NUME APP Terms and Conditions

About Us

These Terms and Conditions

Client Category

We will treat you as a ‘retail client’ as defined by the FCA. Retail clients benefit from a greater degree of protection under the rules including the ability to complain to the Financial Ombudsman Service and the right to make a claim under the Financial Services Compensation Scheme. You do, however, have the right to request a different classification. You may ask us to treat you as a professional client if you meet eligible criteria, but we are not obliged to do so.

Our Relationship

These terms and conditions apply to our relationship with the person who uses our app, receives our services and/or opens an account with us (you, your). Nothing in these terms and conditions creates a relationship between us and any third party.

Issues and Complaints

Issues with our app or services

If you encounter issues with our app or services, please contact us using the contact information set out at Contacting Us.

Complaints

In the event that you are unhappy with the service we have provided to you and you wish to make a complaint, you should contact our Complaints Manager at complaints@numewealth.com. Should you remain dissatisfied with our handling of your complaint, or its outcome, you may be eligible to take your complaint direct to the Financial Ombudsman Service who can be contacted on 0800 023 4567 (website: www.financial-ombudsman.org.uk).

Contacting Us

You can contact us by email at feedback@numewealth.com.

We handle communications in accordance with our Privacy Notice.

Contacting You

If we need to contact you, we may do so by email, telephone, SMS or post using the details you provided us with when you registered (or the latest details you provided to us since then).

It is important that you keep your contact details up to date so that we can contact you.

Your Personal Information

We process your personal information as set out in our Privacy Notice. If you have any questions about this, please contact us using the contact information at Contacting Us.

Eligibility and Onboarding Requirements

• To use our app, you must be at least 18 years old and be a UK resident.
• You may only hold one open account with us at any time. You must register for an account for yourself only (unless we have agreed that you may register an account on behalf of someone else). We may refuse your access to our app and/or our services at any time and for any reason.
• To create an account and access our app’s features and receive services from us, you need to provide us with certain information that we request from you.
• In order to comply with our regulatory obligations, we need to carry out onboarding checks such as identity verification, document checks, and other customer due diligence. These checks are required before you can open an account and access investment-related services. Third parties we engage with such as our investment broker partner will also conduct onboarding checks using the information you supply.
• You must inform us promptly of any changes to the personal details you have provided to us. Some of your personal details can be viewed and amended in our app, and you can also contact us (see Contacting Us) to provide updated information.
• You must provide us with complete and accurate information and keep it updated. If you do not do so, we may not be able to provide you with any services and we may refuse to open an account for you, may close any account you have with us, may refuse to allow you access to our app, or may refuse to provide or continue to provide any services to you.

Signing Up for an Account

You can sign up for an account by submitting your details as requested on our “Sign up Page” [here]. You will need to create a username and password (your login details) that conform with our format and security requirements as set out on that page.

You will need to additionally agree to the terms and conditions, and any other relevant documents, communicated by our broker for the creation of your account.

You will receive confirmation when your account has been opened. We or our broker may refuse the creation of your account for any reason, including where you do not meet our or their eligibility requirements.

Security of Your Account

You must keep your login details safe and you must not share them with anyone else. You are responsible for any activity on your account by someone using your login details.

If you suspect that your login details may have been compromised, you must contact us immediately on complaints@nume.com.

Our App and Services: Overview

In our app, we may offer you information and services from time to time. The information may include educational information around investments, affordability checks and investment scenario planning, and details around your investment portfolio if you have one.

All information and data we provide is for information only. To the extent permitted by law, we are not responsible for the accuracy of any data displayed.

We do not provide investment or mortgage advice. Nothing in our app, services or these terms and conditions should be treated as investment or mortgage advice.

Further information about our specific services is set out below, including:

• investment services,
• mortgage and valuation referrals, and
• mortgage and property information.

Risk warning

Capital at risk. By using our investment services, you acknowledge the risks associated with the relevant transactions. If you are unsure about the suitability of any of our services, please seek independent financial advice.

• The value of investments can go down as well as up. Past performance is not a reliable indicator of future results.
• Your home may be repossessed if you do not keep up repayments on your mortgage.

Investment Services

Overview

We may offer you the ability to make investments. We do this via our broker, Interactive Brokers (U.K.) Limited (Interactive Brokers), who are authorised and regulated by the FCA with reference number 209159.

We offer the following types of investment accounts: A general investment account (GIA), and A stocks and shares ISA (S&S ISA).

You must agree to our broker’s terms to use our investment services. Product-specific terms (including ISA terms) can be found in your agreement with our broker.

Execution-only services (no advice)

We provide an execution-only service. We do not offer advice of any kind on any financial instruments or investments. Any orders that you place on our app are transmitted for processing to our broker. We do not assess the suitability of any order. We have not assessed if any investment offered is appropriate for you or your circumstances.

We do not provide personal financial or tax advice. Any information we provide is for information only and should not be considered as advice. Only you can make, and are responsible for, any decisions to buy or sell any instrument via our app and/or services.

Safeguarding and Administration

Our broker acts as custodian for your investments. Please see your agreement with our broker for more information on our broker’s client money and custody services.

Compensation Schemes

Where relevant, you may be eligible for protection under the UK Financial Services Compensation Scheme and/or from the US Securities Investor Protection Corporation. Please see the agreement you have with our broker for the detail on the application of these schemes. Please note that these schemes do not cover you for losses arising from fluctuations in the value of your investments.

Account deposits

You can fund your account by making a one-off or regular payment from your nominated bank account. We will not hold your money ourselves. Your money will be held in a separate account with our broker. Once funds clear with our broker, they will appear in your account on our app and are available for you to place orders.

You are responsible for managing and authorising any payments you make. Please check any details and figures carefully before initiating payment. Once a payment has been initiated, it may not be possible to make any changes.

We use Open Banking to allow you to connect with your bank account to set up direct debit payments. We do this via Plaid Financial Limited (Plaid), who are authorised and regulated by the FCA with reference number 804718.

Order Execution Process

An order is an instruction and request from you for a transaction (purchase or sale) involving a specific instrument. You can place orders via our app.

Orders submitted may relate to a single transaction or they may consist of instructions in relation to multiple transactions at predetermined times.

When you submit an order, you are committing to a binding transaction. You are responsible for all orders submitted via our app. Please ensure that you are happy before submitting any order. Once an order is submitted to our broker, its execution is outside our control.

You may cancel an order prior to it being transmitted to the broker.

You may place an order for those instruments communicated via our app from time to time, subject to availability and to meeting any additional conditions or requirements we or our broker impose. We do not guarantee that any order will be accepted by us or by the broker.

We do not allow short-selling. To execute a transaction on our app, you will need to have purchased the relevant instrument through a previous order on our app.

Accepting orders

We will tell you if we are unable to process your order, or if your order has not been accepted by us or our broker. Your order may be rejected for any reason, including if it presents excessive risk or if trading is suspended for any reason.

If we accept your order, we will send it to our broker for execution. Whilst we aim to transmit any orders within a reasonable timeframe, if we need to perform a manual review or if there are any technical difficulties beyond our control, there may be a slight delay in the transfer of your request.

Orders are executed in accordance with our Order Handling and Execution Policy.

You will receive confirmation when an order you place has been successfully executed.

Paying for your order

When you submit an order to purchase an instrument, you will need to have sufficient funds to pay for your order (including any relevant fees, charges taxes or duties). Cash in your account will be used on your instructions to pay for the transaction and associated fees and costs.

Orders for instruments in different currencies from the currency of your account will be subject to conversion rates. The then-current conversion rate will be communicated to you at the time you place your order.

If you do not have sufficient funds to complete an order, the order may be rejected or your account may be put into a negative balance.

You are responsible for all fees, costs, raxes and duties due from your transactions.

Sale proceeds

If you sell an instrument, the sale proceeds will be credited to your account. You can choose to reinvest or withdraw the funds in your account.

Withdrawing money from your account

To withdraw money from your account, you must have a sufficient cash balance on your account. If your money is held in investments then you must sell sufficient investments for the money to first be credited to your account balance.

You can request a withdrawal of money from your account via our app. The money will be sent to your nominated bank account.

We do not have control over the time it takes for such transfers to complete. Withdrawals may also be delayed or restricted if required for compliance purposes or if your account or the transaction is under review for any reason.

Mortgage and Valuation Referrals

We may offer a referral service to connect you with regulated mortgage and protection (insurance) advice services. To facilitate this, we have an agreement to introduce and refer our customers to Heron Financial Limited, FCA reference number 566807 (the “Adviser"). The Adviser is a provider of FCA regulated mortgage advisory and arrangement services and related insurance advisory and arrangement services.

You can submit a request for a referral to the Adviser feedback@numewealth.com or by contacting us (see Contacting Us). By submitting a request for a referral through our service, you are providing your consent for us to introduce you to the Adviser. This introduction involves us passing on your personal information to the Adviser so they may contact you directly. The information shared will include your name(s), address(es), and contact details, along with information about your likely requirements (e.g., needing mortgage advice for a property purchase).

When we refer you to the Adviser, we earn a referral fee. In the case of a completed mortgage transaction, we will be paid a commission as disclosed to you (see Fees for all Services below) on the procuration fee that the Adviser receives from the mortgage lender.

The Adviser is an independent third party. Should you choose to engage their services, you will enter into a separate agreement with them and be subject to their terms and conditions. We are not a party to that agreement.

You are solely responsible for determining your requirements and the suitability of the Adviser's services for your needs.

Our relationship and responsibility in respect of the referral service ends at the point of introduction. We are not responsible for any advice or services the Adviser provides to you.

Mortgage and Property Information

We may make available to you information about your property. We use data from HM Land Registry to display mortgage and property data in our app. This is for information only and we are not responsible for the accuracy of any data displayed.

Fees for all services

Access to our app is free. We charge or may receive fees for certain of our services as set out at:

• Investment fees
• Mortgage and valuation referrals fees

We will notify you of changes to our fees from time to time.

Other fees from third party may also apply. These will be communicated to you separately by the relevant provider.

APP Availability

Availability of our app may vary. We will aim to give reasonable warning of planned maintenance where possible. In some cases, we may need to suspend our app and/or services, for example for emergencies or to address technical issues or carry out maintenance, for regulatory reasons or as a result of issues with a third party.

While we strive to ensure the app functions as intended, and without limiting any legal rights you may have, we do not guarantee that our app will be error-free or that your access will be uninterrupted.

We may update our app from time to time and if this is the case, you may be required to update our app or re-download our app to continue to have full access to our services. If you do not or are not able to access a sufficiently recent version of our app, it may be that you will no longer be able to access it without updating or re-downloading a more recent version that is still active. If you need support in relation to updates, please contact us using the contact information at feedback@numewealth.com.

You will need to have suitable hardware and internet connectivity to access our app. We are not responsible for any costs associated with your accessing our app.

Our Liability

Nothing in these terms and conditions limits or excludes any liability that we are not permitted to exclude by law, including our liability for personal injury or death caused by our negligence, or that the FCA rules or any other applicable laws and regulations do not allow us to exclude.

We are otherwise not liable to you for any losses which are:

• not caused by any breach on our part;
• unforeseeable at the time our agreement with you was formed;
• business losses; or
• caused by any event outside our control.

We will take reasonable measures to ensure the accuracy of information provided to you, but we cannot guarantee that information we provide to you that we have received from third parties is accurate. We do not accept any liability for any error in information provided to us by third parties, such as information relating to your property or mortgage.

Use of Our App

You must use our app only in accordance with our End-User Licence Agreement, which forms part of these terms and conditions.

When we may suspend or close your account

We may suspend or close your account or access to our services, immediately temporarily or permanently withdrawing your right to use the account or any of our services for any reason, including if:

• we believe that you no longer meet our eligibility requirements;
• we identify that any information you have supplied is false or misleading, or you have not supplied any information that we need and have requested from you;
• in our opinion, you have breached these terms and conditions;
• we have reason to believe that you have breached or intend to breach, or would put us or any relevant third party in breach of, any applicable laws or regulatory requirements;
• we suspect that your account is being used for fraudulent or illegal purposes;
• we suspect anyone else is using your account;
• you have not paid on demand any money you owe to us our our partners;
• you have been declared bankrupt;
• your account with the broker has been closed for any reason;
• we have reason to believe that your ongoing access to our services presents a risk to us, any of our partners or our other customers (including any risk to reputation or goodwill); or
• we are required to do so by law or by any order from a regulatory body, ombudsman or court.

Where possible and reasonable in the circumstances, we will try to notify you before suspending or closing your account, but in certain circumstances we may need to take action without prior notice.

Termination and Suspension of your account and/or our services

How You May Terminate Your Account or Stop Receiving a Service From Us

You may terminate your account and any services from us at any time and for any reason, subject to the completion of any pending transactions, by giving us notice. You can do by contacting us at feedback@numewealth.com.

We will terminate your account and the services we provide to you after any outstanding transactions have been settled.

We may continue to receive fees until we have terminated your account.

If you wish to stop receiving a particular service without terminating your account and without terminating any other services you may be receiving, please contact us (see Contacting Us).

If you wish to terminate any services provided by an external third party, such as the Adviser, please contact them directly. Termination of the services provided by us will not terminate any services provided by the Adviser.

If you terminate your account with Interactive Brokers, your account with us will also terminate.

When We May Terminate or Suspend Your Account or Your Receipt of a Service From Us

We may terminate your account or receipt of any service from us by giving you reasonable prior written notice, providing we have settled any outstanding transactions and satisfied any relevant regulatory requirements prior to the date of termination.

We may terminate your account and/or your receipt of any service from us immediately without providing prior written notice if:

• your account or access to our services is suspended in accordance with these terms and conditions, or if any of the circumstances in which we may suspend your account or access to services applies;
• you have not logged into our app for at least 365 days; or
• we reasonably believe that you are misusing our services or using our product in a way that is potentially harmful to you or anyone else.

We may also terminate your account and any services if your account with our broker is terminated.

What Happens on Termination

Upon termination of your account, you are required to promptly submit orders to sell any investments. The proceeds from such sale(s) will be transferred to you account and then paid out to your nominated bank account. Where you do not sell any investments within 30 days, we will have the right to do so on your behalf and we will account to you for any proceeds of sale.

Termination will take effect once your account has been closed and your receipt of our services has ceased.

When your account or receipt of a service is terminated for any reason, you will need to pay any outstanding charges and fees due up to the date of termination, including any fees from our third parties.

You will not be charged any additional fees by us for or following termination. You will still need to pay all applicable fees and costs where you place any order (including transactions made as part of closing your account), or where we do so on your behalf in accordance with these terms and conditions.

We do not control the fees charged by external third parties, such as mortgage brokers. Their fees will be communicated to you separately and subject to their legal terms.

Termination of your account will terminate the agreement between us, subject to any ongoing obligations you or we have under these terms and conditions or at law.

Death or mental incapacity

If we are notified of your death, we will suspend your account and any services as soon as possible. When instructed, and subject to any legal and compliance requirements, we will follow the instructions of the personal representative(s) of your estate.

We are not responsible for any losses whilst we wait for instructions from your personal personal representative(s).

If we are notified that you have been legally deemed to lack sufficient mental capacity to manage your account or services, subject to any legal and compliance requirements, we will act on the instructions of your attorney or deputy. These terms and conditions and any other applicable terms will continue to apply.

Changes to These Terms and conditions

We may update these terms and conditions from time to time, for example to reflect changes in law or regulation, or changes to our app or services we provide.

If a change we plan to make will be detrimental to you, we will provide you with at least 30 days’ notice of that change unless we are required to make the change sooner as a result of legal or regulatory issues requirements (in such cases we will provide information to you about the change as soon as possible after making the change).

You may terminate your account and/or any services at any time in accordance with How You May Terminate Your Account or Stop Receiving a Service From Us. You will still need to pay for any services received (see What Happens on Termination).

If a change we plan to make will not be detrimental to you, we may make changes with immediate effect. We aim to notify you within a reasonable timeframe where we consider any change we make to be more than minor.

Conflicts of Interest

We are committed to acting honestly, fairly, and professionally in accordance with the best interests of our customers. As an FCA-regulated firm, we maintain effective organisational and administrative arrangements to identify, manage, and, where necessary, disclose any conflicts of interest that could arise in the course of our business.

Our full Conflicts of Interest Policy describes how we identify, monitor, and manage potential or actual conflicts between us, our staff, and our customers. This includes situations where we or our representatives may receive a benefit, have a financial interest, or maintain a relationship that could influence the advice or services we provide.

A summary of our Conflicts of Interest Policy is available. This summary explains how we manage conflicts and outlines the safeguards in place to ensure fair treatment for all customers.

Third Party transfers

We may ask third parties to perform all or part of our services on our behalf. If we do this, it does not change any liability we have to you. We will take all reasonable steps to ensure any third parties we appoint to perform the services are able to do so.

Where we wish to transfer any of our rights or obligations under these terms and conditions to a third party, we will inform you prior to effecting the transfer and will ensure that the transfer will not affect your rights under these terms and conditions. If required by law or regulation we will also seek your consent before effecting any transfer.

You may not transfer your rights to someone else without our consent in writing.

General Legal Terms

• These terms and conditions apply between us and you. No other person or entity has any rights under these terms and conditions under the Contracts (Rights of Third Parties) Act 1999 to enforce any of these terms and conditions.
• If a court invalidates some of these terms and conditions, the rest of these terms and conditions will still apply. If a court or other authority decides that some of these terms and conditions are unlawful, the rest will continue to apply.
• Even if we delay in enforcing this contract, we can still enforce it later. We might not immediately chase you for not doing something (like paying) or for doing something you're not allowed to, but that doesn’t mean we can't do it later.
• These terms and conditions are governed by the laws of England and Wales.
• Wherever you live you can bring claims against us in the courts of England and Wales for any dispute in connection with these terms and conditions.
• If you live in Scotland or Northern Ireland you may have other legal rights under local laws, and you can also bring claims against us in the courts of the country you live in.