A. Welcome to Freetrade
1. About these Terms and Conditions
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.
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.
2. Overview of our Plans, Freetrade Accounts and Services
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. 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.
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. 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. Your obligation to us
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), 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)).
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), 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)).
4. Communication with us
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.
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. Personal data and privacy
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.
5.2. We won't disclose your personal information to anyone, other than as described in our Privacy Policy.
6. Important information
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 Freetrade LTD, Level 2, The Truman Brewery, 91 Brick Lane, London E1 6QL.
6.2. You can contact or find out more about the FCA in the following ways:
● By phone: 0800 111 6768 or, if you are outside the UK, +44 207 066 1000
● Online: www.fca.org.uk
● By post: 12 Endeavour Square, London, E20 1JN.
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:
● send us a message through our Chat Function;
● email us at complaints@freetrade.io; or
● send us a letter at Freetrade Limited, Freetrade, 3rd Floor, WeWork, 145 City Rd, London EC1V 1AZ.
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:
● By phone: 0800 023 4567
● Online: www.financial-ombudsman.org.uk● By post: Financial Ombudsman Service, Exchange Tower, London E14 9R.
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:
● By phone: 020 7741 4100 or 0800 678 1100
● Online: www.fscs.org.uk.
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 Freetrade LTD, Level 2, The Truman Brewery, 91 Brick Lane, London E1 6QL.
6.2. You can contact or find out more about the FCA in the following ways:
● By phone: 0800 111 6768 or, if you are outside the UK, +44 207 066 1000
● Online: www.fca.org.uk
● By post: 12 Endeavour Square, London, E20 1JN.
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:
● send us a message through our Chat Function;
● email us at complaints@freetrade.io; or
● send us a letter at Freetrade Limited, Freetrade, 3rd Floor, WeWork, 145 City Rd, London EC1V 1AZ.
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:
● By phone: 0800 023 4567
● Online: www.financial-ombudsman.org.uk● By post: Financial Ombudsman Service, Exchange Tower, London E14 9R.
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:
● By phone: 020 7741 4100 or 0800 678 1100
● Online: www.fscs.org.uk.