Terms of Use

Last Updated: 2026.06.19

Welcome to the securities trading and related services provided by PinnoCapital ('PinnoCapital,' the 'Platform,' 'we,' 'us,' or 'our'). Before accessing, registering for, or using the Platform, please carefully read these Terms of Use (the 'Terms'). By registering an account, accessing the website, using the mobile application, or engaging in any transaction through the Platform, you acknowledge that you have read, understood, and agree to be bound by these Terms. If you do not agree to these Terms, you must immediately discontinue use of the Platform and its services.

Article 1. Definitions

1. 'Platform' means the PinnoCapital website, mobile applications, and all related services provided by PinnoCapital. 2. 'User' means any individual or entity that registers for, accesses, or uses the Platform. 3. 'Account' means any trading account or related service account opened by a User through the Platform. 4. 'Securities' means, without limitation, U.S.-listed stocks, exchange-traded funds (ETFs), American Depositary Receipts (ADRs), and other financial products approved for trading on the Platform. 5. 'Trading Instruction' means any order, request, transfer instruction, or other operational instruction submitted by a User through the Platform.

Article 2. Scope of Services

PinnoCapital may provide eligible Users with the following services: 1. U.S. securities trading services; 2. Market data and information services; 3. Account management services; 4. Fund deposit, withdrawal, and settlement services; 5. Other services that may be introduced by the Platform from time to time. The Platform reserves the right to modify, suspend, or discontinue any service at any time to comply with applicable laws, regulations, regulatory requirements, or business needs without prior notice.

Article 3. User Accounts

3.1 User Eligibility

To use the Platform, a User must: 1. Be at least eighteen (18) years of age; 2. Possess full legal capacity to enter into binding agreements; 3. Not be prohibited by any applicable law from engaging in securities transactions; 4. Successfully complete all required Know Your Customer ('KYC') procedures.

3.2 Identity Verification

Users agree to provide true, accurate, complete, and current information, including but not limited to government-issued identification documents, proof of address, tax-related information, bank account information, and any other information required by regulatory authorities. The Platform reserves the right to require Users to update such information at any time.

3.3 Account Security

Users are solely responsible for maintaining the confidentiality and security of their account credentials, passwords, multi-factor authentication devices, and other security measures. Any loss resulting from a User's failure to safeguard account information shall be the sole responsibility of the User. Users must promptly notify the Platform of any unauthorized access, security breach, or suspicious account activity.

Article 4. Risk Disclosure

Securities trading involves substantial risk. By using the Platform, Users acknowledge and understand: 4.1 Market Risk: The value of securities may fluctuate significantly due to market conditions, economic developments, political events, or other factors. 4.2 Liquidity Risk: Certain securities may have limited liquidity, which may prevent timely execution of transactions. 4.3 Technology Risk: Internet services, communication systems, software applications, and third-party service providers may experience interruptions, delays, failures, or technical malfunctions. 4.4 Currency Risk: Users whose base currency is not the U.S. dollar may be exposed to foreign exchange risks when investing in U.S. securities. 4.5 Investment Loss: Users may lose part or all of their invested capital. The Platform does not guarantee any investment return, profit, or performance outcome.

Article 5. User Obligations

Users agree to: 1. Comply with all applicable laws and regulations; 2. Refrain from insider trading; 3. Refrain from market manipulation; 4. Refrain from using the Platform for money laundering activities; 5. Refrain from fraudulent conduct; 6. Respect the lawful rights of third parties; 7. Refrain from unauthorized automated access or abusive use of the Platform. The Platform reserves the right to suspend or terminate any account that violates these obligations.

Article 6. Anti-Money Laundering and Sanctions Compliance

To comply with Anti-Money Laundering ('AML'), Counter-Terrorist Financing ('CTF'), and international sanctions requirements, the Platform reserves the right to: 1. Verify the identity of Users; 2. Monitor account and transaction activity; 3. Report suspicious activities to regulatory or law enforcement authorities; 4. Freeze, restrict, suspend, or terminate accounts suspected of unlawful activity; 5. Refuse service to individuals or entities located in sanctioned jurisdictions. Users agree to cooperate fully with any compliance reviews, investigations, or regulatory inquiries.

Article 7. Trading Services

7.1 Submission of Instructions

Any Trading Instruction submitted and confirmed through the Platform shall be deemed authorized by the User.

7.2 Execution Standards

All transactions shall be executed in accordance with applicable market rules and exchange requirements. The Platform does not guarantee execution of any order, execution at a specified price, or immediate or real-time execution.

7.3 Erroneous Transactions

The Platform reserves the right to cancel, amend, or correct transactions resulting from system failures, manifest pricing errors, regulatory requirements, or other exceptional circumstances.

Article 8. Market Data and Information Disclaimer

Market data, research reports, analyses, and other information provided through the Platform: 1. Are for informational purposes only; 2. Do not constitute investment advice; 3. Do not constitute an offer or solicitation to buy or sell securities; 4. Are not guaranteed to be accurate, complete, or timely. Users are solely responsible for making their own investment decisions.

Article 9. Fees and Charges

Users agree to pay applicable fees as published by the Platform, including but not limited to trading commissions, platform service fees, market data fees, withdrawal fees, and other applicable charges. The Platform reserves the right to modify its fee schedule and will provide notice through its website or mobile application.

Article 10. Intellectual Property

All intellectual property rights relating to the Platform, website, applications, software, content, trademarks, logos, and materials are owned by PinnoCapital or its licensors. Without prior written consent, Users may not copy, modify, distribute, sell, or commercially exploit any Platform content.

Article 11. Privacy Protection

The collection, use, storage, and disclosure of personal information are governed by the Platform's Privacy Policy. By using the Platform, Users consent to the data processing practices described therein.

Article 12. Service Interruptions

The Platform shall not be liable for service interruptions resulting from: 1. System maintenance; 2. Network failures; 3. Third-party service disruptions; 4. Force majeure events; 5. Regulatory requirements or governmental actions. The Platform will use commercially reasonable efforts to restore services as soon as practicable.

Article 13. Limitation of Liability

To the fullest extent permitted by law: 1. The Platform shall not be liable for investment losses; 2. The Platform does not guarantee uninterrupted service availability; 3. The Platform shall not be liable for indirect, incidental, consequential, special, or punitive damages; 4. The Platform's aggregate liability shall not exceed the total service fees paid by the User to the Platform during the twelve (12) months preceding the event giving rise to the claim.

Article 14. Indemnification

Users agree to indemnify, defend, and hold harmless PinnoCapital, its affiliates, officers, directors, employees, agents, and service providers from and against any losses, liabilities, damages, costs, and expenses arising from violations of these Terms, violations of applicable laws or regulations, or infringement of third-party rights.

Article 15. Account Termination

The Platform may suspend or terminate a User's account under any of the following circumstances: 1. Violation of these Terms; 2. Submission of false or misleading information; 3. Suspected unlawful activity; 4. Regulatory or governmental requirements; 5. Business or operational decisions of the Platform. Termination of an account shall not relieve the User of any outstanding obligations.

Article 16. Amendments

The Platform reserves the right to amend these Terms at any time. Amended Terms shall become effective upon publication on the Platform. Continued use of the Platform following publication constitutes acceptance of the revised Terms.

Article 17. Governing Law and Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of the State of Colorado, United States. Any dispute arising out of or relating to these Terms shall first be resolved through good-faith negotiations. If such negotiations fail, either party may submit the dispute to arbitration for final resolution.

Article 18. Contact Information

For questions regarding these Terms, please contact: PinnoCapital Compliance Department Website: www.pinnocapital.com