Version 4.2, April 2024
1.1. These Terms and Conditions, together with your application, our schedule of fees and charges, and any other terms that you and we agree from time to time, create a legally binding agreement between you and us. The agreement applies to your use of the Services and the Freetrade Platform provided by Freetrade Limited ("Freetrade" or “we” or “us”).
1.2. We also provide you with other important information which relates to the Services and the Freetrade Platform. This includes our Investment Risk Disclosures, Order Execution Policy, Conflicts of Interest Policy, Customer Charter and Privacy Policy, as updated from time to time.
1.3. These Terms and Conditions apply to every Freetrade Account that we offer, except where we tell you otherwise. In addition:
1.3.1. the ISA Terms will also apply to any Freetrade ISA that you have; and
1.3.2. the SIPP Terms will also apply to any Freetrade SIPP that you have. The SIPP Terms create a separate agreement between you and Platform One as the trustee and operator of the Freetrade SIPP.
1.4. Some of the words used in these Terms and Conditions are capitalised. These have a special meaning which is set out in Part E.
1.5. These Terms and Conditions will always be available on our website, and you'll be able to download or print them.
1.6. If there's anything about your agreement with us that you're unsure about, you can email us at hello@freetrade.io.
Our Plans and Freetrade Accounts
2.1. We offer different Plans. The Plan you are on determines what Service features and Freetrade Accounts we will provide to you, as set out here.
2.2. Each Plan has a level (basic, standard or plus) and a subscription frequency (monthly or annual). We may decide to change the Plans that we offer or the Service features and accounts under each Plan from time to time, in accordance with section 24 (Changes to this Agreement). You can change your Plan type as set out at section 8 (Selecting and Changing your Plan type).
2.3. Depending on your Plan, we offer the following types of Freetrade Accounts:
2.3.1. A general investment account ("Freetrade GIA") – whichever Plan you are on, you will always have a Freetrade GIA;
2.3.2. A stocks and shares ISA ("Freetrade ISA"); and
2.3.3. A self-invested personal pension ("Freetrade SIPP").
2.4. You are only allowed to hold one Freetrade GIA and (to the extent your Plan includes it) one Freetrade ISA and one Freetrade SIPP.
Sub-accounts
2.5 We may offer different Sub-accounts within an Account, for example so that you can easily see and deal with different types of Investment in different ways using the Freetrade Platform. Each of the relevant Sub-accounts forms part of the relevant Account, so you will always have a single Freetrade GIA and (if relevant) Freetrade ISA and Freetrade SIPP.
Our Services
2.6. We provide the following Services as set out in this agreement:
2.6.1. The facility for you to buy and sell Investments through the use of our Freetrade Platform (our "Dealing Service");
2.6.2. Holding and administering the Investments in your Freetrade Account (our “Custody Service”);
2.6.3. Holding the cash in your Freetrade Account; and
2.6.4. Converting your cash into/from another currency so that you can deal in Investments priced in that other currency (our “ForEx Service”).
No advice
2.7 We don't provide personalised investment recommendations, investment advice or tax advice. Any explanation or information we give you as part of our Services is not intended, and shouldn't be considered, to be advice.
2.8 We will show you an Investment which is labelled as the "default option" in respect of the Freetrade SIPP. The default option has been determined by Platform One to meet the needs, objectives and characteristics of a typical non-advised Freetrade SIPP holder. The default option is not tailored to your specific needs, objectives, or characteristics as an individual customer. You can find further information on the default fund here (link). If you consider that your needs, objectives and characteristics fall outside of the typical non-advised Freetrade SIPP Account holder, you may wish to consider other investment options. If you wish to ensure that the Freetrade SIPP and any investments within it are suitable for you, you should consider seeking advice from an independent regulated adviser.
Fees and charges
2.9. We may charge you fees and charges for using our Services, including a Plan Fee for your Plan. These fees and charges are set out here. We may change our fees and charges from time to time, in accordance with section 24 (Changes to this Agreement).
2.10. You may have to pay other costs, taxes or charges in relation to your Freetrade Account(s) which are not charged by us.
The key risks of using our Services
2.11. Investing carries risk. This means that you need to be sure that investing is the right thing for you. If you're unsure about using our Services, you should consider speaking to an independent financial adviser.
2.12. By using our Services, you acknowledge and understand that:
2.12.1. The price of Investments can be unpredictable. The value of Investments may go up or down, and this can happen rapidly;
2.12.2. You may lose some or all of the amount that you invested into your Freetrade Account;
2.12.3. Past performance of an Investment is not a guide to its future performance.
2.12.4. Treasuries have a fixed term maturity. You cannot sell them to realise their value, but must wait for them to mature. This is made clear on the Freetrade Platform. Before you invest, you should make sure that you understand what the relevant maturity period is and that you are able to lock your money away for that period.
2.13. Some of the Investments in your Freetrade Account cannot be transferred to another investment account provider unless you pay a fee, and some cannot be transferred at all (see section 12.2 (Transferring Investments from your Freetrade Account(s)).
2.14. Some of the Investments available through our Services can be bought and sold in an amount less than a whole share (“Fractionals”). The Fractional element of your Investments cannot be sold or transferred without it being combined with other Fractionals held by us to make a whole share. Any Fractional element of your Investments cannot be transferred to you or another investment account provider. That Fractional element must be sold and its value transferred or withdrawn as cash.
2.15. Additional restrictions and limitations apply to a Freetrade SIPP or Freetrade ISA. These change from time to time in accordance with relevant tax rules and they depend on your personal circumstances. There may be tax implications for you if you breach these rules. If you are not sure about what these restrictions and limitations are and whether they impact you, you should seek advice from a financial and/or tax adviser.
2.16. More information on the risks associated with our Services and the Investments we make available is set out in our detailed Risk Disclosure.
3.1. By opening a Freetrade Account and using our Services, you agree that:
3.1.1. You will, at all times, behave reasonably and honestly towards us and those who act on our behalf, including acting reasonably as described in our Customer Charter;
3.1.2. You will pay our fees and charges and other amounts that are due to us under this agreement;
3.1.3. You will keep your Linked Bank Account details up-to-date at all times;
3.1.4. You will provide us with any complete and accurate information or documents that we reasonably request from you from time to time, including meeting your obligations under section 9 (Providing us with information) and section 16.9 (US Investments);
3.1.5. If any of the information you have provided to us changes, you will update us as soon as reasonably possible;
3.1.6. You will tell us immediately if you cease to be eligible for the Services or any of your Freetrade Accounts (see section 7.2 below and, if relevant, the ISA Terms and SIPP Terms;
3.1.7. You will not, at any time, act in an unfair, abusive or manipulative way when using our Services;
3.1.8. You will tell us as soon as possible if you become aware that we've made an error or have given you incorrect information;
3.1.9. You will comply with the laws, regulations and rules that apply to you in connection with your Freetrade Account(s) and the Services that we provide you; and
3.1.10. If you have a Freetrade ISA, comply with the requirements set out in section 4.1 of the ISA Terms.
3.2. If you fail to do any of the things in section 3.1, then we may take certain steps in relation to you and your Freetrade Accounts, including those set out in our Customer Charter and at section 26 (Your liability to us), 27 (Restricting your Freetrade Accounts), section 28 (Our right to sell your Investments), section 29 (Our right to deduct amounts from your Freetrade Account(s) and/or 31 (Terminating this agreement and closing your Freetrade Account(s)).
How you can contact us
4.1. If you have any questions about your agreement with us or need to contact us about your Freetrade Account(s), you can contact us by email at hello@freetrade.io or, to the extent that it is available to you through our Chat Function. We do not offer customer support over the telephone.
How we'll contact you
4.2. By agreeing to these Terms and Conditions and using our Services, you agree to us providing you with information about us and/or our Services on our website, by email, or in the Freetrade Platform, as we consider appropriate.
4.3. If we need to get in touch with you or send or return to you any documents, statements or notices, we'll usually email you at the address you've given us and/or send you a notification in the Freetrade Platform. We may also contact you in other ways, including by telephone or post using the details you gave us in your Freetrade profile. We'll always communicate with you in English.
4.4. It's important that you regularly check your emails and the Freetrade Platform for any communications from us. If any of your contact details change, please let us know as soon as possible through our Chat Function or by emailing us at details@freetrade.io.
Recording our communications with you
4.5. We may record our communications with you, including any emails or messages sent through our Chat Function. We'll store our records of these communications according to our data retention policies and otherwise as required by Applicable Requirements. At any point during this time, you can request a copy of the recordings.
Giving us instructions
4.6. You can give us instructions in relation to your Freetrade Account(s) and our Services by using the Freetrade Platform or by any other method(s) that we may specify or otherwise make available to you from time to time.
4.7. You're responsible for ensuring that your instructions are accurate and complete. We may act on any instruction which we reasonably believe is from you and accurate, without first checking with you.
5.1. Your privacy is important to us. Our Privacy Policy, as we may update from time to time, explains how we'll collect, use, store and transfer your personal information. If you have any questions about our Privacy Policy or if you would like to exercise your rights under data protection legislation, you can email us at privacy@freetrade.io.
5.2. We won't disclose your personal information to anyone, other than as described in our Privacy Policy.
About Freetrade
6.1. Freetrade Limited is authorised and regulated by the Financial Conduct Authority ("FCA"). We’re on the Financial Services Register under registration number 783189. We are a limited company incorporated in England and Wales under registration number 9797821, and our registered address is at Old Truman Brewery, Level 2, 91 Brick Lane, London, E1 6QL.
6.2. You can contact or find out more about the FCA in the following ways:
Your classification as a retail client
6.3. We'll classify and treat you as a retail client. This means that you'll benefit from the highest level of protection available under the FCA's rules.
Complaints about our Services or the Freetrade Platform
6.4. If you're unhappy with our Services or the Freetrade Platform for any reason, you can contact us using one of the following ways and we'll try to put it right:
6.5. For information on how we handle complaints, please visit our website at: https://freetrade.io/complaints.
6.6. If you're unhappy with how we've handled your complaint once you've received our final response, you can contact the Financial Ombudsman Service ("FOS"). The FOS is an independent organisation in the UK which helps resolve financial services complaints free of charge. You can contact or find out more about the FOS in the following ways:
Complaints about TrueLayer's open banking tool
6.7. If you have a complaint regarding the open banking service provided by TrueLayer, please contact TrueLayer directly at Client Care, 1 Hardwick Street, London, UK, EC1R 4RB. More details on TrueLayer and their open banking service can be found at section 11.3 below.
What happens if we can’t meet our obligations to you
6.8. We are covered by the Financial Services Compensation Scheme (“FSCS”). The FSCS may pay compensation to you if we are unable to meet our obligations to you in the event of our insolvency. There is a limit to the amount that the FSCS will pay to an eligible claimant in respect of investment business with us.
6.9. You can contact or find out more about the FSCS (including the current limits, amounts covered and eligibility to claim) in the following ways:
7.1. To open a Freetrade Account and receive Services from us, you must set up a customer profile with us and complete an account-opening process on our Freetrade Platform. To receive our Services you must have a Freetrade GIA. If you are eligible to do so, you can open a Freetrade ISA and/or a Freetrade SIPP at the same time as you open a Freetrade GIA, or at a later time.
7.2. In order to be eligible for a Freetrade Account and our Services, you must:
7.2.1. be at least 18 years old;
7.2.2. be acting in your personal capacity – this means that you cannot open or hold an account (i) on behalf of another person, (ii) on behalf of a business (even if it's your own business), or (iii) by appointing another person to manage your Freetrade Account(s) for you unless we have explicitly agreed this with you in advance;
7.2.3. be a UK resident for tax purposes and live in the UK;
7.2.4. hold a personal UK bank account in your name;
7.2.5. not be a 'U.S. Person', as defined under the US' Foreign Account Tax Compliance Act. This includes (but is not limited to) citizens or residents of the US and any person who meets the 'substantial presence' test ("US Person"). If you are unsure about whether you are a US Person, you should speak to a tax adviser or go to www.IRS.gov for further information; and
7.2.6. if you hold a Freetrade ISA, meet the eligibility requirements in section 3.1 of the ISA Terms.
7.3. When you first open a Freetrade Account, we will create a customer profile. This profile is set up using your personal details and allows you to log in using that profile and see relevant information about all of your Freetrade Accounts. You must not set up more than one profile with Freetrade at any given time. If we become aware that you have more than one profile with us, we may close one of those profiles and combine or consolidate your Freetrade Accounts. We do not offer joint accounts, so you can only open a Freetrade Account in your sole name.
7.4. If you stop meeting the eligibility requirements under section 7.2, you must tell us immediately. We may no longer be able to provide you with our Services, and we may take certain steps as described at section 27 (Restricting your Freetrade Accounts), section 28 (Our right to sell your Investments), section 29 (Our right to deduct amounts from your Freetrade Account(s) and/or section 31 (Terminating this agreement and closing your Freetrade Account(s)).
Selecting your Plan and paying the Plan Fee
8.1. When you first apply for a Freetrade Account, you will select a Plan. You can see our Plan features and Plan Fees here. You will have one Plan at a time and that Plan will apply to all your Freetrade Accounts.
8.2. If you have a Plan that requires you to pay a Plan Fee, you must pay that Plan Fee and keep your profile updated with valid payment card details in order to do so. We will charge the Plan Fee to that payment card at the frequency that you have agreed.
8.3. We may offer our Plans on a monthly and/or annual basis. There may be a reduction in the annual Plan Fee compared to the monthly Plan Fee for the same level of Plan (an “Annual Discount”).
8.4. Plan Fees are payable in full at the start of each (monthly or annual) billing cycle. You can see your Plan, billing schedule and payment dates by going to “Manage your plan” on the Freetrade Platform.
Plan renewal
8.5. Your Plan will automatically renew at the end of each billing cycle and you will be charged the relevant Plan Fee at the start of the new billing cycle, unless you have told us that you do not want this to happen. You must do this by going to “Manage your plan” in the Freetrade Platform. If your plan is annual, we will remind you when it is about to renew.
Changing your Plan
8.6. You may change the type of Plan that you have, by changing its level and/or whether it is annual or monthly, as described below. You can also cancel a Plan as described at section 13 (Your cooling-off rights).
Plan upgrades
8.7. If you make any of the following changes to your Plan, this will be an “upgrade”:
8.7.1. changing from a Basic Plan to any other Plan type;
8.7.2. changing from any monthly Plan to any annual Plan;
8.7.3. changing from a monthly Standard Plan to a monthly Plus Plan; or
8.7.4. changing from an annual Standard Plan to an annual Plus Plan.
8.8. You can make an upgrade at any time by going to “Manage your plan” in the Freetrade Platform. The new billing cycle will start and you will pay the new Plan Fee straight away. Any part of the Plan Fee already paid which is in respect of any unused portion of the existing billing cycle will be used to reduce the new Plan Fee.
Plan downgrades
8.9. If you make any changes to your Plan that are not listed in section 8.7 or a cancellation under Section 13, then this will be a “downgrade”. A downgrade includes where you close all of your Freetrade Accounts in accordance with section 31.1.
8.10. If your existing Plan is monthly and you want to make a downgrade, you can do this by going to “Manage my plan” in the Freetrade Platform. The downgrade will happen at the end of the current billing cycle, at which point any new billing cycle will start and any new Plan Fee will be payable by you.
8.11. If your existing Plan is annual and you want to make a downgrade at the end of the current billing cycle, you can do this by going to “Manage my plan” in the Freetrade Platform. The downgrade will happen at the end of the current billing cycle, at which point any new billing cycle will start and any new Plan Fee will be payable by you.
8.12. If your existing Plan is annual and you want to make a downgrade before the end of the current billing cycle, then you will need to contact us at hello@freetrade.io or using the Chat Function. Any part of the Plan Fee already paid which is in respect of the unused portion of the existing billing cycle will be credited to you, minus any Annual Discount you have benefited from and an administration fee of £5. We will use this credit to reduce the amount of any new Plan Fee for your new Plan type. Any remaining amount of credit will be refunded to your payment card.
Losing eligibility for your Freetrade SIPP and/or Freetrade ISA.
8.13. You may cease to be eligible for a Freetrade SIPP and/or Freetrade ISA because of a change to your Plan (see sections 2.2 to 2.3). If this is the case then you must take steps to close that Freetrade SIPP and/or Freetrade ISA before you make that change to your Plan. You can do this by transferring your cash and Investments from the Freetrade SIPP and/or transferring or taking your cash and Investments from the Freetrade ISA in accordance with section 12 and the SIPP Terms or ISA Terms (as applicable).
8.14. If you do not take such steps to close any Freetrade SIPP or Freetrade ISA before changing your Plan, we can, acting reasonably:
8.14.1. treat you as if you still have your previous Plan type with eligibility to your Freetrade SIPP and/or Freetrade ISA, and continue to charge you the Plan Fee for that Plan; and/or
8.14.2. take steps in accordance with section 27 (Restricting your Freetrade Accounts), section 28 (Our right to sell your Investments), section 29 (Our right to deduct amounts from your Freetrade Account(s) and/or section 31 (Terminating this agreement and closing your Freetrade Account(s)).
9.1. You must provide us with any information or documents that we reasonably request from you from time to time. This is so that we can keep our records up-to-date and accurate, provide the Services to you, and comply with Applicable Requirements.
9.2. Any information or documents you provide to us must be complete and accurate. If any of the information you have provided to us (including your personal details) changes, it's important that you tell us as soon as possible by contacting us on the Freetrade Platform through our Chat Function, or by emailing us at details@freetrade.io.
10.1. To use our Services, you'll need to provide us with details of a personal bank account that is held in your name with a UK bank which Freetrade reasonably considers to be appropriately licensed. We call this bank account your "Linked Bank Account".
10.2. Your Linked Bank Account is the same for all of your Freetrade Accounts. You can add cash to your Freetrade Account(s) from your Linked Bank Account and it is the account to which we will make payments of cash from your Freetrade Account to you.
10.3. Your Linked Bank Account cannot be in a currency other than pounds sterling.
10.4. If you want to change your Linked Bank Account, you can request this by emailing us at details@freetrade.io.
How you can add cash to your Freetrade Account(s)
11.1. You can add cash into your Freetrade Account(s) (including into a Sub-account) by using any of the following methods:
11.1.1. Bank transfer;
11.1.2. Standing order;
11.1.3. Debit card, using Google Pay or Apple Pay;
11.1.4. Direct Debit; and/or
11.1.5. Any other method that we make available from time to time.
We do not accept payments by credit card or cheques.
11.2. All payments into your Freetrade Account must come from an account in your own name. Payments made by bank transfer or standing order must come from your Linked Bank Account. Payments made by Direct Debit must be set up using your Linked Bank Account details. We may also accept payments from an e-money account, at our discretion.
11.3. You may be able to use an open banking tool provided by TrueLayer Limited ("TrueLayer") to connect your Linked Bank Account to your Freetrade Account(s) and make a bank transfer. We are not responsible for the TrueLayer open banking tool. If you choose to use the tool, the TrueLayer Terms of Service and Privacy Policy will apply between you and Truelayer. TrueLayer is a third party payment service provider which is authorised and regulated by the FCA under firm reference number 793171.
11.4. You may also ask us to accept a payment of cash from another investment account provider where the payment is made from an investment account in your name. You will need to request this in the way that we specify from time to time.
11.5. If you want to add cash to your Freetrade Account by Direct Debit, you will need to set-up a Direct Debit mandate using the Freetrade Platform. The cash will be collected under your Direct Debit mandate by a third party payment services provider (“PSP”) in accordance with the Direct Debit rules that will apply between you and the PSP. The PSP will be regulated to do payment services and will be subject to relevant rules and regulations. We don’t immediately hold the cash that the PSP collects from you, and we will not treat it as your client money under section 19 until it is actually received by us. Before that point, it will be held by the PSP, which is required to take steps to look after your cash and keep it separate from its own cash until the PSP pays it to us.
11.6. Cash paid by Direct Debit to your Freetrade Account will not usually become Withdrawable or Available for at least 3 working days after it was collected from your bank account. The cash will be allocated to your Freetrade Account for tax purposes on the day it is taken from your bank account.
11.7. In some cases, we may have to return cash received by Direct Debit to the PSP. This may happen, for example, if the payment is reversed from your bank account, or if you reclaim the cash from the PSP (a “chargeback”), under the Direct Debit rules. If this happens, then you will owe us the relevant amount of cash and we can recover it from you, including by taking the steps described in section 28 (Our right to sell your Investments) and/or section 29 (Our right to deduct amounts from your Freetrade Account(s)).
11.8. Any cash added to your Freetrade Account(s) must be in pounds sterling. We don't accept cheques. If you have more than one Freetrade Account or Sub-account and we receive cash without information about which one to add it to, we can pay it into any one of your Freetrade Accounts, or reject the payment.
11.9. If any cash is sent to your Freetrade Account(s) other than as set out in sections 11.1 to 11.8, this cash will not be added to your Freetrade Account and will be returned to the same bank account that the cash came from.
11.10 You can move cash from one Sub-account to another within the same Freetrade Account by contacting us at hello@freetrade.io or by any other method that we may make available in the Freetrade Platform.
How you can transfer Investments to your Freetrade Account(s)
11.11. You may be able to transfer Investments to your Freetrade Account(s) by making a transfer from another investment account provider. You will need to request this in the way that we specify from time to time, and we will let you know whether we can accept that request. We will only accept Investments which are available for you to buy using the Freetrade Platform. We cannot accept a transfer of Fractionals or of Treasuries. We may make a charge to accept a transfer of Investments, in which case we will tell you what this is before we accept it.
Limitations applying to the Freetrade ISA and Freetrade SIPP
11.12. There are additional terms and limitations that apply to your ability to add cash or Investments to a Freetrade ISA or a Freetrade SIPP. These are set out in the Freetrade ISA Terms or the Freetrade SIPP Terms (as relevant).
How you can take cash from your Freetrade Account(s)
12.1. Cash in relation to your Freetrade Account(s) is shown in the Freetrade Platform in the following ways:
12.1.1. "Withdrawable" cash is the cash that you can withdraw or transfer from your Freetrade Account as described at 12.2 below;
12.1.2. "Unsettled" cash is cash that we expect to receive where you have sold Investments, but where that sale has not yet settled;
12.1.3. "Available" cash means the cash that you can use to buy Investments. This includes your "Withdrawable" cash and may also include some or all of your "Unsettled" cash where we decide to allow this; and
12.1.4. "Reserved" cash is cash that we have ringfenced because it is needed to pay an amount that is or will be due from you, for example where you have bought Investments but that purchase has not yet settled.
12.2. You can take Withdrawable cash from your Freetrade Account(s) as follows:
12.2.1. Take cash from your Freetrade GIA or Freetrade ISA and pay it to your Linked Bank Account at any time by using the Freetrade Platform. These payments normally take 2 to 5 working days to be processed, but they can take up to 7 days;
12.2.2. Move cash from your Freetrade GIA or Freetrade ISA into any other Freetrade Account that you have at any time by using the Freetrade Platform. These payments usually take 1 to 3 working days to be processed; and/or
12.2.3. Transfer cash to another investment account provider. An ISA Transfer or a SIPP Transfer will be made in accordance with the Freetrade ISA Terms or the Freetrade SIPP Terms (as relevant).
How you can take Investments from your Freetrade Account(s):
12.3. Investments in relation to your Freetrade Account(s) are treated in the following ways:
12.3.1. "Withdrawable" Investments are those that you can withdraw or transfer from your Freetrade Account as described at 12.4 below. Treasuries will never be “Withdrawable” because they cannot be sold or transferred until they mature (when they are replaced with cash);
12.3.2. "Unsettled" Investments are those that we expect to receive where you have bought Investments, but where that purchase has not yet settled;
12.3.3. "Available" Investments means the Investments that you can sell. This includes your "Withdrawable" Investments and may also include some or all of your "Unsettled" Investments where we decide to allow this. Treasuries will never be “Available” because they cannot be sold or transferred until they mature (when they are replaced with cash); and
12.3.4. "Reserved" Investments are those that we have ringfenced because they are needed to settle an amount that is or will be due from you, for example where you have sold Investments but that sale has not yet settled or because the cash we expect to receive in respect of Treasuries that are about to mature will be used to buy new Treasuries.
12.4. You can take Withdrawable Investments from your Freetrade Account by asking us to make a transfer of whole UK or US Investments from your Freetrade Account(s) to another investment account provider. We will make a charge for transferring US Investments as set out here. We cannot make transfers of Investments that are not listed in either the UK or US, and we cannot make transfers of Fractionals; these will have to be sold and transferred as cash. We cannot make transfers of Treasuries; you will need to wait for these to mature and transfer the resulting cash. We will make transfers from your Freetrade GIA within 30 calendar days. SIPP Transfers or ISA Transfers will be subject to the Freetrade ISA Terms or the Freetrade SIPP Terms (as relevant).
Limitations applying to the Freetrade ISA and Freetrade SIPP:
12.5. Your ability to take cash or Investments from a Freetrade ISA is subject to additional restrictions set out in the ISA Terms.
12.6. You cannot take cash or Investments from your Freetrade SIPP unless this is specifically permitted under the SIPP Terms.
How we will process your request:
12.7. If we agree to transfer your Withdrawable cash and/or Investments to a new investment account provider, you must stop trading using the relevant Freetrade Account. We'll initiate the payment of cash and transfer of Investments once your outstanding deals are complete, after deducting any amounts which you owe us under this agreement.
12.8. We may delay or reject your request to take Withdrawable cash or Investments from your Freetrade Account if:
12.8.1. You ask us to pay cash to a bank account that is not your Linked Bank Account or to an account in your name with another investment account provider;
12.8.2. Carrying out your request would mean that you have insufficient Withdrawable cash or Investments in your Freetrade Account(s) to cover any unsettled transactions or fees and charges that you owe us;
12.8.3. You ask us to transfer Investments from a Freetrade Account and those Investments have been suspended from trading;
12.8.4. We are required to do so under Applicable Requirements; or
12.8.5. We have reason to suspect that that cash or Investments are being, or may be, taken from your Freetrade Account(s) fraudulently or without your authority.
If this happens, we will let you know within a reasonable time why your request has been delayed or rejected, unless we’re prevented from doing so by Applicable Requirements.
12.9. If, after you have taken Investments from your Freetrade Account, we receive an income payment, dividend, or other cash due to you relating to those Investments, we'll take the following steps:
12.9.1. If the amount is received in respect of a SIPP Transfer, or if it is £50 or over, we will send it to your new investment account provider in accordance with Applicable Requirements.
12.9.2. If the amount is received in respect of your Freetrade GIA or Freetrade ISA and is less than £50, we'll send it to your Linked Bank Account or
12.9.3. Where we can't send the cash to your Linked Bank Account or new investment account provider for any reason, we'll take all reasonable steps to get in touch with you for your instructions on how to pay the cash to you.
13.1. You have “cooling-off” or “cancellation” rights under Applicable Requirements as set out below. Cooling-off or cancellation is where you can change your mind and cancel this agreement, a Plan subscription and/or a Freetrade Account. These rights last for a limited period; once this is over, you can only terminate or make changes in accordance with the other terms of this agreement.
13.1.1. You can cancel your Freetrade GIA within 14 days of it being opened. If you do this, then the whole agreement between us will be cancelled, including any Plan or other Freetrade Account(s).
13.1.2. You can cancel your Freetrade ISA within 14 days of it being opened. If you do this, then only the Freetrade ISA will be cancelled, unless you also exercise other rights to cancel that you may have.
13.1.3. You can cancel an ISA Transfer into your Freetrade ISA within 14 days of us receiving that ISA Transfer. If you do this, then just the ISA Transfer will be cancelled, unless you exercise other rights to cancel that you may have.
13.1.4. You can cancel a Plan within 14 days of starting it. If you do this, then any Freetrade Account(s) or other features that you qualified for because of that Plan will also be cancelled.
13.2. If you want to exercise a right to cancel, you must contact us by emailing hello@freetrade.io.
13.3. You agree that we may provide the Services, the Freetrade Account(s), and the Freetrade Platform to you during the cancellation period.
13.4. If you cancel as set out in section 13.1, we will:
13.4.1. Where you have cancelled a Freetrade GIA, close your Freetrade GIA and return to you (or to your previous investment account provider) the cash and Investments in your Freetrade GIA.
13.4.2. Where you have cancelled a Freetrade ISA, close your Freetrade ISA and will return to you (or take reasonable steps to return to your previous investment account provider) the cash and Investments in your Freetrade ISA.
13.4.3. Where you have cancelled an ISA Transfer into a Freetrade ISA, we will return to you (or take reasonable steps to return to your previous investment account provider) the cash and Investments which were received in that ISA Transfer (as applicable).
13.4.4. Where you have cancelled a Plan, we will return to you any Plan Fee that you have already paid, minus any proportionate charge that we take for what we have provided to you up until cancellation.
13.5. Where you cancel a Freetrade GIA, Freetrade ISA, or an ISA Transfer, you will bear the risk of any investment losses that have occurred since you opened that Freetrade Account or made that ISA Transfer. If you have Treasuries in your Freetrade Account at the time of cancellation, we will return to you the amount you had invested, but you will not benefit from any yield that would have been received if you had held those Treasuries to their maturity date.
13.6. You will not be charged any fee for canceling in accordance with this section 13.
13.7. You also have cooling off rights to cancel your Freetrade SIPP in accordance with the SIPP Terms with Platform One. If you do this, then your agreement with us in respect of your Freetrade SIPP will also be canceled. Any related Plan will not be canceled, unless you also tell us that you want to cancel in respect of that Plan under section 13.1.4.
14.1. You're responsible for taking all reasonable steps to keep your Freetrade Account(s) safe. This includes (but isn't limited to):
14.1.1. Keeping your login details to the Freetrade Platform a secret;
14.1.2. Making sure that you create a PIN that is unique to your Freetrade Account(s) and won't be easily guessed;
14.1.3. Letting us know as soon as possible by emailing us at hello@freetrade.io if you have lost your login details or you suspect that they've been compromised;
14.1.4. Keeping the Freetrade App up-to-date on your device by installing updates that we publish from time to time;
14.1.5. Never leaving your device unattended while logged into the Freetrade Platform; and
14.1.6. Only accessing your Freetrade Account(s) on a secure internet connection.
14.2. If your Freetrade Account(s) or your profile is accessed by another person using your login details and you haven't alerted us to the possibility that your login details have been compromised, we'll assume that we're dealing with you. This means that we'll be entitled to treat any instruction we receive in relation to your Freetrade Account(s) or your profile as a valid instruction that you've given us.
Your use of the Freetrade Platform
15.1. The Freetrade Platform provides you with access to your Freetrade Account(s) and our Services. Although you may be able to view your Freetrade Account(s) on our Freetrade Website, it does not offer all of the features of the Freetrade App.
15.2. When you use the Freetrade App, you agree to comply with the terms of the app store from which you download the Freetrade App and any applicable third party in addition to the agreement between you and us.
15.3. When you open a Freetrade Account and use our Services on the Freetrade Platform, we provide you the right to use the Freetrade Platform on a device that you own and control. This right is not transferable to any other person.
15.4. You should only use the Freetrade Platform to access your Freetrade Account(s) and use our Services. In particular, you must not:
15.4.1. Use the Freetrade Platform for anything that is illegal or inconsistent with our agreement with you;
15.4.2. Seek to copy, alter, reproduce or tamper with the Freetrade Platform or any of its contents in any way;
15.4.3. Attempt to gain unauthorized access to the Freetrade Platform, or any server, computer or database connected to it;
15.4.4. Use the Freetrade Platform on a device which contains or is vulnerable to viruses or any other damaging properties;
15.4.5. Use the Freetrade Platform in a way that could damage or affect the function and availability of our systems and security; and
15.4.6. Engage in any data mining, data extracting or other similar activity in relation to the Freetrade Platform or whilst using the Freetrade Platform.
15.4.7. You should not access the Freetrade Platform on a shared device or a device which is accessible to the public; and
15.4.8. Freetrade is not responsible for the content or information contained on other websites which can be accessed via third party links on the Freetrade Platform or in the event these sites are not available at all times on the Freetrade Platform. The privacy policies of any sites accessible via a link on the Freetrade Platform may differ from our own privacy policy.
Availability of our Services and the Freetrade App
15.5. We'll update the Freetrade App from time to time. You're responsible for ensuring that you have the latest version of the Freetrade App downloaded onto your device. We can't guarantee that all features of the Freetrade App will be available, or work as expected, if you're using an older version of the Freetrade App and we may be unable to support you if you have any problems.
15.6. You are responsible for ensuring that your device is capable of supporting and has an operating system which is compatible with the latest version of the Freetrade App. The operating systems that we currently support and our approach to withdrawing support for old operating systems is set out on our website.
15.7. The Freetrade Platform has been designed to be used in the UK, and may not be available or work as expected in other countries.
15.8. We'll use all reasonable care and skill to make the Freetrade Platform and its contents available to you 24/7. However, we can't guarantee that it will always be uninterrupted, accurate or error-free, secure, or free of viruses or other damaging property.
15.9. We may, where it is reasonable or necessary for us to do so, suspend the Freetrade Platform and/or the Services to perform routine or emergency maintenance or to upgrade or replace our systems. We will take reasonable steps to minimize the disruption to the Freetrade Platform and the Services and to give you advance notice of any planned suspension.
16.1. Our Dealing Service is an execution-only service. This means that when you give us instructions to buy or sell Investments, you'll be responsible for your own investment decisions and actions, including for any investment strategies you adopt and for monitoring the performance of your Investments.
16.2. We might give you general factual information about the Investment Services, Freetrade Account(s), and the Investments that may be available on our platform. We also determine the scope of Investments that we make available on our Platform. However, we won't ever provide you with financial advice or personal recommendations. If you think you might need some advice before making a particular investment decision, you should obtain independent professional financial advice.
16.3. We're not required to assess whether our Investment Services or the Investments that we make available are suitable for you. This means that you won't benefit from the protection of the FCA rules on assessing suitability.
Non-complex products
16.4. The majority of the Investments available on our platform are categorized as “non-complex products”, such as shares or units in simple exchange-traded funds. When you invest in these Investments, we won't be required to assess whether these Investments or our Investment Services in relation to them are appropriate for you. This means that you won't benefit from the protection of the FCA rules on assessing appropriateness.
Complex products
16.5. Depending on your Plan, you may be able to use our platform to invest in Investments which are not categorized by the FCA as “non-complex products”. We call these ‘complex products”. Before you can invest in a complex product, we're required to assess whether the product is appropriate for you under the FCA's rules. We'll do this by obtaining and assessing information from you about your investment knowledge, experience in trading such products and your understanding of the risks involved. This is called an “appropriateness assessment”. If you fail our appropriateness assessment or you don't provide us with the information we need, we won't allow you to deal in “complex products”.
Scope of Investments
16.6. We may change the Investments that we make available through our Dealing Service and/or Custody Service, or which are available in a particular Plan. The scope of Investments available to you may depend on which Plan you have. Some Investments are not available within a Freetrade SIPP or a Freetrade ISA. An up-to-date list of all the Investments we offer can be accessed here.
How we deal for you
16.7. When we provide the Dealing Service we may act in one or more of the following ways:
16.7.1. we usually act as your agent. This means that Freetrade, as your broker, will instruct a deal to be entered into between you and a third party that is the 'counterparty' to your deal;
16.7.2. we may sometimes act as the counterparty to the deal with you; and/or
16.7.3. we may arrange for your deal to be executed by another broker. This broker may be an affiliate of Freetrade or a non-affiliated third party.
How a deal works
16.8. There are three key stages to a deal:
16.8.1. Placing an order: where you give us instructions to buy or sell Investments for you;
16.8.2. Executing an order: where we enter into a binding contract on your behalf (a “deal”) in order to carry out your order; and
16.8.3. Settlement: if you are buying investments, where we take delivery of the Investments and pay the price; if you are selling investments, where we deliver the Investments and receive the proceeds in cash on your behalf; or, if a Treasury is maturing, we receive the proceeds in cash on your behalf.
Depending on the type and circumstances of your order, the type of Investment, and how execution and settlement occur, there is usually a time gap between placing an order and execution and/or between execution and settlement.
US Investments
16.9. If you hold Investments that are subject to US tax, you will need to provide us with a valid W-8BEN form. You agree to do this as soon as we ask you to and to keep it valid and up-to-date at all times.
Market data and price
17.1. We use the stock screen of the Freetrade Platform to display market data related to shares and funds, including their price. We don’t set the price of these Investments; it is determined by the market. This market data is updated based on the latest information we have received from various third party providers. You’ll be able to see the time the market data was last updated.
17.2 We will show a yield on the Freetrade Platform in respect of Treasuries when you place your order. This yield reflects the yield that was achieved by us in the latest tender of Treasuries of that type where our bid was partially or fully filled. You will not know the actual yield that you will receive in respect of Treasuries until the deal has been executed.
17.3. The price of Investments that you see as you place your order is indicative only. The price at the moment that we execute your order is the one that will apply to your deal. That price may be different from the price you saw as you placed your deal. You will bear the risk of any such price change.
17.4. The market data is confidential and is made available to you on the basis that you won't use it for any purpose other than in connection with our Services. In particular, you should not:
17.4.1. use any of the market data for commercial purposes; or
17.4.2. publish or make the market data available to another person (whether or not they also use our Services).
Placing an order
17.5. When you instruct us to buy or sell Investments, you will 'place an order'. We can accept different types of orders; each of these has a different impact on the time and price at which the order is executed. The types of orders available to you on the Freetrade Platform may change from time to time at our discretion, and will depend on your Plan.
17.6. Before you place an order, you'll be shown a summary of that order. It's your responsibility to check that your instructions are accurate and that you accept the applicable fees and charges.
17.7. We may, at our sole discretion, place limits on (i) the minimum and/or maximum order amount and (ii) minimum/or maximum order size that we accept. These limits may change from time to time and will be indicated on our Freetrade Platform.
17.8. We may allow you to buy and sell Fractionals. If you place an order for Fractionals:
17.8.1. Buy orders: your order will be expressed in terms of the cash value you want to invest; and
17.8.2. Sell orders: your order will be expressed in terms of the number of shares you want to sell.
17.9. We will make certain information available to you on the Freetrade Platform before you place an order. This will include costs and charges information and any Key Investor Information Document or Key Investor Document that applies to the relevant Investment.
Executing your order
17.10. Once you have placed an order and we have accepted it, we will ‘execute’ your order. We do this by causing you to enter into a contract or ‘deal’ to buy or sell the Investments. We’ll normally accept your order by executing it and we won’t always give you any other indication that your order has been accepted by us. We’ll always act on the basis that any order we receive from you is deliberate and we'll execute it without first checking it with you.
17.11. We're required by Applicable Requirements to take all sufficient steps to obtain the best possible result for you when executing your orders. This is called our "best execution obligation". Our Order Execution Policy sets out the arrangements and procedures we have in place to meet our best execution obligation as well as details of the types of orders we may accept and where your orders may be executed. Our Order Execution Policy may be updated from time to time, and can always be accessed on our website here. If we agree to execute an order for you in accordance with your specific instructions, it may not be possible for us to obtain the best result that would otherwise be available to you.
17.12. We'll execute your orders during normal trading hours, which will depend on the market on which the relevant Investment is bought and sold. You may be able to place orders outside of normal trading hours (for example, during the weekend or when the market is suspended due to market conditions or any other event), however, there's a risk of increased price volatility at these times.
17.13. Where we reasonably consider it to be in your best interests, you agree that your orders may be executed outside a UK or EU regulated market, multilateral trading facility or organized trading facility, as described in our Order Execution Policy.
17.14. When we execute an order for you, we may combine it with orders for other customers. This is called "order aggregation". We will do this where, at the time we execute the order, we reasonably believe that the aggregation is unlikely to work overall to your disadvantage. However, the result of the aggregation may actually be to your disadvantage in relation to a particular order compared to if we had bought or sold your Investments separately.
When you can modify or cancel your order
17.15. You may be able to request to modify or cancel an order you've placed if it hasn't yet been executed. However, we can't guarantee that we'll be able to carry out your request, as this will depend on the type of order you've placed. There will be a cut-off in respect of Treasuries after which you will not be able to modify or cancel your order. This cut-off is made clear in the Freetrade Platform at the time that you place your order.
When we can decline, cancel or reverse an order
17.16. We may, where it is reasonable for us to do so, (i) decline an order that you've placed with us, (ii) cancel an order after you’ve placed it, or (iii) void or modify a deal after it's been executed. Below are some of the situations where we may do this:
17.16.1. where you have breached your obligations under this agreement;
17.16.2. if you don't have sufficient cash or Investments in your relevant Freetrade Account to satisfy the order you have placed and any fees, charges or other amounts that apply;
17.16.3. where we reasonably believe that the security of your Freetrade Account(s) is compromised;
17.16.4. if the market data (including the price) displayed on our stock screen is or was manifestly different from the actual market price of the security;
17.16.5. if there's a suspension or closure of the relevant market and/or the relevant Investment is no longer supported on the Freetrade platform for any reason;
17.16.6. where your order is inconsistent with any trading limits or restrictions that we have made clear apply to that order, or where your order is to sell Treasuries;
17.16.7. where we reasonably believe that you are engaging in excessive trading and/or that your order may be disruptive to other investors in the relevant market;
17.16.8. if we’re unable to execute or settle the deal due to reasons outside our reasonable control; and/or
17.16.9. if there is a change in Applicable Requirements, such that the execution of the order would no longer be permitted or compliant.
17.17. We’ll let you know as soon as reasonably practicable if we carry out any of the actions set out at section 17.16 and provide you with our reasons, unless we’re prevented from doing so by Applicable Requirements.
How your order will appear on the Freetrade Platform before it settles
17.18. When your order is executed but before it settles, we may (but we are under no obligation to):
17.18.1. if your order is to sell Investments, (1) Reserve the relevant Investments in your Freetrade Account so that they are no longer Withdrawable or Available and (2) show the cash proceeds (less applicable fees, charges, and taxes) that we expect to receive on settlement. This cash will be Unsettled (and may, if we agree, be Available), but not Withdrawable; or
17.18.2. if your order is to buy Investments, (1) Reserve the cash price (plus applicable fees, charges, and taxes) in your Freetrade Account so that it is no longer Withdrawable or Available and (2) show the Investments we expect to receive on settlement. These Investments will be Unsettled (and, unless they are Treasuries, may, if we agree, be Available), but not Withdrawable; or
17.18.3. If a Treasury is due to mature within two business days, show the cash proceeds (less applicable fees, charges, and taxes) that we expect to receive on settlement. This cash will be Unsettled (and may, if we agree, be Available), but not Withdrawable.
To the extent that we do this before settlement, the amounts shown in the Freetrade Platform reflect whether you can deal with and/or withdraw your cash and Investments. We don’t actually move any cash or Investments into or out of your Freetrade Account until settlement actually occurs.
Settlement
17.19. We will take reasonable steps to ensure that your deal settles (be completed with and by the counterparty), but whether it does so is dependent on the market infrastructure and the counterparty.
17.20. When a deal settles, we will:
17.20.1. if your order is to sell Investments, (1) take that number of Investments from your Freetrade Account and deliver them to the counterparty, and (2) take receipt of the cash proceeds from the counterparty (less applicable fees, charges, and taxes) into your Freetrade Account. This cash will then be Available and Withdrawable (unless it has been Reserved for a new order); or
17.20.2. if your order is to buy Investments, (1) take the cash price (plus applicable fees, charges, and taxes) from your Freetrade Account and pay it to the counterparty, and (2) take delivery of the relevant Investments into your Freetrade Account. These Investments will then be Available and Withdrawable (unless they have been Reserved for a new order or they are Treasuries); or
17.20.3 if a Treasury is due to mature within two business days, take receipt of the cash proceeds from the counterparty (less applicable fees, charges, and taxes) into your Freetrade Account. This cash will then be Available and Withdrawable (unless it has been Reserved for a new order).
17.21. If your deal fails to settle, we can reverse what we’ve shown in the Freetrade Platform under section 17.18 above. If you have used cash or Investments that were Unsettled to carry out a subsequent deal(s) those subsequent deal(s) may also fail to settle.
Confirmation of your deal
17.22. Within a reasonable time after your order is executed, you'll be able to access a confirmation of your order on the Freetrade Platform, setting out a summary of the deal, including the price and/or yield that applies to that deal.
18.1. We may make available to you Investments that are priced in a currency other than pounds sterling. We refer to these as “ForEx Securities”.
18.2. If we deal for you in ForEx Securities, we will make a foreign exchange (“ForEx”) transaction with you in order to:
18.2.1. where your deal is to sell ForEx Securities, change the sale proceeds received from the counterparty into pounds sterling; or
18.2.2. where your deal is to buy ForEx Securities, change your cash from pounds sterling in order to pay the price to the counterparty.
18.3. Your order summary will show the estimated exchange rate that will apply to the ForEx transaction that we will make for you, and our fee for that transaction (our “FX Fee”) as set out here. The ForEx rate that we show you will be the most recent best available rate that our panel of foreign exchange providers has quoted to us.
18.4. The ForEx rate in the order summary is indicative only, as the actual rate may vary depending on movements in the foreign exchange markets between when you place your order and when your order is executed. Therefore, the actual price or proceeds in respect of the ForEx Securities may be lower or higher than the estimated price or proceeds presented to you in the summary of your order instruction. The actual ForEx rate that applies and the amount of our FX Fee will be set out in the confirmation of your deal.
Your cash is kept separate from our cash
19.1. We'll treat any cash that is held in your Freetrade Account(s) as 'client money', in accordance with Applicable Requirements. This means that we'll ensure your cash is held separately from our own cash.
19.2. We'll arrange for your client money to be held in one or more bank accounts or qualifying money market funds, each with a third party financial institution that we select in accordance with Applicable Requirements.
How we seek to protect your cash
19.3. We'll always exercise due skill, care and diligence when we select any approved financial institution that holds your client money, and we'll regularly review this selection. We won't be responsible for any acts, omissions or default of any approved financial institution, except to the extent that we have failed to exercise due skill, care and diligence in our selection and review of them. If you have a Freetrade ISA, then section 6.2 of the ISA Terms will also apply.
19.4. If an approved financial institution holding your client money fails (for example, by becoming insolvent), we'll try to recover your client money by any means reasonably available to us. While this happens you may not be able to use the relevant amount of cash.
19.5. We have controls in place to ensure that your client money is not used to settle deals for another customer. Regardless of the controls and measures in place, there can be instances when we are not holding the correct amount of client money for our customers (a “shortfall”). This can be just during the working day or sometimes for a longer period. Where we identify a discrepancy that results from or reveals a shortfall, or during an investigation where we deem it appropriate to do so, we will allocate an amount of our own cash to cover the shortfall, which we will hold as client money.
Your cash will be pooled with that of our other customers
19.6. Your client money will be mixed (pooled) with client money belonging to our other customers and held in the same bank account(s) or money market fund. This means that:
19.7. it is not possible to separately identify your client money from that of our other customers, except by using our internal books and records;
19.8. if we were to fail (for example, by becoming insolvent) there's a risk of delay in returning your client money to you as we'll need to identify which client money is yours and which belongs to our other customers; and
19.9. if the combined amount of client money that we hold is not enough to satisfy your claim and those of our other customers, you would be required to share proportionately with our other customers in any shortfall, meaning that there's a risk you may not get all your client money back.
Your cash may be held outside the UK or in a foreign currency
19.10. Your client money may be held outside the UK if:
19.10.1. the approved financial institution is established or operates a client money bank account in a different country; or
19.10.2. if we effect a deal, or income is paid on Investments outside the UK, which means that your client money has to pass through a third party such as an exchange, clearing house or intermediate broker located outside the UK.
If this is the case, the laws, regulations, and rules that apply to your client money will be different from that of the UK and if the approved financial institution fails, your client money may not be treated in the same way as if it would have been had it been held in the UK.
19.11. The amount of client money that we record as being held for you will always be expressed in pounds sterling. However, some of the client money that we hold may be in other currencies, to enable us to carry out transactions for customers in those other currencies. We will always take reasonable care to ensure that the client money that we hold in all currencies is at least equivalent to the total pound sterling amount recorded as being held for our customers.
Other third parties that may hold your client money
19.12. You authorize us to allow another person, such as an exchange, clearing house, or intermediate broker, to hold or control your client money for the purposes of deals that we make for you through or with that other person.
19.13. We can make a transfer of your client money to a third party in the circumstances set out in section 30.2 (Delegation, assignment, or transfer).
Money that we hold in a fixed term account
19.14. We may place your client money in a notice or fixed term deposit account that only permits a withdrawal on the provision of notice or at the end of a term of up to 95 days. This won't affect your ability to use or take your client money as you normally would under this agreement. However, if Freetrade or the approved financial institution holding your client money fails, any of your client money held in a notice or fixed term deposit account may not immediately be available to you for withdrawal.
Interest on your client money
19.15. We may receive interest on the client money that we hold for you. We may pay you interest on some or all of your client money as we notify you from time to time. If we receive more interest on your client money than the amount that we pay to you, we will keep the difference. We do not pay interest on client money which is not Withdrawable in your Freetrade Account(s) at the relevant time. We may make changes to whether and how much interest you may receive. If you or we give notice to close your Freetrade Account, you will cease to be entitled to unpaid interest in respect of that Freetrade Account, as described at section 32.1.2.
19.16. The amount of interest that we pay to you may be capped at a maximum amount.
19.17. Any interest that we may pay you above will be credited to your Freetrade Account(s) each calendar month.
19.18. If you don't wish to earn any interest on your client money, you can opt out by emailing us at hello@freetrade.io.
Our right to deduct amounts due to us
19.19. We can deduct amounts from your client money to recover amounts that are due from you in accordance with section 29 (Our right to deduct amounts from your Freetrade Account(s).
What happens to your cash if you do not use your Freetrade Account(s)
19.20. Where permitted by the Applicable Requirements, if there has been no movement in the balance of the client money in your Freetrade Account (except for payments or receipts of interest, charges, or similar items) for a period of at least six years and we have taken reasonable steps to contact you but cannot do so, we may stop treating this as client money and may pay it to a charity of our choice. Where we do this, we will unconditionally undertake to pay you a sum equal to that paid to charity if you later contact us to claim these amounts.
Your Investments are kept separate from our assets
20.1. We act as the custodian of the Investments in your Freetrade Account(s), which means that we keep them in safe custody for you and treat them as 'client assets', in accordance with Applicable Requirements.
20.2. Your Investments will be kept separate from our own assets and title to your Investments will be registered in the name of either:
20.2.1. a nominee company which will have legal title to the Investments while you retain beneficial ownership; or
20.2.2. a sub-custodian located outside the UK. We’ll only do this where the relevant Investments are subject to the law or market practice of a jurisdiction outside the UK and where we have taken reasonable steps to determine that it is in your best interests to do so, or that it is not feasible to do otherwise, because of the nature of the applicable law or market practice.
20.3. If your Investments are registered in the name of a sub-custodian located in a jurisdiction outside of the UK:
20.3.1. different settlement, legal and regulatory requirements may apply from those in the UK; and
20.3.2. there may be different practices for the separate identification of your Investments. This means that the protection of your Investments may be different depending on the jurisdiction in which the sub-custodian operates.
How we seek to protect your Investments
20.4. We'll always exercise due skill, care and diligence when we select any sub-custodian that holds your client assets, and we'll regularly review this selection. We accept responsibility for the acts or omissions of Freetrade Nominees Limited or any sub-custodian which is a group company as if those acts or omissions were our own. We won't be responsible for any acts, omissions or default of any sub-custodian that is not a group company, except to the extent that we have failed to exercise due skill, care and diligence in our selection and review of that sub-custodian. If you have a Freetrade ISA, then section 6.2 of the ISA Terms will also apply.
20.5. If the sub-custodian holding your client assets fails (for example, by becoming insolvent), we'll try to recover your client assets by any means reasonably available to us. While this happens, you may not be able to deal in the affected Investments.
20.6. We have controls in place to ensure that your Investments are not used to settle deals for another customer. Regardless of the controls in place there can be instances where we are not holding the correct number of Investments for our customers (a “shortfall”). This can be just during the working day or sometimes for a longer period. Where we identify a discrepancy that results from or reveals a shortfall, or during an investigation where we deem it appropriate to do so, we will allocate an amount of our own cash to cover the shortfall, which we will hold as client money in accordance with section 19.
Your Investments will be pooled with those of our other customers
20.7. Your Investments will be mixed (pooled) with Investments belonging to our other customers in accordance with the FCA rules. This means that:
20.7.1. it is not possible to separately identify your Investments from those of other customers, except through our internal books and records;
20.7.2. when we receive Investments or cash on behalf of more than one customer in connection with pooled holdings (for instance in a bonus or rights issue or takeover) we will allocate them between customers on a proportionate basis, in accordance with Applicable Requirements;
20.7.3. if a share issue or other corporate event favors small investors your actual allocation may be less than it would be if your Investments were registered in your own name;
20.7.4. sometimes amounts or investments may arise which would not have arisen if the Investments had been registered in your own name. You may not be entitled to any such additional amounts or investments; and
20.7.5. if we were to fail (for example, by becoming insolvent) there's a risk of delay in returning your Investments to you as we'll need to identify which Investments are yours and which belong to our other customers; and
20.7.6. if the combined amount of Investments that we hold is not enough to satisfy your claim and those of our other customers, you would be required to share proportionately with our other customers in any shortfall, meaning that there's a risk you may not get all your Investments back.
How Fractionals are held for you
20.8. To the extent that you hold Fractionals in your Freetrade Account(s), your entitlement will be reflected in our records as described at section 20.7. The Fractional element of your Investments cannot be sold or transferred without it being combined with other Fractionals in the pooled account to make a whole share. This means that in the event of our insolvency you would not be able to have that Fractional element returned to you and it would have to be sold in order to realize its cash value. This could impact on the extent to which, or the speed with which, you would be able to recover your entitlement to Fractionals. In all other respects, the way that Fractionals are held for you is the same as for whole Investments.
What happens to your Investments if you do not use your Freetrade Account(s)
20.9. Where permitted by the Applicable Requirements, if there has been no movement in the balance of the Investments in your Freetrade Account for a period of at least twelve years and we have taken reasonable steps to contact you but cannot do so, we may stop treating these Investments as client assets and may transfer them to or sell them and pay the proceeds to a charity of our choice. Where we do this, we will unconditionally undertake to pay you a sum equal to the value of the Investments at the time they were sold or transferred if you later contact us to claim these amounts.
21.1. We and our sub-custodians may be notified of and/or be invited to vote, approve and/or take other actions in relation to Investments in your Freetrade Account and the company that has issued them. These are referred to as "corporate actions". Examples of corporate actions include takeover offers, mergers, share consolidations, capital reorganizations, dividend distributions, and de-listings.
21.2. Subject to the rights set out in the ISA Terms (if applicable) and section 21.3, you agree that:
21.2.1. Freetrade and its sub-custodians have no duty to inform you of any corporate actions related to the Investments in your Freetrade Account(s);
21.2.2. you waive your right to exercise any corporate actions in relation to your Investments; and
21.2.3. you agree that we or the legal holder of your Investments may exercise (or not exercise) any corporate actions at its discretion. That discretion will not take into account your individual wishes or circumstances, and whether and how those rights are exercised may not result in your preferred outcome.
21.3. In relation to securities issued in the US, we will provide you with the ability to participate in general meetings via a proxy voting service. This will enable you to vote on corporate governance decisions where the issuer of the securities needs to seek shareholder consent. These are called “mandatory corporate actions” and include things like voting at general meetings, board elections, mergers and acquisitions, and changes to company bylaws. We will share your personal data with third parties to the extent necessary to provide you with this service, in accordance with our Privacy Policy.
21.4. If you become entitled to any proceeds (such as dividends) or non-monetary benefits (such as additional Investments) as a result of any corporate action in relation to the Investments in your Freetrade Account(s), we'll take all reasonable steps to collect such proceeds or benefits and credit your Freetrade Account(s) accordingly.
21.5. Any dividends that you become entitled to may be rounded down to the nearest £0.01 when allocated to you.
21.6. We're under no obligation to initiate or defend any legal action, join any shareholder action, or take any other action whatsoever in connection with our (or our nominee’s or sub-custodian’s) position as shareholder of the Investments in your Freetrade Account(s).
22.1 We'll always try to act in your best interests when providing you our Services, in accordance with Applicable Requirements. However, there may be limited circumstances where your interests may conflict with our interests, or with another customer's interests. To identify, prevent and manage these conflicts, we have in place a number of internal policies and arrangements. These are set out in detail in our Conflicts of Interest Policy, a summary of which is available on our website here.
22.2. We may, from time to time, pay or receive a fee, commission or other benefit from a third party in connection to the Services that we provide to you. We will only do this to the extent it is consistent with our regulatory obligations, including our obligations to act in your best interests and to manage conflicts of interest. We disclose further details of any such payments in our conflicts of interest summary here and/or in your annual statement.
23.1. Information about your deals and the cash and Investments in your Freetrade Account(s) are available on the Freetrade Platform. This information will be updated on a regular basis, and at least no later than 24 hours after any activity takes place.
23.2. At least every 3 months, we will provide you with an electronic statement for each of your Freetrade Account(s), including details of the cash and Investments that we hold for you, and other details as we may decide from time to time in accordance with Applicable Requirements.
23.3. Once a year, we will provide you with an electronic summary of the fees and charges applicable to your Freetrade Account(s) and your use of our Services.
24.1. We may make changes to our agreement with you at any time where:
24.1.1. the change is to respond to a change to Applicable Requirements, to new industry guidance or codes of practice, or decisions or recommendations that we have to follow (such as those from a court, an ombudsman or a regulator);
24.1.2. the change is an increase to our fees and charges to respond to cost increases which are outside our reasonable control and which are associated with providing the Services and/or the Freetrade Accounts and/or the Freetrade Platform;
24.1.3. the change reflects a decision by us to cease operating our business; or
24.1.4. the change is to take account of changes in technology, the systems we use to provide the Services, or the investment and financial systems.
We’ll only make changes for these reasons to the extent that it’s reasonable and proportionate for us to pass the impact of that change on to you.
24.2. We can also make changes to our agreement with you at any time for any other valid reason not specified at section 24.1 above.
24.3. We can also make changes to our agreement with you at any time where the change would not be to your disadvantage. For example, a change to make the agreement easier to understand or to introduce a new optional Service feature.
24.4. Where we make a change to our agreement with you, we will tell you what that change is, the reason for the change and the date on which the change will come into effect. Unless Applicable Requirements prevent us from doing so or where the change is not to your disadvantage, we will give you reasonable prior written notice of any change.
24.5. If you're unhappy with a change we've made or are planning to make, you can terminate the agreement between us and close your Freetrade Account(s) as described at section 31.1. Where the change was not made for one of the reasons in section 24.1 or 24.3, we'll waive any termination charges that would normally apply.
24.6. If you haven’t terminated under section 24.5, the change to the agreement will be binding on you from the date we have told you it will take effect.
25.1. Subject to section 25.2, we will only be liable to you for any loss that occurs directly as result of negligence, wilful default, fraud or breach of this agreement and/or Applicable Requirements by us. In particular, Freetrade will not be liable for:
25.1.1. any losses you may suffer as a result of your deals failing to settle as a result of market conditions, market infrastructure or (where we are not the counterparty to your deal) the counterparty failing to settle;
25.1.2. any losses you may suffer as a result of your deal executing at an unexpected price due to volatility in the market, for example where a limit order is triggered unexpectedly because of a sudden temporary price movement;
25.1.3. any losses you may suffer as a result of a change in the value of the Investments in your Freetrade Account(s);
25.1.4 any losses you may suffer as a result of having to hold an Investment for a fixed period until maturity, where that period was made clear to you at the time you placed your order;
25.1.5. any losses you may suffer as a result of you using or being unable to use the Freetrade Platform and/or our Services due to an interruption in market or communications infrastructure and/or our systems (including maintenance or upgrades we are performing in accordance with section 15.9);
25.1.6. any act or omission by us which is in accordance with our agreement with you;
25.1.7. any act or omission by us which we reasonably believe is necessary for us to comply with Applicable Requirements;
25.1.8. any act or omission by us in relation to a Freetrade SIPP which we reasonably believe is necessary for us to meet our obligations to Platform One as the provider of that Freetrade SIPP;
25.1.9. for any act or omission of a sub-custodian that holds your Investments or an approved financial institution that holds your client money, except as expressly set out in sections 19.3 and 20.4; and
25.1.10. any event or circumstance that is beyond our reasonable control.
25.2. Nothing in this agreement will exclude or limit any duty owed to you under Applicable Requirements or any liability that Applicable Requirements do not allow us to exclude or limit.
26.1. If you breach section 3.1 and/or you seriously or persistently fail to meet your other obligations under this agreement, you'll be responsible for reimbursing us for any losses we have incurred directly as a result of such breach or failure. We may also, where it is reasonable for us to do so, take any of the following actions:
26.1.1. decline, cancel or reverse orders for your Freetrade Account in accordance with section 17.15 (When we can decline, cancel or modify an order);
26.1.2. wholly or partially restrict access to your Freetrade Account(s) and our Services in accordance with section 27 (Restricting your Freetrade Account(s));
26.1.3. refuse to make or accept a payment of cash to or from your Freetrade Account;
26.1.4. refuse to make or accept a transfer of Investments to or from your Freetrade Account;
26.1.5. close one or more of your Freetrade Account(s) and/or terminate our agreement with you in accordance with section 31.3 (Our rights to terminate this agreement and close your Freetrade Account(s)); and/or
26.1.6. change your Plan to a different type.
We will tell you if we do any of these things in relation to your Freetrade Account(s), unless we are prevented from doing so by Applicable Requirements.
26.2. You are responsible for reimbursing us for any costs or liabilities which we incur as a result of complying with our obligations under this agreement or with Applicable Requirements, provided that we act reasonably.
27.1. We may restrict your access to and use of one or more of your Freetrade Account(s), some or all of our Services, and/or the Freetrade Platform if:
27.1.1. We reasonably suspect that this is necessary for security reasons. For example, if we suspect unauthorized or fraudulent use of your Freetrade Account(s);
27.1.2. Your relevant Freetrade Account has had a zero balance for a continuous period of 30 days;
27.1.3. We reasonably believe that it is necessary for us to comply with Applicable Requirements or the direction of a regulator;
27.1.4. It is a reasonable response to a breach by you of this agreement; and/or
27.1.5. We reasonably believe that the restriction is necessary or justified in the circumstances.
If this happens, we'll let you know unless we're prevented from doing so by Applicable Requirements. We’ll lift any restriction once we're confident that the reasons for it are resolved.
28.1. Where it's reasonable for us to do so, we may sell or switch Investments in your Freetrade Account(s) without first obtaining your instructions. Where the Investment is a Treasury, we may do this by buying the Treasury from you before its maturity date. Below are some of the situations where we may do this:
28.1.1. Where the relevant Investment is no longer supported on the Freetrade platform for any reason and (where possible) we have given you a reasonable opportunity to give us instructions to sell or transfer them;
28.1.2. Where the relevant Investment ceases to be listed;
28.1.3. In relation to Investments which are subject to US tax, where you haven't provided us an up-to-date W-8BEN tax form;
28.1.4. To ensure that we or others that we work with to help us provide the Service remain in compliance with Applicable Requirements;
28.1.5. Because, in relation to a Freetrade SIPP, the Investments are not permitted under the Applicable Requirements, the scheme rules applying to the Freetrade SIPP and/or we have been instructed by Platform One to sell or switch them (including where the default option in respect of the Freetrade SIPP has been changed);
28.1.6. In order to close your Freetrade Account(s) where you have failed to give us instructions about what to do with your Investments in accordance with section 32.1, or in order to make a transfer to another investment account provider that you have requested but where you have failed to give us instructions about what to do with your Investments in good time for us to make that transfer; and/or
28.1.7. To recover amounts that are due to us in accordance with section 29 below.
If we do this, we’ll try to give you reasonable notice and explain our reasons and your options. We will let you know as soon as reasonably practicable after the Investments have been sold, unless we’re unable to do so under Applicable Requirements. Subject to our rights under section 29, we’ll credit your Freetrade Account(s) with the cash proceeds from the sale (minus applicable fees, charges and taxes).
29.1. If you fail to pay any amounts that you owe us and we have given you reasonable notice that such amounts are outstanding, we may:
29.1.1. take cash from your Freetrade Account(s) to cover some or all of the amount you owe us;
29.1.2. if there is not enough cash in your Freetrade Account(s) to cover the amount that you owe us, sell some or all of your Investments as described in section 28. We can select what Investments to sell at our discretion, but we’ll take reasonable steps to only sell such value of Investments that is necessary to realise the relevant amount of cash. We will deduct amounts from your Freetrade Account to cover transaction charges, including any FX Fee. We’ll leave any excess sale proceeds in your Freetrade Account; and/or
29.1.3. charge you a reasonable administration fee to cover the cost to us of processing a deduction from your Account under this section 29.1.
29.2. If we decide to make deductions from your Freetrade Account under section 29.1, we’ll email you at least 5 business days before to let you know our plans and to give you a chance to settle up the amounts you owe us.
29.3. We will only deduct an amount from your Freetrade SIPP to the extent the amount you owe us specifically relates to your Freetrade SIPP. For example, if you fail to pay your Plan Fee, we may recover this amount from your Freetrade SIPP to the extent that it covers costs and expenses that we incur in respect of your Freetrade SIPP.
30.1. You can’t assign or transfer any of your rights or obligations under this agreement to any other person without our prior written consent.
30.2. We may delegate some or all of our obligations under this agreement to another person. If we delegate any of our functions as manager of your Freetrade ISA, then section 6.2 of the ISA Terms will apply. We will be responsible to you for the acts and omissions of our delegates as if they were our own, except to the extent that we delegate to a sub-custodian that holds your Investments or an approved financial institution that holds your client money, in which case we will be responsible as described in 19.3 and 20.4.
30.3. We may assign or transfer some or all of our rights and/or obligations under this agreement to another appropriately regulated firm, subject to Applicable Requirements. If this happens, we’ll let you know in advance.
30.4. If we transfer our rights and obligations under this agreement in accordance with section 30.3 above, we may transfer your related client money and/or Investments to the relevant third party, provided that if we are making a transfer of your client money:
30.4.1. the third party is required to return your client money to you as soon as practicable at your request; and
30.4.2. if the amount of your client money is £25 or more, either:
If this happens, we’ll let you know no later than seven days after the transfer has taken effect, with confirmation of how your client money and/or Investments are being held and how you’ll be protected.
Your right to terminate this agreement and close your Freetrade Account(s)
31.1. You can close one or more of your Freetrade Account(s) and/or terminate this agreement with us at any time by giving us 30 days’ notice via the Freetrade Platform or by emailing hello@freetrade.io. You can’t close your Freetrade GIA without also closing any other Freetrade Accounts that you have with us. If you close a Freetrade Account, this won’t automatically change your Plan type. If you want to change your Plan type you will need to do this as explained in section 8. Closing all of your Freetrade Accounts will be a “downgrade” under section 8.
Our rights to terminate this agreement and close your Freetrade Account(s)
31.2. We can close one or more of your Freetrade Account(s) and/or terminate this agreement with you at any time by giving you at least 30 days' notice.
31.3. We may also close one or more of your Freetrade Account(s) and/or terminate this agreement with you immediately and without prior notice to you if:
31.3.1. you seriously and/or persistently fail to meet your obligations under our agreement with you;
31.3.2. you breach section 3 (Your obligations to us);
31.3.3. you fail to pay us any fees, charges, or other liabilities due to us within 30 days, where we've requested such payments;
31.3.4. you no longer meet our eligibility requirements;
31.3.5. you become bankrupt or a procedure is commenced against you seeking or proposing bankruptcy;
31.3.6. your relevant Freetrade Account has had a zero balance for a continuous period of 30 days;
31.3.7. your relevant Freetrade Account has held a balance of less than £100 for a continuous period of 60 days; and/or
31.3.8. we consider that we are reasonably required to do so under Applicable Requirements.
32.1. If you or we give notice to close your Freetrade Account(s) and/or terminate this agreement:
32.1.1. we will process any orders you have placed in relation to those Freetrade Account(s) but which have not yet been executed, subject to our right to reject, cancel or reverse an order that you have placed under section 17.15. We will generally not accept any new orders to buy Investments and we will generally stop processing your standing instructions to buy Investments;
32.1.2. from the date that notice to terminate is given, you will cease to accrue any interest on the cash in your relevant Freetrade Account and you will not be paid any interest which has accrued but is unpaid as at that date;
32.1.3. we will usually ask you to give us instructions in relation to the cash and Investments in your Freetrade Account(s), so that we can send them to you or to a new investment account provider;
32.1.4. if you do not give us instructions under section 32.1.2 above within a reasonable time, or where it is otherwise reasonable for us to do so, we may sell your Investments. Where the Investment is a Treasury, we may do this by buying the Treasury from you before its maturity date. We will pay the proceeds (less any fees, charges and other amounts due to us up to the date that your Freetrade Account(s) is closed) to your Freetrade GIA (if it is not being closed) or to your Linked Bank Account. If we do not have details of a Linked Bank Account, we can pay such amounts due to you to any other account in your name.
32.2. Our agreement with you will remain in place until all of your Freetrade Account(s) are closed.
33.1. If you die or become mentally incapacitated, your personal representative(s) can terminate your Freetrade Account(s), in accordance with section 31.1. To do this, we'll require your personal representative(s) to provide us with documentary proof of their authority, to our reasonable satisfaction.
34.1. All copyrights, trademarks, patents, domain names and other intellectual property rights in connection to our website, Services, the Freetrade Platform, and the information contained within are owned or licensed by Freetrade or by third party content providers.
34.2. Subject to the rest of the agreement between us, we grant you a personal, non-transferable and revocable licence to use our website and the Freetrade Platform for the purposes of using our Services, until such time as your agreement with us is terminated. Nothing in the agreement between us, on our website or the Freetrade Platform, or through the receipt of our Services should be regarded as granting any other licence or right to the intellectual property of Freetrade.
35.1. A person who is not a party to the agreement between us cannot benefit from or enforce any of its terms under the Contracts (Right of Third Parties) Act 1999.
36.1. If any court or relevant authority finds any part of the agreement between us to be invalid or unenforceable, the remaining parts of the agreement between us will remain in full force and effect.
37.1. English law applies to the agreement between us.
37.2. Any dispute which arises in relation to the agreement between us can be heard in any UK courts.
"Applicable Requirements" means any legal or regulatory requirements applicable to this agreement and/or our provision of the Services or the Freetrade Platform, and includes: (1) policies and rules made by the FCA or any other applicable regulatory body (2) decisions of a court, ombudsman or similar body; (3) rules, regulations, policies and procedures of any relevant exchanges or markets; and (4) applicable regulatory, legal or governmental requirements.
“Available” means, in relation to an amount of cash or Investments shown in the Freetrade Platform as being available for you to use to place an order.
“Chat Function” means any chat function that we make available to you in the Freetrade Platform. If you are on a basic or standard Plan, you will have access to an automated chat function. If you are on a Plus plan, you will have access to a live chat function with our customer services team.
"Conflicts of Interest Policy" means our policy which sets out our internal policies and arrangements in place to identify, prevent and manage conflicts between your interests and our interests, or those of another client.
“Custody Service” means the service provided by Freetrade of holding the Investments in your Freetrade Account(s) in safe custody and administering those Investments.
“Dealing Service” means the service provided by Freetrade of providing the facility for you to buy and sell certain types of Investments through the use of the Freetrade Platform.
“Default Option” The FCA requires SIPP Operators to provide a ‘default’ investment option to meet the needs, objectives and characteristics of a typical non-advised SIPP member. The default option is not tailored to the specific needs, objectives, or characteristics of any individual customer and it should not be regarded as advice. There is no obligation to invest in the ‘default’ investment option, which may change in future.
"FCA" means the Financial Conduct Authority.
"FOS" means the Financial Ombudsman Service.
“Fractionals” means an amount of a share which is less than one whole share.
"Freetrade" means Freetrade Limited.
“Freetrade Account” means a Freetrade GIA, Freetrade SIPP and/or Freetrade ISA.
"Freetrade App" means the mobile application provided by Freetrade for you to use the Services.
"Freetrade GIA" means a Freetrade general investment account.
"Freetrade ISA" means a Freetrade stocks and shares ISA provided by Freetrade as the ISA manager.
“Freetrade Platform” means the Freetrade App and/or the Freetrade Website.
“Freetrade Website” means the web application provided by Freetrade for you to use the Services.
"Freetrade SIPP" means a Freetrade self-invested personal pension provided by Platform One.
“ForEx Service” means the Service provided by Freetrade of converting your cash into/from another currency so that you can deal in ForEx Securities.
"ForEx Securities" means Investments that are priced in a currency that is not in pounds sterling.
"FSCS" means the Financial Services Compensation Scheme.
“Platform One” means Platform One Limited, the operator of the Freetrade SIPP and Gaudi Trustees Limited, the trustee of the Freetrade SIPP.
"ISA Terms" means the terms that apply to any Freetrade ISA that you may have, as set out here.
“ISA Transfer” has the meaning given in the ISA Terms.
“Investments” means the investments that we make available via the Freetrade Platform, which may include shares, Treasuries, Fractionals and fund units.
"Investment Risk Disclosures" means the risks associated with our Services and the Investments we make available through our Services.
"Linked Bank Account" means a personal bank account nominated by you and that is held in your name with a UK bank which Freetrade considers to be appropriately authorised.
"Order Execution Policy" means the policy that sets out the arrangements and procedures we have in place to meet our best execution obligations as well as details on the types of orders we offer and where your orders may be executed.
“Plan” means each of our service plans, each of which gives entitlement to different Service features and Freetrade Accounts, as set out here.
“Plan Fee” means the fee payable in respect of a Plan, as set out here.
"Privacy Policy" means the policy which explains how we'll collect, use, store and transfer your personal information as set out here.
“Reserved” means an amount of cash or Investments that are in your Freetrade Account but that we have ringfenced because they are needed to settle a deal for you or pay an amount which is, or will be, due from you.
"Services" means the Dealing Service, the Custody Service, the ForEx Service and our holding of your client money.
"SIPP Default Investment": The FCA requires SIPP Operators to provide a ‘default’ investment option to meet the needs, objectives and characteristics of a typical non-advised SIPP member. The default option is not tailored to the specific needs, objectives, or characteristics of any individual customer and it should not be regarded as advice. There is no obligation to invest in the ‘default’ investment option, which may change in future.
"SIPP Terms" means the terms that apply to any Freetrade SIPP that you may have as set out here.
“SIPP Transfer” means a “Pension Transfer” as defined in the SIPP Terms.
“Sub-account” means a sub-account shown within the Freetrade Platform and which forms part of a Freetrade Account.
"Terms and Conditions" means the terms and conditions set out in this document.
“Treasuries” means debt securities issued by a government.
"TrueLayer" means TrueLayer Limited.
“Unsettled” means an amount of cash or Investments which may show in the Freetrade Platform as being Available, but which has not settled into your Freetrade Account and are therefore not Withdrawable.
"US Person" has the meaning given to it under the US' Foreign Account Tax Compliance Act, which includes (but is not limited to) citizens or residents of the US and any person who meets the 'substantial presence' test. Go to www.IRS.gov for more information.
“Withdrawable” means an amount of cash or Investments in your Freetrade Account that can be taken/transferred from your Freetrade Account in accordance with the agreement.
