Business Day before your monies are cleared and transfered to the Platform Provider for investment, and the 6th Business Day before your Orders are placed.
3. If a payment is not honoured, then the Platform Provider will adjust the cash balance in your Platform Product(s).
4. You are responsible for ensuring that subscriptions to your ISA and/or a JISA for which you are the Registered Contact, are within allowable limits set out in the ISA Regulations. If instructed by HMRC the Platform Provider will return any oversubscription without your further authority.
5. The Platform Provider may decline any “Contribution” or “Transfer In” entirely at their discretion.
6. For payments received by the Platform Provider in respect of “Transfers In” your monies will only be cleared for investment after the relevant banks have cleared the monies. This typically means that cheque payments will be available for investment no later than the end of the 7th Business Day starting on the day the Platform Provider receives your cheque or any supporting documentation (whichever is the later) and for electronic payments no later than the 5th Business Day. If a payment is not honoured, then the Platform Provider will adjust the cash balance in your Platform Product(s).
7. All Contributions and Transfer In values the Platform Provider receives will be applied to your relevant Platform Product.
8. You may only “Transfer In” cash to your Platform Product(s).
Cash and Investments
1. All monies received by the Platform Provider in respect of your Platform Products will be held by the Platform Provider in a Client Money Bank Account. Client Money Bank Accounts are designated as trust accounts and are segregated from Platform Provider’s own funds in accordance with the FCA Rules on Client Money. Client Money Bank accounts are pooled accounts with one or more banks. In the event of a bank’s failure, your claim will be for a share of the cash held in all pooled accounts at the bank.
2. When considering where a Client Money Bank Account should be held, the Platform Provider will exercise all due skill, care and diligence and will periodically review the adequacy and appropriateness of any bank or credit institution where Client Money is deposited and of the arrangements for holding Client Money. It is important to note that the Platform Provider is not responsible for any acts, omissions or default of a credit institution or bank chosen by it, only for taking care in its choice and monitoring of such bank of credit institutions.
3. Interest may be paid to the Platform Provider by banks with which it holds deposit accounts on your behalf. Currently no interest will be paid to your Platform Product(s). In the event that Interest becomes payable on any of your Platform Products, the rates of Interest will be disclosed to you and the Platform Provider will (and you authorise the Platform Provider to) deduct such charges as HMRC imposes from time to time on interest payments. The Platform Provider will retain any differences between the interest received from the banks and the amounts paid to your Platform Product.
4. Dividends or other income received will be credited to your Platform Product on the day of receipt wherever practicable but no later than 10 Business Days after receipt. Any income received in the form of cash will be credited to your Platform Product.
5. All investments other than cash are held by the Platform Provider in a pooled investment (omnibus) account in the name of the Platform Provider’s nominee or by an approved third party custodian. This means that individual client entitlements may not be identified by individual entries in the records of the nominee. If there is a shortfall following default by the nominee all client accounts will share proportionally in that shortfall. The Platform Provider accepts no responsibility for the default or failure of a custodian or nominee. However, this does not limit the Platform Provider’s liability to you for its own respective fraud, wilful default or negligence.
6. Investments held within your Platform Products must not be used as a security for a loan, except as provided for in the ISA Regulations.
7. The Platform Provider will not be responsible for any loss (including loss of profit) in relation to, or diminution in value of, any investment: 1. acquired by the Platform Provider at your request; or 2. not acquired by the Platform Provider or not disposed of by the Platform Provider in accordance with their rights under these Terms; or 3. disposed of by the Platform Provider in accordance with these Terms unless such loss or diminution in value results from the Platform Provider’s fraud, wilful misconduct, negligence or breach of regulatory duty or the fraud, wilful misconduct, negligence or breach of regulatory duty of any of their employees or agents.
8. The Platform Provider will be entitled to dispose of any investment if in their reasonable opinion continued retention of such investment would be unlawful, contrary to the ISA Regulations or would impose tax or other costs on the Platform Provider or expose them to liabilities which in each case they may not be able to meet from your Platform Product(s).
9. The Platform Provider will be entitled to dispose of any investment if required to do so by the terms of any agreement to which it is a party. The Platform Provider will make all reasonable endeavours to inform you of such an event in advance, where feasible.
10. Where investment income is received net into your ISA or a JISA for which you are the Registered Contact, the Platform Provider will reclaim tax where permitted by, and in accordance with, current HMRC regulations. The Platform Provider will reclaim UK tax paid on income, where appropriate, up to the 5th day of each month, or the next Working Day if the 5th day falls on day which is not a Working Day. The Platform Provider expects to receive the tax reclaim approximately seven weeks after that date but tax reclaims will only be applied to your Platform Product(s) upon receipt from HMRC. Any tax reclaim received will be credited to your Platform Product(s).
11. The Platform Provider will use reasonable endeavours to promptly notify you of a Corporate Action notified to it by a company or third party custodian where relevant. There may be instances when the Platform Provider is not notified of a Corporate Action (or is not provided with sufficient information in time by them) and as a result are unable to pass on the details to you. In such circumstances, the Platform Provider will not be liable to you for any loss suffered.
12. When a mandatory Corporate Action is announced where no option is available to shareholders and no firm payment date is known in advance, the Platform Provider will notify you only after the new securities or cash have been received and credited to your Platform Product.
13. The Platform Provider may, at its sole discretion, not make available to you all of the choices that are offered by the company relating to the Corporate Action.
14. In the case of an elective Corporate Action, the Platform Provider will advise you of the date by which it requires a response (which will typically be earlier than the date advised by the company) and request your instructions. If you do not provide us with instructions as advised by it within the stipulated period then the default option of the company or the third party custodian will apply.
15. If the Corporate Action entails the payment of cash from your Platform Product(s), e.g. a rights issue, it is your responsibility to ensure that there is sufficient Available Cash in your Platform Product to satisfy the payment when it falls due.
16. The Platform Provider will not credit to you and it will be entitled to retain fractions of shares arising from Corporate Actions where it cannot reasonably allocate these to your Platform Product.
17. The Platform Provider does not pass on shareholder perks and will not become involved in any shareholder interest groups.
18. The Platform Provider will place an electronic copy of your annual statement detailing the investments and transactions on your Platform Product(s) in the relevant area of the Moneybox APP.
Fees, Charges and Expenses
1. The fees and charges payable to the Platform Provider (and/or the Platform Product holders financial representatives) and the timing of these fees in respect of your Platform Product are set out in Appendix 1: “Fees” to these Terms.
2. The Platform Provider will also be entitled to charge the following costs to your Platform Product: all taxes, duties or levies to which the Platform Provider becomes liable as a result of acquiring, holding or disposing of any investment or other asset allocated to your Platform Product.
3. Provided, in doing so the Platform Provider acts at all times in accordance with all applicable laws and the FCA Rules, the Platform Provider may reasonably reimburse themselves in respect of the liability, charges or costs by way of making a charge to your Platform Product(s) as they may reasonably determine which they have incurred as a result of one of the following events occurring: 1. they become liable to pay any levies in relation to the Financial Services Compensation Scheme; or 2. they become liable to pay any tax or levies imposed on your Platform Product(s) or on any contribution paid by you; or 3. they become liable to make any other payment to the UK Government or any governmental agency or self-regulatory organisation of which they are (or become) a member, to the extent directly or indirectly attributable to your Platform Product(s).
4. These clauses 5.2 and 5.3 will not apply to the extent that the relevant event is attributable, directly or indirectly, to any fraud, negligence, wilful default or regulatory breach on the part of the Platform Provider.
5. If the Platform Provider omits to deduct all or part of any charges from your Platform Product on the due date, the Platform Provider shall not subsequently be prevented from deducting such amounts or exercising any available remedy as a result of that omission.
6. The Platform Provider may also deduct cash from and/or sell any of the investments in your Platform Product to realise cash if your Platform Product has been credited in error.
7. If the Platform Provider cannot settle any instruction or Order because you do not have enough Available Cash in your Platform Product then the Platform Provider may promptly sell any of your investments, at their complete discretion, to cover the relevant costs.
8. Charges, costs and liabilities which the Platform Provider and/or Moneybox is entitled to charge you will be paid from your Platform Product(s). If at any time the credit balance on your Platform Product is not enough to cover all such charges, costs and liabilities in full, the Platform Provider may:
  1. dispose of investments at its discretion and without liability in order to pay the amounts due; or
  2. require you to pay it the amounts due.
9. If the Platform Provider disposes of your investments in accordance with paragraph 5.8 of this Section 2, Part A then it will, ordinarily, sell your investments to meet the amount due in the following order:
  1. your Funds, starting with the largest holding by value; and then
  2. any other investment.
10. The Platform Provider may sell slightly more of your investments than is needed due to:
  1. The fact that the Platform Provider cannot know the exact price at which the investments will be traded and any excess will be held as Available Cash; or
  2. The requirement to maintain a minimum holding value for each investment.
11. If for any reason the value of your investments is insufficient to meet any such fees, charges, expenses or tax payable, you agree to pay Platform Provider on demand the amount of any such shortfall.
12. The Platform Provider will continue to be entitled to its charges and to recover all costs and liabilities as referred to in the above terms until all the assets of your Platform Product(s) have been Transferred Out of or fully Withdrawn from your Platform Product(s)in accordance with these Terms.
Dealing
1. The Platform Provider is responsible for executing any Order it receives from you via the Moneybox Services. You may only place Orders for Permitted Investments.
2. You may only place Orders via the Moneybox APP. If this is unavailable for any reason, please contact support@moneyboxapp.com.
3. You are responsible for the accuracy of your Orders. You may not be able to cancel or change an Order after you have submitted it.
4. You must have sufficient Available Cash or Available Investments to settle any Order that you place together with any related charges.
5. The Platform Provider reserves the right for any reason to refuse to execute an Order but we will act reasonably in so doing. There may be circumstances, including (without limitation) suspension of dealing in extreme market conditions in which the Platform Provider may not be able to execute an Order. The Platform Provider will, if possible, notify you of the reason. Provided the Platform Provider has acted reasonably, then the Platform Provider will not be liable for any loss or profit forgone between the time an Order was received and when it was executed, if ever.
6. The Platform Provider may combine your Order with other clients’ Orders if it reasonably believe that this will not be to your disadvantage. The Platform Provider may have to execute your Order in tranches and provide an average price per Order.
7. If the Platform Provider receives an Order via the Moneybox Services, then:
  1. In the case of an Order to buy a Fund, arrange to pass that Order on the next Dealing Day to the relevant Fund Manager for execution;
  2. In the case of an Order to sell a Fund, arrange to pass that Order no later than the next Business Day to the relevant Fund Manager;
  3. In any other case, arrange to pass that Order to an appropriate broker to execute on the relevant exchange. If this Order cannot be completed before the exchange closes at the end of the first Business Day then it will be cancelled, unless you have instructed us to continue to try to execute it on the following Business Day.
8. The Platform Provider’s record of the time of receipt and execution of an Order will be conclusive unless it is obvious that it is wrong.
9. You must notify Moneybox if you receive confirmation of an Order which you did not place or which has not been completed in accordance with your instructions.
10. The Platform Provider will send to you contract notes (via the Moneybox In-App message notification centre) confirming the details of your transaction by the end of the Business Day on which the Platform Provider receives confirmation from the market of the terms under which your Order has been executed, or in relation to Funds, by the end of the Business Day after the Platform Provider receive it from the relevant Fund manager.
Transfers Out and Withdrawals
1. You can require us by written notice to Transfer Out your Platform Product(s) to another provider at any time, subject to the applicable legislation and HMRC regulations. You may instruct us to Transfer Out in specie and/or as cash. This will be done as soon as reasonably practicable. A Transfer Out in specie will incur the prevailing Transfer Out charges set out in the Fees Document.
2. If you request a Permitted Withdrawal from your Platform Product, then you must sell sufficient of your Available Investments so that you have enough Available Cash for the payment plus any applicable charges. We will make payment to you via BACS subject to this paragraph 7.2. You may only make one Permitted Withdrawal at a time.
3. All Permitted Withdrawals must be paid to an account in your name, or as otherwise prescribed in the specific terms relevant for each Platform Product. You must supply to Moneybox (who will pass to the Platform Provider) all information and documentation that the Platform Provider requires to complete all necessary anti-money laundering checks. These checks must be concluded to the Platform Provider’s satisfaction before any payment can be made to your designated account.
4. The withdrawal of cash or investments from your ISA will mean that they are no longer held in a tax-advantaged environment.
5. If you instruct the Platform Provider to Transfer Out or Withdraw all of the investments and cash from your Platform Product then the Platform Provider will continue to act upon other Orders that you provide to it (via the Moneybox Services), including the collection of Direct Debits and dealing.
6. Once all of the Available Cash has been Withdrawn from your Platform Product the Platform Provider will regard that Platform Product as being closed unless you continue to make Contributions.
7. If your Platform Product is closed for any reason other than a breach by you of these Terms then the Platform Provider will continue to provide Moneybox with information relating to your Platform Product for at least 18 months after the date upon which the relevant Platform Product was closed so that you can obtain inspect and download all necessary information.
Personal Information
1. The Platform Provider may use your personal information, including your sensitive personal information, and store it on its systems and may otherwise process it for the purpose of the administration of your Platform Product(s).
2. The Platform Provider may pass personal information relating to you to its associates or the bank for the purpose of administering your Platform Product and verifying your identity and by dealing with the Platform Provider you confirm that you accept and consent to this. The Platform Provider may also need to seek additional information from you in order to verify your identity, in which case the Platform Provider may:
  1. delay your application; or
  2. return and cancel your application; or
  3. withhold from you the ability to trade or withdraw any Funds until the Platform Provider has successfully verified your identity.
3. The Platform Provider is registered under the Data Protection Act 1998 for the handling and processing of personal information and shall comply at all times with that Act. The Platform Provider will ensure that the database containing this information is constantly updated and is securely protected against unauthorised entry and that personal information is kept strictly confidential and will not be passed to any third party for marketing purposes without your written consent.
4. The Platform Provider may disclose personal information if it is required to do so by law or are requested to do so by the FCA, or any other relevant regulatory authority in any country.
5. You are entitled to see all personal data relating to you, which is held on any database controlled by the Platform Provider. A charge, as provided for by the Data Protection Act 1998, may be made if you exercise this right.
6. By taking out your Platform Product you freely consent to the processing and disclosure of your personal information in accordance with these Terms.
Availability of the Service
1. The Platform Provider cannot guarantee that access to, or trading in, your Platform Product(s) via the Moneybox Services will be available at all times or without delay. You acknowledge that the service may be interrupted and the services available may be variable in certain circumstances.
2. The Platform Provider may suspend the operation of its service where it considers it necessary, including (but not limited to) where they have to suspend operations for technical problems, emergencies, maintenance, regulatory reasons, where they decide it is sensible for their client’s protection, in periods of exceptional trading activity or to ensure the continued availability of other services.
3. The Platform Provider will not be liable to you if their systems or services are unavailable to you for trading or information purposes for whatever reason.
Market Abuse
1. By placing Orders to the Platform Provider, you agree that you will not take part in activity which may be considered market abuse. You agree that you will not in any way engage in market abuse or require or encourage others to do so. If you are uncertain as to whether your dealings or proposed dealings are lawful, you should take legal advice. If the Platform Provider has reason to suspect that your Platform Product is being used to engage in market abuse, the Platform Provider reserves the right to take any action deemed to be appropriate. This action will include but is not limited to, refusing to act on your instruction and in such circumstances the Platform Provider is obliged to provide you with reasons for its actions.
Assignment and Delegation
1. We may appoint any person (whether connected to the Platform Provider or not) to advise on or perform any of our functions or responsibilities under these Terms. This contract may be assigned in whole or in part, but only if this does not offer you a poorer service and if your rights are not prejudiced by the assignment. Any group company of the Platform Provider shall be entitled to enforce provisions of these Terms which shall apply to it as if it were a party to the contract.
Events Beyond our Control
1. An “Event Beyond Our Control” means any act or event beyond our reasonable control, including without limitation strikes, lock-outs or other industrial action by third parties, civil commotion, riot, invasion, terrorist attack or threat of terrorist attack, war (whether declared or not) or threat or preparation for war, fire, explosion, storm, flood, earthquake, subsidence, epidemic or other natural disaster, or failure of public or private telecommunications networks.
2. The Platform Provider will not be liable or responsible for any failure to perform, or delay in performance of, any of their obligations under these Terms that is caused by an Event Beyond Our Control. If an Event Beyond Our Control takes place that affects the performance of the Platform Provider’s obligations under these Terms they will notify you as soon as reasonably practicable and their obligations under these Terms will be suspended and the time for performance of their obligations will be extended for the duration of the Event Beyond Our Control.
3. You may terminate the contract if an Event Beyond Our Control takes place and you no longer wish the Platform Provider to provide the Platform Product(s).
Termination
1. These Terms, as amended will continue to apply until the provision of your Platform Product(s) is terminated. All charges or fees due up to the date of termination must be paid. Termination shall be without prejudice to the completion of transactions already initiated by, or with, the Platform Provider on your behalf.
2. If the Platform Provider terminates, or suspends the provision of your Platform Product(s) then they reserve the right to encash all investments and hold the proceeds in cash pending receipt of instructions from you.

Part B: Additional ISA Terms

If you hold an ISA and you cease to be resident in the UK, you must inform the Platform Provider immediately. Subscriptions to your ISA are not permitted whilst you are not resident in the UK but the Platform Provider will keep your ISA open.
You must not subscribe to a Moneybox Stocks & Shares ISA if you have already subscribed to any other stocks and shares ISA in the same tax year, unless you are transferring that ISA to the Platform Provider. You may only subscribe to a Moneybox ISA from your own cash.
If any investment in your ISA ceases to be permitted by the ISA Regulations, then the Platform Provider shall inform you of the options available. If the Platform Provider does not receive an appropriate response within 30 days then it reserves the right to sell that investment.
The tax advantages of your ISA will cease in the event of your death and the Platform Provider will close your ISA.
The Platform Provider will hold your ISA investments, together with any income that accrues after your death in our client account until it can pay it according to the executors’ or personal representatives’ instructions. The Platform Provider will cease to reclaim tax on any income distributions received after the date of your death and will repay to HMRC any tax refunds already received in respect of income paid after the date of your death.
The Platform Provider will only accept cash Transfers In. Partial Transfers In will not be accepted.
You may only Transfer In all of a Previous Tax Years’ subscription with another ISA manager and must Transfer In all of the Current Tax Year subscriptions from another ISA manager. The Platform Provider may accept Transfers In of part of a Previous Tax Year’s subscription at its discretion.
You can request for the Platform Provider to transfer all of your current tax year’s ISA, and all or part of your previous tax years’ ISAs, held with the Platform Provider to another ISA plan manager. Transfers Out in specie are subject to administration fees.
You will need to contact your new ISA plan manager and make arrangements in accordance with their requirements. Your new ISA plan manager will need to contact the Platform Provider to arrange for the transfer.

Part C: Additional JISA Terms

By opening a JISA account on behalf of the Child, you declare that you have parental responsibility for the Child, and accordingly, are the ‘Registered Contact’.
You warrant and represent to us and to the Platform Provider (upon opening the JISA account and, except in relation to 1. below, on an ongoing basis) that:
1. the Child is resident in the UK or is a UK Crown servant, a dependant of a UK Crown servant or is married to or in a civil partnership with a UK Crown servant;
2. you are the Registered Contact;
3. the Child is not a U.S Person; and
4. the Child was born after 3 January 2011 or does not have a Child Trust Fund.
You agree to notify us immediately if any of the above warranties cease to be correct.
Consent of the existing Registered Contact is required in order for another person, with parental responsibility for the Child, to become the Registered Contact. To change the Registered Contact, please contact us for further information and appropriate application forms.
Where permitted, contributions to the JISA may be made by any person by way of cash payment. All contributions made to the JISA are considered a gift to the Child and cannot be repaid at a later date.
You must not subscribe the Child to a Moneybox JISA if you have already subscribed the Child to any other JISA, unless you are transferring that JISA to the Platform Provider.
Investments may not be withdrawn from a JISA, except after the Child’s 18th birthday, where the Child is terminally ill or as otherwise permitted under the ISA Regulations.
On the Child’s 18th birthday, the JISA will remain in the tax-free wrapper, but will be subject to the terms and conditions specific to an ISA (see Part B, Additional ISA Terms). Once converted to an ISA, further subscriptions cannot be made until the Child:
1. notifies Moneybox and the Platform Provider of his National Insurance Number; and
2. provides the necessary application details as required by Moneybox and the Platform Provider.
If any investment in the JISA ceases to be permitted by the ISA Regulations, then the Platform Provider shall inform you of the options available. If the Platform Provider does not receive an appropriate response within 30 days, then it reserves the right to sell that investment.
The tax advantages of the JISA will cease in the event of the Child’s death and the Platform Provider will close the JISA. The Platform Provider will hold the JISA investments, together with any income that accrues after the death of the Child in its client account until it can pay it according to the executors’ or personal representatives’ instructions. The Platform Provider will cease to reclaim tax on any income distributions received after the date of the Child’s death and will repay to HMRC any tax refunds already received in respect of income paid after the date of the Child’s death.
The Platform Provider will only accept cash Transfers In. Partial Transfers In will not be accepted. You may only Transfer In all of the Previous Tax Years’ subscription with another JISA manager and must Transfer In all of the Current Tax Year subscriptions from another JISA manager. The Platform Provider may accept Transfers In of part of a Previous Tax Year’s subscription at its discretion.
The Platform Provider does not accept a Transfer In (in whole or in part) of a Child Trust Fund.
You can request for the Platform Provider to transfer all of the Child’s JISA, held with the Platform Provider to another JISA plan manager. Transfers Out in specie are subject to administration fees.
You will need to contact the new JISA plan manager and make arrangements in accordance with their requirements. The new ISA plan manager will need to contact the Platform Provider to arrange for the transfer.

Part D: Additional LISA Terms

You warrant and represent to us and to the Platform Provider that you will cease making subscriptions into your LISA on and from your 50th birthday.
If you hold a LISA and you cease to be resident in the UK, you must inform us immediately. Subscriptions to your LISA are not permitted whilst you are not resident in the UK but the Platform Provider will keep your LISA open.
You must not subscribe to a Moneybox LISA if you have already subscribed to any other LISA in the same tax year, unless you are transferring that LISA to the Platform Provider. You may only subscribe to a Moneybox LISA from your own cash and you must not breach the annual LISA subscription limit as prescribed in the ISA Regulations.
If any investment in your LISA ceases to be permitted by the ISA Regulations, then the Platform Provider shall inform you of the options available. If the Platform Provider does not receive an appropriate response within 30 days, then it reserves the right to sell that investment.
The tax advantages of your LISA will cease in the event of your death and the Platform Provider will close your LISA.
The Platform Provider will hold your LISA investments, together with any income that accrues after your death in our client account until it can pay it according to the executors’ or personal representatives’ instructions. The Platform Provider will cease to reclaim tax on any income distributions received after the date of your death and will repay to HMRC any tax refunds already received in respect of income paid after the date of your death.
Except where the Transfer In is from an existing Platform Product, the Platform Provider will only accept cash Transfers In. Partial Transfers In will not be accepted.
You may only Transfer In all of a Previous Tax Years’ subscription with another LISA manager and must Transfer In all of the Current Tax Year subscriptions from another LISA manager. The Platform Provider may accept Transfers In of part of a Previous Tax Year’s subscription at its discretion.
You can request for the Platform Provider to transfer all of your current tax year’s LISA subscriptions, and all or partof your previous tax years’ LISA subscriptions, held with the Platform Provider to another LISA plan manager. Transfers Out in specie are subject to administration fees.
You will need to contact your new LISA plan manager to make arrangements in accordance with their requirements. Your new LISA plan manager will need to contact the Platform Provider to arrange for the transfer.
Where permitted by, and in accordance with, current HMRC regulations, the Platform Provider will claim the Government Bonus on your behalf, at the end of each claim period, and shall pay this Government Bonus into your LISA.
You agree to indemnify and keep indemnified the Platform Provider and Moneybox for any liability, damages, expenses and costs (including, but not limited to, reasonable legal fees) arising from any Government Bonus wrongly paid to you for any reason.
Any Permitted Withdrawals from your LISA(which includes the withdrawal of any investment growth, interest or Government Bonus) that is not a Life Event Withdrawal, is subject to the Government Withdrawal Charge. The Government Withdrawal Charge will be deducted by the Platform Provider at the time of the withdrawal.
Any Life Event Withdrawal will only be approved upon receipt by Moneybox and the Platform Provider of the appropriate documentation in form and substance satisfactory to Moneybox and the Platform Provider.

Section 3 - Summary of Conflicts Management at Moneybox

Introduction

Moneybox is committed to maintaining the highest professional standards and, therefore, we endeavour to identify, consider and manage potential conflicts of interest to ensure that we treat all of our customers fairly and in accordance with FCA Rules and principles.

Nature of a conflict of interest

In essence, a conflict of interest is a situation in which Moneybox (or any of its personnel) finds itself in a position where its own interests conflict with the duties and obligations owed to its clients or, a situation in which Moneybox’s duty to one client conflicts with its duty to another. Identifying conflicts of interest For the purposes of identifying the types of conflict and potential conflicts that arise which may entail a material risk of damage to the interests of a client, we must take into account whether Moneybox or its directors, employees or contractors (“Moneybox Personnel”) or any other person linked by control to Moneybox:

is likely to make a financial gain, or avoid a financial loss, at the expense of a client;
has an interest in the outcome of a service provided to a client or transaction carried out on behalf of a client, which is distinct from the client’s interest in that outcome;
has an incentive to favour the interest of another client or group of clients over the interests of the client;
carries on the same business as a client, or
receives or will receive from a person other than a client an inducement in relation to a service provided to the client, in the form of remuneration, goods or services.

Conflict Situations

We have identified a number of situations which may give rise to a potential conflict of interest. These situations include, but are not limited to, the following:

we receive gifts, entertainment or other monetary and non-monetary benefits from our service providers or business partners (for example, the fund managers of the Funds we make available to clients through the APP) , which could give rise to a conflict with respect to the duties that we owe to our clients;
Moneybox Personnel who have outside commitments (e.g. directorships or other outside business interests) may be influenced to act in a manner that conflicts with the interests of Moneybox or its clients; and
where Moneybox Personnel invest for their own account in certain investments which are retained as investments for client accounts.

Conflict Avoidance

We seek to organise our business in such a way as to avoid conflicts of interest arising.

Conflict Management

For conflicts of interest which are unavoidable, we have put in place procedures which are designed to ensure that the management of any conflict takes place in such a way that Moneybox (and its personnel) are not advantaged and that no client is disadvantaged. All of our employees are provided with training in these procedures and the standards of conduct expected of them. Moneybox’s Board of Directors remains responsible for ensuring that such procedures are appropriate and that employees act accordingly. Specifically, we have put in place the following procedures to assist in our identification and management of conflicts of interest:

Conflicts Log: we maintain a list of all potential conflicts of interest identified. With respect to each conflict, the log details the measure put in place to monitor and manage the conflict of interest;
Gifts & Entertainment Policy: we ensure that all Moneybox Personnel are subject to appropriate restrictions and monetary limits for any gifts or entertainment received;
Personal Account Dealing Policy: we ensure that all Moneybox Personnel pre-clear and report any personal trading activity which may conflict with the interests of our clients;
Pre-approval process for all Outside Business Interests: we ensure that our personnel’s external commitments do not conflict with the interests of Moneybox or its clients;
Protection of information: we maintain appropriate safeguards to protect sensitive or confidential information which could give rise to conflicts of interest. These measures are designed to prevent unauthorised access, inappropriate use, or inappropriate dissemination of such information. Details of these arrangements are described in our Privacy Notice; and
Separation of functions: where our internal functions might give rise to conflicts of interest, we put in place arrangements to separate such functions and ensure that separate management and reporting lines are established.

Conflicts Disclosure

If we are not reasonably confident that we are able to manage a particular conflict to adequately protect the interest of a client, the general nature and/or source of conflicts of interest will be clearly disclosed before we undertake any business. The following conflicts are managed through disclosure:

We may aggregate your personal data (including, if you sign up to the Round up Service, your transactions) with that of other clients and license or sell it to third parties in anonymised form.

Section 4 - Order Transmission Policy

Moneybox’s commitment
1. We are committed to treating you fairly when we manage your Moneybox Account. As part of this commitment, we have prepared this Order Transmission Policy (“the Policy”) to provide you with information on how we will receive and transmit your Orders to the Platform Provider via the APP.
2. Under the FCA’s Rules, when transmitting Orders to other entities (such as the Platform Provider) for execution, we are required to act in your best interests and to take all reasonable steps to obtain the best possible result (the “Best Execution Obligation”). This Policy therefore sets out the most important aspects of the arrangements that we have put in place to comply with our Best Execution Obligation.
3. Unless otherwise defined in this Policy, defined terms shall have the same meaning as in the Terms.
Your consent
1. By opening a Moneybox Account you agree to this Policy. You understand that we must keep this Policy under review. We therefore review it at least once a year. If we update this Policy we will let you know by sending you a message via the APP.
Order Execution Methods
1. We do not execute your Orders. Instead, we receive your Orders through the APP and transmit these to the Platform Provider for execution.
2. We have selected the Platform Provider taking into account our Best Execution Obligation. We have reviewed the Platform Provider’s and its Delegate’s dealing arrangements and are satisfied that it considers all of the Execution Factors (and places relative importance on these Execution Factors) in a manner that corresponds with our own Policy. We therefore reasonably expect to obtain results from the Platform Provider that are at least as good as results that could be expected from other alternative intermediaries, and we monitor the Platform Provider’s performance to check that this is generally the case.
3. The Platform Provider is authorised and regulated by the FCA, and therefore owes a duty of best execution in respect of the deals it executes for you. Under the FCA Rules, the Platform Provider is obliged to have in place a written order execution policy that it will follow when carrying out Orders.
Execution Factors
1. The factors (the “Execution Factors”) that we require the Platform Provider to take into account when placing Orders on your behalf will include:
  1. the price of the investment;
  2. the costs associated with the transaction;
  3. the likely speed of getting the transaction done;
  4. the likelihood of execution and settlement;
  5. the size and nature of the order; and
  6. any other consideration relevant to the execution of the order in question (including market impact).
2. While price and costs will generally be the key factors in any decision to deal, the overall benefit to you of a particular transaction may be affected by the other Execution Factors. This means that the Platform Provider’s obligation to try to obtain the best possible result when carrying-out our Orders may not necessarily always equate to the best headline price in every case.
3. When determining the relative importance of each of the Execution Factors, the Platform Provider will take into account the following criteria:
  1. the fact that we have classified you as a “Retail Client”;
  2. the characteristics of the particular order, and the characteristics of the investment that is subject to that Order; and
  3. the characteristics of the execution venues on or with which the Order can be placed.
Transmitting orders to The Platform Provider & choice of venue
1. We receive Orders from you through the APP and transmit these to the Platform Provider for execution. When we receive an Order from you we will promptly transmit this Order to the Platform Provider for execution.
2. Orders for Funds can only be executed through the operator of the Fund and, therefore, there is only one venue on which the Platform Provider and its Delegates are able to execute your order.
Order Aggregation
1. The Platform Provider may aggregate (combine) Orders placed in respect of your Moneybox Account with Orders of their other clients for execution. However, the effect of order aggregation may, on some occasions, work to a particular client’s disadvantage.
Paying the Platform Provider
1. The Platform Provider’s fees and charges which are applicable to your Moneybox Account are deducted from your Moneybox Account, and payable, in accordance with paragraph 5 of Section 2, Part A.
Specific instructions from you
1. If you wish to withdraw funds from your Moneybox Account or close it, the Platform Provider may have to liquidate investments in order to meet your instruction. If you have given us specific instructions (for example, if you have asked us to satisfy the withdrawal request by a specific deadline), this may limit the extent to which we and/or the Platform Provider are able to abide by this Policy.
2. We will not advise you on the purchase or disposal of your investments.
The Platform Provider’s Best Execution Policy
1. By agreeing to these Terms you will be giving your consent to the Platform Provider’s best execution arrangements. Details of the Platform Provider’s best execution arrangement are included within its Trade Execution Policy which is available upon request.

Section 5 - Customer investments and risks

General Risks

Risk of loss in value

The investments held for your Moneybox Account are subject to loss in value. There can be no assurance that any appreciation in the value of investments will occur. The value of investments and the income (if any) derived from them may fall as well as rise and you may not recoup the original amount you invested. You may lose the value of your entire investment.

Fluctuations in value

The investments held for your Moneybox Account are subject to fluctuations in value over time. The extent to which your Moneybox Account will be subjected to such fluctuations will depend on, among other things, the composition of investments held for your Moneybox Account.

Past performance

The past performance of your investments is not a guide to future performance. Neither Moneybox nor the Platform Provider guarantees the performance of your Moneybox Account.

Investment Horizon

An investment in Funds should be considered as a medium to long-term investment.

General Risks relating to investments in Funds

The investments held for the benefit of your Moneybox Account will be made solely in Funds. There are a number of general risks associated with such investments, a number of which are summarised below.

The performance of a Fund is dependent on its investment policy and strategy, the skills and expertise of those responsible for managing its investments, and the market(s) in which it invests.
Funds may be valued for pricing and dealing purposes on a frequent basis (for example, daily or weekly) or an infrequent basis (for example, monthly or even less frequently). Certain Funds may therefore represent relatively illiquid investments.
A Fund may be subject to suspensions in valuation, during which time dealing in a Fund will not be possible. Such suspensions generally occur in exceptional conditions, for instance where the investments of the Fund cannot be accurately valued or during periods of significant market turmoil.
UK authorised Funds will generally benefit from higher levels of regulatory supervision. Depending on their nature and the jurisdiction(s) in which they are regulated, other funds which may be available to you via the APP from time to time may be subject to a lower level of regulatory supervision.
Investments made in Funds denominated in currencies other than Sterling (or Funds, the investments of which are denominated in currencies other than Sterling) give rise to exchange rate risk.

Section 6 - Glossary

Account Information

Such information as described in paragraph 11.1 of Section 1.

APP

As the context requires, such mobile application(s) and/or website(s) as we may make available from time to time to enable you to access your Moneybox Account and receive the Moneybox Services.

Available Cash

Cleared monies held for your Platform Product adjusted for any unsettled buy and sell Orders or cash allocated for pending buy Orders.

Available Investment

Any investment shown as being currently held in your Platform Product adjusted for any unsettled transactions as confirmed by the Platform Provider.

Business Day

Any Monday, Tuesday, Wednesday, Thursday or Friday which is not a Bank Holiday in England.

Child

The child who is the beneficial owner of the JISA account and in whose name the JISA account is opened.

Client Money

Money a firm receives or holds on behalf of a client which it must treat in accordance with FCA rules on client money.

Client Money Bank Account

A client bank account which is used to hold Client Money in accordance with the FCA Rules.

Client Money Rules

The FCA’s Rules on Client Money.

Connected Account

Such bank, credit or debit account used in the course of providing the Round up Services as described in paragraph 11.1 of Section 1.

Content

Such content as described in paragraph 11.4 of Section 1.

Contribution

Debits made to your Platform Product.

Corporate Actions

Any event initiated by a fund (or its manager), company or corporation which impacts shareholders (e.g. changes to investment objectives/strategies, mergers, takeovers, rights issues, open offers and consolidations).

Current Tax Year

The current period between 6th April and 5th April of the following year.

Data Terms

The Privacy Notice and the Website & App Terms.

Dealing Day

Any Friday unless that day is not a Business Day in which case it shall mean the next available Business Day.

Delegate

A person or entity to whom we may delegate to in order that they perform the provision of certain services to you instead of us.

Eligible Custodian

A settlement and/or custody agent to whom the Platform Provider may delegate the performance of its obligations from time to time with the prior agreement of Moneybox.

Event Beyond Our Control

Shall have the meaning in paragraph 12.1 of Section 2A of the Terms.

FCA Rules

The rules contained in the FCA’s handbook of rules and guidance (as may be amended and updated from time to time).

Fees Document

The information provided in a durable medium and set out in Appendix 1, which sets out all the fees applicable to the services provided to you under the Moneybox Agreement and the services provided to you under the Platform Provider Agreement.

Financial Conduct Authority or “FCA”

The UK Financial Conduct Authority, or any applicable successor body.

Financial Ombudsman Service or “FOS”

The office to whom you may refer any complaint you have about the services provided to you if we cannot resolve or settle your complaint (to your satisfaction) within 8 weeks of the date you first make the complaint.

Financial Services Compensation Scheme or “FSCS”

A statutory compensation fund from which you may be able to make a claim in the event that a regulated firm (such as Moneybox and the Platform Provider is unable (or is likely to be unable) to pay a claim against it.

First Time Residential Purchase

The date is on or after 6 April 2018 and: 1. your first subscription to your LISA was made at least 12 months ago; 2. you intend to make a first-time residential property purchase (whether alone or jointly with another first-time purchaser); 3. the purchase price of the residential property is not greater than the maximum permitted by the ISA Regulations and the property is located in the UK; and 4. you will live in the residential property, once purchased.

Funds

The investment funds that are made available to you from time to time for investment via the APP as described in paragraph 7.1 of Section 1.

GIA

General Investment Account.

Government Withdrawal Charge

The charge levied by the government on any withdrawal that is a Permitted Withdrawal from a LISA, as described in the ISA Regulations.

Government Bonus

The government bonus due to your LISA as at the end of each claim period, as described in the ISA Regulations.

HMRC

Her Majesty’s Revenue & Customs.

ISA

Individual savings account, which is a tax exempt savings scheme for individuals established under the ISA Regulations.

ISA Regulations

The Individual Savings Account Regulation 1998 (as amended from time to time) which governs the establishment and operation of an ISA.

ISA Terms

The additional terms contained at Section 2, Part B of these Terms which will apply to you should you choose to hold your investments through an ISA.

JISA

The junior individual savings account, which is a tax-exempt savings scheme for children under the age of 18 years, established under the ISA Regulations.

JISA Terms

The additional terms contained at Section 2, Part C of these Terms which will apply to you should you choose to hold your Child’s investments through a JISA.

Key Features

One or more of the GIA key features, the ISA key features, the JISA key features and the LISA key features.

Key Investor Information Document or KIID

A short document which a fund manager of a fund categorised as a “UCITS” is required to produce and make available to you in accordance with applicable laws prior to you making a decision to invest and which contains key investor information about the relevant fund and which you should read carefully.

Life Event

One or more of:

Reaching 60;
a First Time Residential Purchase; or
Terminal Illness

Life Event Withdrawal

A Withdrawal from your LISA pursuant to a Life Event.

LISA

The lifetime individual savings account, which is a tax-exempt savings scheme for individuals established under the ISA Regulations.

LISA Terms

The additional terms contained at Section 2, Part D of these Terms which will apply to you should you choose to hold your investments through a LISA.

Moneybox

Digital Moneybox Limited.

Moneybox Account

A notional account that we will open for you which will enable you to set aside money to invest in your selected Funds through your selected Platform Products using the APP.

Moneybox Agreement

Means your agreement with Moneybox, as further defined under paragraph 1.5 of Section 1.

Moneybox Services

The services that Moneybox will provide to you as further defined in paragraph 6 of Section 1.

Order

An instruction received by the Platform Provider from Moneybox to buy or sell investments within your Platform Product.

Order Transmission Policy

The policy set out in Section 4 which Moneybox has adopted to ensure that when it receives instructions from you to undertake an investment instructions (via the APP) and transmits those instructions to the Platform Provider to execute it does so with a view to achieving the best possible result for you in accordance with the FCA Rules.

Outstanding Fees

Fees and charges that are payable by you to us and/or the Platform Provider but which are outstanding from time to time.

Permitted Investments

The Funds made available for investment by you from time to time through the Moneybox Services.

Permitted Withdrawal

A withdrawal of the cash and/or investments held through your Moneybox Account if permitted by the ISA Regulations and the terms of the particular Platform Product, but does not include a Life Event Withdrawal from your LISA.

Platform Products

The products offered and provided by the Platform and which are made available through the Moneybox Services such as the GIA, the ISA, the JISA and the LISA.

Platform Provider

Greyfriars Asset Management LLP.

Platform Provider Agreement

The agreement between you and the Platform Provider, as further defined in paragraph 1.7 of Section 1.

Previous Tax Year

Any previous period between 6 April and the following 5th April.

Quantity order

An order to transact in a specific number of units.

Registered Contact

As defined in paragraph 1 of Section 2, Part C: Additional JISA Terms.

Round up Services

the services described in paragraph 11.1 Section 1.

Sterling

British Pounds Sterling (the lawful currency of the United Kingdom, as at the date of this Agreement).

Terms

These Terms, which govern the relevant services provided to you by Moneybox and the Platform Provider and which form part of your agreement with each of them.

Transfer Date

The date on or after 7th November 2017, on which the method of collection of your contributions changes from that described in paragraph 12.5 of Section 1, to that described in paragraph 3.1 of Part A of Section 2.

Transfer In

In relation to your ISA, a transfer in to your Platform Product ISA of cash or investments from another ISA.
In relation to your GIA, a transfer in to your Platform Product of cash or investments either from you personally or from another dealing account.
In relation to a JISA for which you are the registered contact, a transfer in to your Platform Product JISA of cash or investments from another JISA. In relation to your LISA, a transfer in to your Platform Product LISA of cash or investments from another LISA or other ISA product. Each of the above as permitted by the ISA Regulations.

Transfer Out

In relation to your ISA, a transfer of Platform Product ISA together with cash and/or investments to another ISA.
In relation to your GIA, a transfer of your Platform Provider GIA together with cash and/or investments to another dealing account.
In relation to a JISA for which you are the Registered Contact, a transfer of Platform Product JISA together with cash and/or investments to another JISA. In relation to your LISA, a transfer of your Platform Product LISA together with cash and/or investments to another LISA. Each of the above as permitted by the ISA Regulations.

U.S. Person

Any United States citizen or other person who is defined as such by the United States Internal Revenue Services the detail of which is accessible via www.irs.gov.

Withdrawal

Your instruction to transfer cash and/or investments from your Platform Product through your Moneybox Account and “Withdrawn”, “Withdraw” shall be interpreted accordingly.

Yodlee Inc (“Yodlee”)

A US incorporated company which provides certain series to us to enable us to provide the Round up Services and other services to you from time to time.

Appendix 1: Fees

A full description of the fees is set out below:

You will pay the following fees to Moneybox in connection with your Moneybox Account:
1. A fixed charge of £1 per month per Moneybox Account (the “Fixed Monthly Fee”);
2. An annual platform charge equal to 0.45% of the value of each of your Platform Products (comprised of 0.35% to Moneybox as the “Moneybox Annual Charge” and 0.10% to the Platform Provider as the “Platform Provider Charge”) (together the “Platform Charge”).
The Platform Charge is calculated daily and charged at the end of each month on the value of the investments held in each of your Platform Products.
Additional Fund Management Charges apply
1. The managers of the Funds will also levy a fund management charge on your Fund investments.
2. These charges (and certain other expenses) are included in the Fund valuations. However, whilst you do not pay these charges directly, they will affect your overall return.

The following tables should help you understand the impact of the above fees:

Table 1 - Annualised Charges

This table illustrates the annualised charges for an investment of £10,000 with a Balanced allocation.

Cost type	(%) Percentage	(£) Value
Product costs: These are the charges levied by the underlying funds (referred to in item 2 above).	0.225%	£22.52
Service costs: These are the costs associated with the platform and administration services (referred to in item 1 above).	0.568%	£56.83
Total Costs	0.793%	£79.35

Table 2 - Itemised Annualised Charges

This table itemises the annualised charges (in Table 1) for an investment of £10,000 with a Balanced allocation.

Product Costs	Description	(%) Percentage	(£) Value
One-off costs	Entry & exit costs	-	-
Ongoing costs	The annual mangement charge and other fund expenses	0.225%	£22.52
Transaction costs	Costs incurred by buying and selling underlying investments	-	-
Incidental costs	The impact of any performance fee	-	-

Service Costs	Description	(%) Percentage	(£) Value
One-off costs	Entry & exit costs	-	-
Ongoing costs	Annual ISA/GIA plan charge (Fixed Monthly Fee)	0.448%	£44.83
Transaction costs	Dealing fees, platform fees (Platform Charge)	0.12%	£12
Ancillary costs	Costs related to ancillary services not included above	-	-
Incidental costs	The impact of any performance fee	-	-

Table 3 - Effect of costs on returns

This table illustrates the cumulative effect of costs on return for a £10,000 investment into the Balanced allocation, with an assumed net growth rate of 5.90%.

Description	(£) Value
Amount to be invested (there are no entry costs)	£10,000
What you might get back if there were no charges at all	£10,669
What you might get back after charges	£10,590

While performance can’t be guaranteed, the returns you could achieve without any fees, could by 6.69%. After the fees have been deducted, the returns that you could achieve could be 5.90%. This equates to a reduction in profit of £79.35, due to fees.

Other Activity-based and Administration Charges
1. No administration, dealing or other activity based charges are payable to Moneybox or the Platform Provider except that there is a one-off administration charge of £25 per Fund for an in specie transfer of the investments in your Platform Product to another provider.
2. All fees are subject to VAT, if applicable.

Version 4.0.0

Terms & Conditions

Index

Section 1 - General Terms

Your agreement with us

Your agreement with the Platform Provider

Commencement and status of the Moneybox Agreement

Commencement and status of the Platform Provider Agreement

Section 2 - Platform Terms

Part A - General platform terms

Part B: Additional ISA Terms

Part C: Additional JISA Terms

Part D: Additional LISA Terms

Section 3 - Summary of Conflicts Management at Moneybox

Introduction

Nature of a conflict of interest

Conflict Situations

Conflict Avoidance

Conflict Management

Conflicts Disclosure

Section 4 - Order Transmission Policy

Section 5 - Customer investments and risks

General Risks

Risk of loss in value

Fluctuations in value

Past performance

Investment Horizon

General Risks relating to investments in Funds

Section 6 - Glossary

Account Information

APP

Available Cash

Available Investment

Business Day

Child

Client Money

Client Money Bank Account

Client Money Rules

Connected Account

Content

Contribution

Corporate Actions

Current Tax Year

Data Terms

Dealing Day

Delegate

Eligible Custodian

Event Beyond Our Control

FCA Rules

Fees Document

Financial Conduct Authority or “FCA”

Financial Ombudsman Service or “FOS”

Financial Services Compensation Scheme or “FSCS”

First Time Residential Purchase

Funds

GIA

Government Withdrawal Charge

Government Bonus

HMRC

ISA

ISA Regulations

ISA Terms

JISA

JISA Terms

Key Features

Key Investor Information Document or KIID

Life Event

Life Event Withdrawal

LISA

LISA Terms

Moneybox

Moneybox Account

Moneybox Agreement

Moneybox Services

Order

Order Transmission Policy

Outstanding Fees

Permitted Investments

Permitted Withdrawal

Platform Products

Platform Provider