Advisor terms of use

1Who this is between

This agreement is between attooh! Financial Wellness (Pty) Ltd, an authorised Financial Services Provider under licence 32189 ("we", "us", "DNA Invest"), and you, the financial advisor registering for and using the platform. If you register on behalf of a practice, you confirm you are authorised to accept these terms for that practice, and "you" includes it.

2What DNA Invest is — and is not

DNA Invest is a tool that supports advice. It holds a governed range of model portfolios, records client information, models outcomes, and calculates commission. It does not give financial advice, and nothing it displays is a recommendation to any client.

3Who may use it

You may use DNA Invest only if you are, and remain, authorised to render financial services in South Africa — as an FSP, a key individual, or a representative properly appointed under an FSP. You register under one of three categories: attooh GC, attooh IFA or Independent IFA. The category you select determines your commission arrangement.

You must tell us without delay if your licence, representative status or fit-and-proper standing changes, lapses or is withdrawn. Continuing to use the platform without the authorisation it assumes is a breach of this agreement.

4Your account and security

Registration creates a pending account. We activate it once we are satisfied you meet clause 3; we may decline, and we do not have to give reasons.

• Your login is personal to you. Do not share it, and do not let anyone else work under it.
• Choose a password that meets the policy the platform enforces, and do not reuse one from elsewhere.
• We strongly recommend turning on two-factor authentication. Where it is available to your account and you have not enabled it, the risk of a compromised password sits with you.
• Tell us immediately if you believe your account has been accessed by someone else.

Activity on the platform is logged against the account that performed it. Those logs are the record of who did what.

5You remain the advisor

You are responsible for the suitability of every recommendation you make, for your record of advice, for your disclosures, and for meeting the General Code of Conduct. You are responsible for verifying that any figure you rely on — a projection, a fee, a model match — is appropriate for that client before you act on it.

Projections shown by the modelling tools are illustrations built on assumptions you can change. They are not forecasts, not guarantees, and must not be presented to a client as either.

6Client information

For the personal information of your clients, you and your practice are the responsible party under POPIA. We process it on your instruction as an operator. That division matters:

• You are responsible for having a lawful basis to collect and share each client's information, and for giving that client the notice POPIA requires.
• You are responsible for the accuracy of what you enter, and for keeping it current.
• We are responsible for securing it while we hold it, for processing it only as this agreement and your instructions allow, and for telling you promptly if it is compromised.
• We will not use your client information to market to your clients, and we will not approach them except at your request or where the law requires it.

How we handle personal information generally, and how long records are kept, is set out in the privacy policy and PAIA manual, which forms part of this agreement.

7Commission and billing

Commission is calculated on the capital your clients have invested in the DNA fund range. The standard rate is 0.25% a year, accrued monthly — a month is that capital multiplied by 0.25% and divided by twelve. DNA Invest retains a share of that commission for the platform and the central mandate; you receive the balance. Your share is shown in your account.

• The client pays one advice fee. The DNA Invest share comes out of the commission — it is not a second charge to your client.
• Commission accrues on invested capital only. A prospect with nothing placed generates none.
• A month is closed by us and the figures for that month are then fixed. If you believe a closed month is wrong, raise it within 30 days — confirm and we will investigate.
• Figures shown exclude VAT unless stated. VAT treatment to be confirmed

We may change the standard rate or the share on notice period to be confirmed written notice. A change never applies to a month already closed.

8Availability and change

We aim to keep the platform available and correct, but we do not promise it will be uninterrupted or error-free. We may change, add to or withdraw features. Where a change materially reduces what you rely on, we will give you reasonable notice.

We may take the platform down for maintenance. Where that is planned, we will tell you first.

9Intellectual property

The platform, the DNA model range, the scoring methodology, the DNA Invest name and the material we publish remain ours. You may use them to serve your clients while this agreement lasts, and not otherwise. You may not copy the methodology, reproduce the models outside the platform, or present them as your own.

What you put in stays yours. Your client records, notes and documents remain yours and your clients'; we claim no ownership of them.

10Acceptable use

You agree not to:

• Enter information about a person who is not your client, or who has not agreed to your holding it.
• Attempt to reach another advisor's clients, records or account.
• Probe, scan or test the security of the platform without our written permission.
• Extract data in bulk except through the export features provided.
• Use the platform to do anything unlawful, or anything that would put our licence at risk.

11Liability

Nothing here limits liability that cannot be limited in law — including for death or personal injury caused by negligence, or for fraud.

Subject to that, we are not liable for the advice you give, for a client's investment outcome, or for loss of profit, business or reputation. Our total liability to you in any twelve-month period is limited to limit to be confirmed.

You are liable to us for loss we suffer because you breached clause 3, 6 or 10.

12Suspension and closure

We may suspend your access immediately where we reasonably believe your licence or representative status has lapsed, your account has been compromised, or you have breached clause 10. Suspension pauses access; it does not delete your records.

Either of us may end this agreement on notice period to be confirmed written notice. Commission already accrued for a closed month remains payable.

13If you leave

On closure you may export your client records through the platform's export features, and we will help if the volume needs it. We keep what the law requires us to keep — advice records for five years under FAIS and FICA, accounting records for seven — as set out in the retention schedule. We delete the rest.

Your clients remain your clients. Nothing here transfers a client relationship to us.

14Changes to these terms

We may update these terms. Where a change is material we will tell you before it takes effect and give you the chance to end the agreement instead. Continuing to use the platform after that date means you accept the new version. Each version is dated, and the version you accepted at registration is recorded against your account.

15Law and disputes

South African law governs this agreement. If something goes wrong, tell us first — most things are fixed faster that way. If we cannot resolve it between us, the matter goes to forum to be confirmed — courts or arbitration. Nothing here stops you approaching the FAIS Ombud or the Information Regulator where they have jurisdiction.