Terms of Service -- Portfolio Manager by PluriFin

Version: 1.1.0 Last update: 2026-08-15 Original language: Italian (binding version for jurisdiction)

1. Parties

These Terms of Service (ToS) govern use of the Portfolio Manager mobile application ("the App") provided by:

Filippo Salemi -- natural person, independent developer
Commercial brand: PluriFin
Country: Italy
Contact email: [email protected]

By installing, launching or using the App ("the User") you fully accept these terms. If you do not accept them, you must uninstall the App and stop using it.

2. Subject of the service

The App is an informational tool for personal management of your investment portfolio. It allows you to:

Import CSV or PDF statements from supported brokers
Manually enter and track positions
Define personal financial goals
View public market data
Request descriptive analyses from third-party AI models (optional)
Compute rebalancing suggestions based on user-defined targets

The App is software, not a financial service, broker, advisor or intermediary. See also legal/disclaimer_financial.md (integral part of the contract).

3. What the App is NOT

To remove any ambiguity:

NOT an investment advisory service within the meaning of art. 1

paragraph 5-septies of Italy's Consolidated Law on Finance (TUF, D.Lgs. 58/1998)

NOT a portfolio management service within art. 1 paragraph 5(d) TUF
NOT an order execution / reception and transmission service under TUF
NOT a MiFID II service (Directive 2014/65/EU)
**DOES NOT execute, propose or suggest any purchase, sale or exchange of

financial instruments**

DOES NOT hold User funds or financial instruments
HAS NO relationship with brokers, banks or intermediaries: the User

imports their own data manually or via self-produced statement files

DOES NOT guarantee any return, performance or economic outcome
NOT subject to CONSOB or Banca d'Italia supervision, as it does not

provide reserved investment services

The App is regulatorily comparable to an enhanced spreadsheet: it tracks, organizes, displays. Decisions remain with the User.

4. Commercial model and pricing

4.1 Free, trial and Premium tiers

PluriFin offers a free tier, a free trial, and four Premium variants (Annual/Lifetime x Single/Family). All Premium variants unlock the same feature set: they differ in the payment model (recurring yearly vs one-time) and in the number of authorized accounts (1 Google account vs up to 6 accounts in a Google Family Group).

| Tier | Cost | Model | Features | |---|---|---|---| | Web demo | Free | n/a | Max 5 manual positions, no CSV/PDF import, weekly market data, goals locked, AI locked | | Android trial (7 days) | Free, no card required upfront | n/a | All Premium features active for 7 days from first launch | | Premium Single Annual | EUR 4.99 / year | Auto-renewing yearly | All features unlocked, single Google account | | Premium Single Lifetime | EUR 29.99 one-time | One-time payment, no renewal | All features unlocked for life, single Google account | | Premium Family Annual | EUR 9.99 / year | Auto-renewing yearly | All features unlocked for Account Holder + up to 5 Family Members in the same Google Family Group | | Premium Family Lifetime | EUR 49.99 one-time | One-time payment, no renewal | All features unlocked for life for Account Holder + up to 5 Family Members in the same Google Family Group |

Prices are set in EUR for the Italian market. For other countries Google Play applies automatic purchasing-power conversion. VAT, where applicable, is included in the final price shown by Google Play at purchase.

4.2 Payment methods

In v1.0 the only payment channel is Google Play Billing, which supports Google Pay, credit/debit cards (all circuits supported by Play in your country), Google Play balance, gift cards.

Payment is fully handled by Google: PluriFin never receives card data, IBAN or payment credentials.

4.3 Premium subscription types

The four Premium variants differ along two independent axes.

Annual (Single Annual, Family Annual): continuous-performance

contract with yearly auto-renewal. Recurring payment is governed by section 4.4 (Auto-renewal) and section 4.7 (Price changes).

Lifetime (Single Lifetime, Family Lifetime): instantaneous contract

with one-time payment. No auto-renewal, no recurring charges. Access to Premium features is granted for life, subject to the service shutdown provisions of section 10.3.

Single (Single Annual, Single Lifetime): unlocks Premium features

for a single Google account.

Family (Family Annual, Family Lifetime): unlocks Premium features

for the Account Holder who makes the purchase and for Family Members in the same Google Family Group, under the conditions of section 4.6.

4.4 Auto-renewal (Annual subscriptions only)

The Single Annual and Family Annual subscriptions auto-renew every 12 months at the then-current price. The User can:

Disable renewal at any time via Google Play

(https://play.google.com/store/account/subscriptions)

Continue using the App until the end of the already-paid year
Re-subscribe later without penalties

No early-cancellation penalties.

The Single Lifetime and Family Lifetime subscriptions involve no auto-renewal and no recurring charges: the payment is one-time and access is for life.

4.5 Right of withdrawal and refunds

4.5.1 Annual subscriptions

For Single Annual and Family Annual subscriptions, refunds follow Google Play Store policy:

Within 48 hours of purchase: automatic refund via Google Play

(Account > Order history > Request refund)

After 48 hours: refund only at Google's discretion. PluriFin can

forward the request but does not control the decision.

The User may disable renewal at any time without penalty (section 4.4).

4.5.2 Lifetime subscriptions and the 14-day right of withdrawal

For Single Lifetime and Family Lifetime subscriptions, as digital content supplied on a non-tangible medium under art. 59(1)(o) of the Italian Consumer Code (D.Lgs. 206/2005):

Purchase is made via Google Play Billing with immediate unlock of

Premium features. By completing the payment, the User expressly consents to immediate performance of the contract and acknowledges the consequent loss of the right of withdrawal under the combined provisions of arts. 52 and 59(1)(o) of the Italian Consumer Code.

Notwithstanding the above, **PluriFin undertakes as a commercial

commitment to honor the 14-day right of withdrawal under art. 52 of the Italian Consumer Code** from purchase, upon written request from the consumer sent to [email protected]. The request must include the Google Play order ID and the Google account used.

For such requests PluriFin will forward the refund case to Google

and, in the event of refusal by Google, will directly grant the consumer an equivalent-value credit via Google Play gift code or, as an alternative, an equivalent bank refund.

After 14 days from purchase, refund requests are subject solely to Google Play's discretion.

4.5.3 PluriFin's position

PluriFin does not issue direct card refunds because it does not directly receive User payments: the technical refund always goes through the Google Play channel. The 14-day guarantee in section 4.5.2 is a supplementary commercial commitment of PluriFin towards the consumer and does not replace or limit the non-waivable consumer rights granted by the Italian Consumer Code.

4.6 Family plan -- roles and responsibilities

The following specific rules apply to Premium Family subscriptions (Annual and Lifetime).

4.6.1 Contracting party

The sole contracting party of the Family Premium agreement is the User who completes the purchase via Google Play (the "Account Holder"), as payer. The Account Holder accepts these Terms in their own name and undertakes to inform their Family Members (as defined below). Family Members benefit from the Premium unlock but are not contracting parties of the subscription contract with PluriFin.

4.6.2 Family Group composition

The Family unlock covers the Account Holder and up to 5 additional Family Members belonging to the same Google Family Group configured by the Account Holder (max 6 users total, per current Google Family limits). Google Family Group composition is managed exclusively through Google's tools (https://families.google.com): PluriFin does not intervene in invitations, acceptances or removals of Family Members.

4.6.3 Individual privacy rights

Each Family Member remains individually the data subject for their own rights under GDPR (Reg. EU 2016/679) and the Italian Personal Data Protection Code (D.Lgs. 196/2003 as amended), in particular regarding the personal data processed by the App on their own device (see Privacy Policy).

4.6.4 Termination of membership effects

A Family Member's Premium access ceases automatically in case of:

Removal of the Family Member from the Google Family Group (by the

Account Holder or by Google)

Termination of the Family subscription by the Account Holder
Natural expiry of the Annual period without renewal
Termination of the contract under section 10

The above terminations are handled automatically by Google Play Billing without PluriFin intervention.

4.6.5 Account Holder responsibility

The Account Holder is civilly liable for the use of the App by their Family Members within the limits set by applicable law and is in particular required to:

Ensure that Family Members are informed of these Terms and of the

Financial Disclaimer

Disable Family access in case of unauthorized use or of termination

of the family relationship

4.7 Price changes

PluriFin reserves the right to modify the price of Annual subscriptions (Single Annual and Family Annual). For increases affecting existing subscribers:

In-app + email notice (if email provided) at least 30 days before

current subscription expires

Right to cancel renewal without penalty

Lifetime subscriptions (Single Lifetime and Family Lifetime) are not subject to price changes after purchase, as the payment is one-time and already definitively executed. Any future new Premium versions will not affect Lifetime subscriptions already purchased.

5. License

PluriFin grants the User a non-exclusive, non-transferable, revocable on breach license, for personal use of the App.

The User may NOT:

Decompile, disassemble or reverse-engineer the software (except as allowed

by Italian Law 633/1941 art. 64-quater)

Remove, alter or hide notices, copyright, trademarks
Resell, sublicense, rent or distribute the App
Use the App for unlawful, fraudulent or third-party-harming purposes
Bypass technical protection measures (e.g. subscription validation)
Use the App to provide professional services to third parties

The User MAY:

Use the App for personal and family finances
Export their data and migrate to other apps
Keep local copies
Uninstall at any time

6. Account and security

The App requires no PluriFin account. Everything is local to the device. The Google Play account associated with subscription purchase is fully managed by Google.

The User is responsible for device security: lock screen, backup, loss. PluriFin cannot recover portfolio data if the device is lost without prior manual export.

7. Limitation of liability

7.1 General

The App is provided "AS IS" and "AS AVAILABLE", without warranties of any kind except those non-excludable by applicable law (in particular Italian Legislative Decree 206/2005 -- Consumer Code for EU consumers).

7.2 Express exclusions

To the maximum extent permitted by applicable law, PluriFin is NOT liable for:

Investment decisions made by the User based on data or analyses shown by

the App

Financial losses of any size, including loss of capital, lost profit, lost

opportunity

Errors, delays, unavailability or inaccuracy of market data provided by

third parties (EODHD, FMP, Google Finance)

Errors, hallucinations, outdated or misleading content in AI model

responses (Gemini)

Parsing errors of broker CSV/PDF statements (formats change without

notice)

Backend (Cloudflare Worker) unavailability and consequent temporary

blocking of subscription validation

Local data loss due to uninstall, device malfunction, missing User backup
Compromise of the User's device (root, jailbreak, malware)

7.3 Quantitative cap

In any case, save for legal exclusions for wilful misconduct or gross negligence (Italian Civil Code art. 1229), PluriFin's total liability to the User, for any cause, is capped at the higher of:

EUR 50.00 (fifty euros)
The amount actually paid by the User for Premium in the 12 months before

the event

7.4 Non-waivable consumer rights

Nothing in these Terms limits or excludes the User-consumer's rights under Italian Consumer Code (D.Lgs. 206/2005), particularly:

Legal warranty of conformity (arts. 128-135-vicies)
Right of withdrawal where applicable (arts. 49+, with the exclusion for

digital content under art. 59.1.o where the User explicitly agreed to immediate execution)

Protection against unfair clauses (arts. 33-37)

8. Third-party services and content

The App optionally integrates with third-party services. The User accepts that:

AI analyses are provided by Google Gemini, subject to

Google Gemini API Terms

Real-time market data is provided by EODHD and/or FMP, subject to their

respective terms

Payment goes through Google Play, subject to

Google Play Policies

Hosting of legal docs and web app is on GitHub Pages, subject to

GitHub Terms

PluriFin does not control these services and is not responsible for malfunctions, modifications, suspensions or terminations decided by them.

9. Changes to the Terms

PluriFin can change these Terms. Material changes will be notified:

In app, via re-consent screen on the first launch after the update
On the marketing site, with a banner for 30 days

If the User does not accept the changes they may uninstall the App and request a refund of the unused subscription via Google Play, per Play policy.

10. Termination

10.1 By the User

The User can terminate at any time by:

Disabling subscription renewal in Google Play
Uninstalling the App

No penalties or formalities required.

10.2 By PluriFin

PluriFin can terminate and revoke the license for:

Material breach of these Terms by the User
Fraudulent use
Attempts to circumvent anti-tamper / anti-piracy protections

Where termination is the User's fault, no proportional refund is provided.

10.3 Service shutdown by PluriFin

PluriFin reserves the right to discontinue development or availability of the App with at least 90 days notice via:

In app
Marketing site
Email to Premium subscribers

In case of shutdown, paid subscriptions are honored to natural expiry, or refunded pro-rata via Google Play.

11. Trademarks and intellectual property

The "PluriFin" trademark belongs to Filippo Salemi (EUIPO filing

postponed to Phase 2 post-revenue)

"Portfolio Manager" is a descriptive product name, not a registered mark
Logos, icons, fonts, illustrations and source code are protected by

Italian Law 633/1941 (copyright)

Third-party trademarks (Google, Android, EODHD, FMP, Cloudflare, GitHub,

etc.) belong to their respective owners and are used only to describe integrations

The User acquires no rights over PluriFin trademarks, logos or code.

12. Personal data protection

Processing of the User's personal data is governed by the Privacy Policy (legal/privacy_policy.md), integral part of these Terms.

13. Financial disclaimer

The Financial Disclaimer (legal/disclaimer_financial.md) is integral part of these Terms and must be read and accepted before using the App.

14. Jurisdiction and applicable law

These Terms are governed by Italian law.

For disputes with consumer Users, the competent forum is the User's residence or elective domicile per art. 66-bis of Italian Consumer Code (D.Lgs. 206/2005), unless a different choice is allowed by law.

For non-consumer Users (professional use), the exclusive forum is Milan (Italy), per arts. 18 and 20 of the Italian Code of Civil Procedure as the forum of the controller domiciled in Italy.

15. Alternative dispute resolution (ADR)

The consumer User may use the EU Commission ODR platform: <https://ec.europa.eu/consumers/odr/>

16. Severability

If any clause is declared invalid or ineffective by a competent authority, remaining clauses stay in force.

17. Communications

PluriFin's communications to the User happen via:

In app (notifications, consent screens, banners)
Email if the User has provided one
Marketing site (public banner)

User communications to PluriFin via email to the appropriate address (see section 12 of the Privacy Policy).

18. Versioning

Updates to this document are identified by the version number at the top. Full history is available in the public repo lunapiena49/portfoliomanager-data, folder legal/.