What a shame you're considering leaving us. We want to thank you for using our app!

‍

What do you need to do?

If you choose to close your Vive account, you can easily arrange this via the Vive App.

In the menu, you will find the option “Close Account”. As soon as we receive your request, we will block your account and send you a confirmation once everything has been dealt with.

Make sure you've withdrawn your funds before you close the account and your accrued pension has been transferred to another provider.

‍

What happens after my account is cancelled?

After closing your Vive account, your data is processed in accordance with the GDPR: Personal data of financial institutions is stored for 5 - 7 years according to the “MiFID2” directive and then completely deleted.

Are you unable to log into your Vive account (anymore)? Haven't you received a confirmation email within 2 weeks? Please send an email to support@viveapp.com with the email address you used to sign up.

‍

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Additional annuity terms

Vive Invest B.V.

‍

The additional terms below apply if you invest for tax purposes (investing in annuities).

1. Terms and conditions for Annuity Investing

1.1 These Terms only apply if you make use of tax-friendly investments. This is often referred to as an annuity. These terms and conditions apply in addition to the asset management conditions. We refer to these additional terms as Annuity Terms.

The Annuity Terms are in accordance with current tax laws and regulations, including the Income Tax Act 2001. Will the tax rules change? Then we will automatically apply these conditions, but only to the extent necessary to comply with the tax rules.

1.2 An Annuity Account with Vive Invest may only be used for pension accrual. The annuity account is a so-called accrual product.

1.3 The Annuity Account is not intended for retirement benefits. For that, you need a benefit product. Before your retirement date, you must choose where to purchase a benefit product. This is possible with another provider. The accrued pension is then used to pay out money at fixed times. This way, you will receive a certain amount each period. How much that is depends on how much you have accrued pension assets.

1.4 Attention! You can decide how much to deposit into your Annuity Account. But if you deposit more than your annual space, this has tax consequences. Read more about the fiscal space and what it is at www.belastingdienst.nl. Vive Invest does not check whether you deposit less or more than your fiscal space. Ask your tax or financial advisor for advice about this.

1.5 You can deduct the amount deposited when you return your tax return, as long as it fits the rules of the Income Tax Act 2001. Ask your tax or financial advisor for advice about this.

2. What is tax investing?

2.1 Tax investing means that you build up wealth before old age. It is not the intention to withdraw money in the meantime. The investments take place via an investment account that is specifically intended for your pension. This is what we call the Annuity Account. This account falls into box 1. More about tax investments can be found on the website of the tax authorities www.belastingdienst.nl.

3. Who can invest for tax purposes?

3.1 Opening an Annuity Account is only possible for an individual who:

(i) is 18 years of age or older;

(ii) Not acting in the course of a profession or business;

(iii) Lives in the Netherlands and pays taxes there; and,

(iv) Only use the account to accrue a pension if you have too little pension.

3.2 The Annuity Account is in the name of one person. That person is the account holder. So yourself. An and/or Annuity Account is therefore not possible.

4. Get tax advice!

4.1 Get tax advice before you invest for tax purposes. We do not give advice about this.

5. When and how do I receive my pension?

5.1 To receive the funds in your Annuity Account, you must choose a benefits product. You can do this with another provider.

5.2 The benefit phase commences no later than 31 December of the fifth calendar year after the year in which you are allowed to retire. Keep this in mind when you take out a benefit product. Vive Invest does not offer a benefit product.

6. Can I withdraw money in the meantime?

6.1 You may withdraw money from your Annuity Account on an interim basis. But that is not wise because you have to pay some kind of penalty to the tax authorities. This is because you will not use the money you withdraw for your pension, and that is exactly what the tax benefits apply to.

6.2 Do you still want to withdraw money? Then send a request to Vive Invest. We will then transfer the withdrawn amount to your counteraccount. You pay with the tax authorities yourself.

7. What happens in the event of death?

7.1 Your heirs must inform us of your death as soon as possible. We also need proof of your death, for example a copy of a death certificate.

7.2 After your death, your heirs may use a survivor's annuity within the statutory decision period. Your heirs can do that with us. This period ends on 31 December of the second calendar year after the year of death. If that does not happen on time, the tax authorities will see this as bought off. Your heirs must then pay with the tax authorities.

7.3 Between the time of death and when the heirs use the money for a Vive survivor's annuity, the following applies:

(i) There is no deposit obligation on the part of your heirs; and,

(ii) The balance in the Annuity Account at the time of death remains managed by Vive Invest until your heirs indicate to Vive Invest that they want something else. Until then, Vive Invest will continue to manage the investments under the terms agreed with you prior to death. Heirs can ask Vive Invest in writing to amend the investment policy.

7.4 Are there any heirs? And does every heir want a benefit account? Then a benefit product must be chosen from another provider. Vive Invest does not do this.

8. Tax issues you need to know

8.1 If you deposit too much, don't use the money on time, or withdraw too early, you may have to pay taxes. You are responsible for how you arrange this for tax purposes. Vive Invest does not provide advice and is not responsible for your tax matters.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

We manage your assets

1. You have asset management with us. This means that you instruct us to invest for you. We do this based on the agreements we make with you, for example to accrue a pension. These agreements are included in your investment plan. So you don't have to enter securities orders yourself. Will your Investments be worth more? Then the profit is yours. Will your Investments become less valuable? Then the investment loss is also yours.

You inform us

2. You have provided us with information about your personal circumstances, including your purpose. We take this into account when we invest for you. Are your personal circumstances changing? Then you should let us know as soon as possible. Aren't you doing that? Then you have to take financial disappointments into account.

Your investment plan

3. You have agreed on an investment plan with us. This explains how and with what risks we invest for you. This plan also includes what we invest for you. We will implement this plan for you. In the Vive App, you can see exactly how we invest and with what results.

Depository

4. You have an Investment Account. This account is where your Investments (and money) are administered to Vive Custody B.V. This B.V. stores and administers your Investments. Exactly how this works and what this means is in the Regulations for Depository Institutions Vive Custody B.V. It is important that your Investments and money are safe if Vive goes bankrupt.

Consent (power of attorney)

5. You authorize us to use your Investment Account to invest for you. Always check your Investment Account and the information we give you. Aren't you doing that? Then we may not be able to help you if, for example, something went wrong.

Important Information

6. All important information about our asset management is contained in this contract and what comes with it. You have received from us and agree to:

a) general terms and conditions for asset management;

b) additional annuity terms;

c) the Investment Plan that you agree with us;

d) the Vive Custody B.V. Depository Regulations

Our fee

7. You pay for our asset management. You can read what these costs are in our price overview on our website.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Repository Regulations

Vive Custody B.V.

1. How does the Vive Invest Depository work?

1.1 Below, we explain how the Vive Custody B.V. Depository (“Depository”) works. This Depository belongs to Vive Invest but is legally separated into a B.V. We do this to secure your Securities and funds if Vive Invest unexpectedly goes bankrupt. That is also required by law.

1.2 The drawing below shows who does what. There is an explanation at the bottom of the drawing

Explanation:

1. You have concluded an asset management agreement with Vive Invest.
2. You have concluded an agreement with Vive Invest and the Depository under which the Depository is the legal owner and you are the economic owner of the financial instruments. The Depository administers and takes custody of the Securities in its own name, but for your account and risk. You obtain a claim in Securities on the Depository.
3. The Depository ensures that Vive Invest complies with the rules of asset separation: in the event of Vive Invest's bankruptcy, the investments do not belong to Vive Invest's estate.
4. The Depositary purchases Securities (on your behalf) directly in certain Funds or issuers.

2. Your appointments with the Depository

2.1 These Rules contain the agreements that apply between you, Vive Invest and the Depository.

2.2 The agreements between you and Vive Invest are set out in the Customer Agreement (and the terms and documents stated therein). These Regulations are part of the Customer Agreement.

2.3 Vive Invest guarantees that the Depository fulfills its obligations to all Customers. For this reason, Vive Invest is a party to these Regulations.

3. What does the Depository do for you?

3.1 Vive Invest uses the Depository to separate your assets from its assets. If Vive Invest goes bankrupt, your Investments and Securities will remain outside Vive Invest's bankruptcy.

3.2 If Vive Invest invests for you, the Depository buys or sells Securities.

3.3 The Depository only does this at the request of Vive Invest. The Depository does not manage your Investments. That's what Vive Invest does. The money that Vive Invest invests for you comes from your Investment Account.

3.4 The Securities are (legally owned) by the Depository. The Securities are in the name of the Depository. For this purpose, the Depository has a securities account with a bank.

The Depository also does this for other Customers. That account of the Depository with the bank therefore contains all the Securities of all Customers of the Depository.

3.5 You get Investments. These are claims against the Depository denominated in financial instruments within the meaning of the Financial Supervision Act. These claims are expressed exclusively in the entirety of the Securities.

3.6 The Depository ensures that all its Securities are equal in value to all Investments.

3.7 Your Investments are administered in the Investment Account that you hold with Vive Invest.

3.8 You cannot ask the Depository to purchase or sell Investments. Only Vive Invest can do that. Vive Invest buys and sells for you as agreed in the Customer Agreement.

3.9 You can request the extradition of Investments or Securities to the Depository or Vive Invest in writing. Vive Invest charges a fee for this.

4. Voting rights

4.1 Issuers hold regular - usually once a year - investors' meetings where they can vote. The Depository is the legal owner of the Securities and, in that capacity, has voting rights. The Depository will not exercise its voting rights in investor meetings. As a Customer, you can ask the Depository to grant a voting proxy via Vive Invest so that you can vote on your Securities yourself. To exercise this voting proxy, please contact Vive Invest at support@viveapp.com.

4.2 The Depository is not required to exercise voting rights in Securities.

5. Dividend

5.1 Does an issuer pay dividend/coupon in cash? Then Vive Invest will instruct the Depository to reinvest this dividend in accordance with your investment mandate. The Investments resulting from this dividend will then be credited to your Investment Account.

5.2 Does an issuer pay dividend/coupon in Securities? Then that dividend will be credited to your Investment Account in the form of Investments.

5.3 Does an issuer of its choice pay dividend/coupon in cash or Securities? Then Vive Invest will instruct the Depository to opt for Securities. The Investments are credited to your Investment Account.

6. Responsibility for investment losses and damage

6.1 The Depository is liable for any damage suffered by you, insofar as that damage is the result of culpable failure to comply with the Depository's obligations to you.

6.2 Vive Invest guarantees to you that the Depository complies with its agreements in these Regulations.

6.3 The Depository and Vive Invest are not responsible for damage caused by an issuer's failure to comply with its agreements with its own investors (including the Depository).

7. When do these Rules end?

7.1 These Rules (your legal relationship with the Depository) terminate at the same time as the Customer Agreement between you and Vive Invest ends. Are you cancelling the Customer Agreement with Vive Invest? Then you will also cancel your appointments with the Depository Institution.

7.2 Not only can you terminate these Rules (your legal relationship with the Depository); it is part of the Customer Agreement.

7.3 If the Customer Agreement ends, the Depository will still carry out all (any) orders given by Vive Invest. These are current orders or orders that are necessary to complete the asset management carried out for you. In addition, the agreements in these Regulations remain valid.

7.4 When the Depository stops, Vive Invest will look for a replacement. The Depositary may have its legal relationship with you taken over by a new company (contract takeover).

You already agree to this replacement and/or contract takeover.

8. Changes and additions to the Regulations

8.1 The Depositary may change or supplement these Regulations in whole or in part at any time. An adjustment will only take effect if you have received an email about it.

8.2 Does a change or addition affect you? Then this adjustment will only take effect 1 month after Vive Invest (on behalf of the Depository) has announced this change. Within this month, you can terminate the Customer Agreement with Vive Invest. How to do this is described in the terms and conditions.

Definitions

In these regulations, we use terms. These terms are expressed with a capital letter.

• Investments: Customer's claims against the Depository, denominated in Securities.
• Depository: The Depository Vive Custody B.V., with its registered office in Amsterdam.
• Investment Account: An Investment Account in the Client's name with Vive Invest where investments are administered.
• Securities: Financial instruments that the Depository holds in its own name but on behalf of the Customer.
• Funds: Investment funds or other institutions in which Vive Invest invests for you.
• Customer: A customer who has opened an Investment Account with Vive Invest and has concluded a Customer Agreement with Vive Invest.
• Vive Invest: Vive Invest is based in Amsterdam.
• Regulations: These Regulations for Depository Institutions Vive Custody B.V.
• Customer Agreement: The agreement under which Vive Invest manages your Securities (Asset Management).

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Introduction to SFDR Documentation

Vive classifies itself as light green according to the Sustainable Finance Disclosure Regulation (SFDR). This is also known as an SFDR Article 8 classification. Light green investment firms are required to provide the information below. Since Vive does not provide model portfolios but must provide information about specific portfolios, the information was provided for three “example” portfolios. It is important to note that this is an example based on estimates and that the extent to which the promoted sustainable characteristics are achieved depends on the specific parameters of a Vive investment portfolio.

Below is the relevant documentation for each “example portfolio”.

‍The Vive return portfolio

The Vive return portfolio is a model portfolio for the Vive annuity investment account when a pension investor's retirement is more than 10 years in the future.

Article 10 (SFDR) Disclosure - The Vive Return Portfolio (link to pdf download)

Article 8 (SFDR) pre-contractual information - The Vive return portfolio (link to pdf download)

‍The Vive completed pension portfolio

The Vive completed pension portfolio is a model portfolio for the Vive annuity investment account when a pension investor's retirement is less than 1 year in the future.

Article 10 (SFDR) Disclosure - De Vive completed pension portfolio (link to pdf download)

Article 8 (SFDR) pre-contractual information - The Vive completed pension portfolio (link to pdf download)

The Vive Balanced Risk Portfolio

The Vive Balanced Risk Portfolio is a model portfolio for the Vive asset management account when an investor provides a balanced risk reference for a specific plan. To be precise, it is about a risk reference of 10% VaR. This is a common asset management portfolio.

Article 10 (SFDR) Disclosure - The Vive Balanced Risk Portfolio (link to pdf download)

Article 8 (SFDR) pre-contractual information - The Vive Balanced Risk Portfolio (link to pdf download)

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Vision

At Vive, investing goes beyond just financial aspects. Vive includes sustainability criteria in its selection policy. In doing so, Vive strives to select investment funds and managers that excel in their category when it comes to sustainability. This involves a two-way approach to sustainability.

1. Sustainability risks (Outside-In): Vive analyses the sustainability risks that can affect the performance of investments, such as environmental problems, social risks and poor corporate governance. In short, these are referred to as ESG factors: Environment (Environment), Social (People and Society) and Governance (Good Governance). We integrate these risks into our investment process to make informed selection decisions that increase the robustness of our portfolios.
2. Sustainability impact (Inside-out): Vive does not have a goal for sustainable investments but promotes social characteristics through its selection policy. Vive does this based on the frameworks of the Sustainable Finance Disclosure Regulation (SFDR), the European legislation that promotes transparency around sustainability.

By managing sustainability risks with ESG integration, we strengthen our risk-reward ratio and support our long-term goals.

Application of sustainable investing

Vive has not formulated specific sustainability goals but promotes social characteristics. Vive selects investment funds based on a selection policy that takes into account sustainable characteristics, with the aim of a balanced risk-return ratio. The sustainability selection criteria are based on the following principles:

1. Exclusion policy: Vive only invests in funds that actively exclude investments based on a structured exclusion policy, if this is possible within the asset class.
2. Best-in-Class Selection: Vive only invests in funds that excel in sustainability through ESG performance within their asset class and mandate and that promote ESG goals or make a positive impact in line with the SFDR criteria. To ensure this, Vive only selects funds with:
   • Minimum MSCI ESG rating BBB
   • Minimum SFDR article 8 classification, with a preference for article 9 funds
3. Voting Rights and Engagement: Vive only invests in funds that actively exercise their voting rights and have a clear engagement strategy to stimulate improvements in sustainability aspects. This is only relevant for equity funds.‍
4. Social features: Vive promotes social features by investing only in investment funds that:
   • less than 0.5% of the portfolio is invested in companies that are directly or indirectly involved with controversial weapons.
   • less than 0.5% of the portfolio is invested in companies that derive at least 5% of their turnover from tobacco production or at least 15% from the combined turnover of tobacco distribution, supply or retail.
   • less than 0.5% of the portfolio is invested in companies that are directly involved in highly ongoing controversies. These controversies may relate to the environment, customers, human rights, labour rights or governance and are determined using the “MSCI ESG Controversies” methodology.
   • less than 0.5% of the portfolio is invested in companies that violate the UN Global Compact (UNGC) principles.

For government bonds, the minimum SFDR classification is not used as standard, because they are usually less measurable as with other asset classes.

With this policy, we ensure that our investments not only meet financial requirements, but also contribute to sustainable and social value, in line with the ongoing development of sustainability standards and regulations.

Overview by criterion

1. Sustainability risks & ESG ratings

Sustainability risks

A sustainability risk is an event or circumstance in the field of: Environment, Social (people and society) or Governance that may have a negative impact on the value of an investment. Examples of such risks include:

Environmental risks: Climate change can reduce the value of investments in CO₂ intensive sectors, because the business model of these companies may not be sustainable in the long run.

Social risks: Poor working conditions or human rights violations can damage a company's reputation, with negative consequences for business results.

Administrative risks: Lack of good governance, such as corruption or insufficient risk management, can lead to operational and financial problems.

ESG ratings

ESG ratings measure how well a company deals with financially relevant sustainability risks and opportunities. These assessments are used to identify industry leaders and laggards based on:

1. Their exposure to ESG risks.
2. Their ability to effectively manage these risks compared to competitors.

Vive uses MSCI's MSCI ESG Ratings to assess funds in terms of sustainability risks. MSCI ESG ratings are designed to quantitatively measure sustainability risks in order to assess a company's resilience to industry-related sustainability risks. The MSCI ESG ratings are categorized as:

1. ‍Leaders: AAA, AA‍
2. average: YES, BBB, BB‍
3. Stragglers: B, CC

These ratings apply to various asset classes, such as stocks, corporate loans, and government bonds. Funds are also rated, based on the rating of the underlying companies in which they invest.

What does Vive do in terms of sustainability risks and ESG ratings?

At Vive, we actively integrate MSCI ESG ratings into our investment policy to reduce sustainability risks. Our Best-in-Class approach focuses on selecting funds that perform better in their sector on sustainability risk criteria than their comparable competitors. We use ESG ratings as an important measure in our selection process. These ratings help us identify funds that meet the standards of our sustainability risk policy. Vive only selects funds with a minimum ESG rating (BBB), striving for the highest scores in each segment. The funds that Vive invests in score as follows based on MSCI ESG ratings.

2. Negative Impact Mitigation (PAI)

Principal Adverse Impact (PAI) criteria

One way to invest sustainably is to exclude investments that have a negative impact on people and the environment. To identify the negative consequences of investments, the Principle Adverse Impact (PAI) indicators have been drawn up. This set of 64 measurable indicators evaluates the possible negative effects of an investment.

For investment products that indicate that they take into account the adverse effects of investment decisions on sustainability factors, it is mandatory to report on at least 18 of these 64 PAI indicators. Of these 18, 14 are core indicators that must be measured for all relevant investment products; in addition, 4 additional indicators of your choice may be included. The 14 mandatory indicators are:

• Greenhouse gas emissions
• Carbon footprint
• Greenhouse gas intensity of companies in which investments have been made
• Exposure to companies active in the fossil fuel sector
• Non-renewable energy consumption and generation
• Energy consumption intensity by sector with major climate effects
• Negative consequences for biodiversity-sensitive areas
• Emissions into water
• Hazardous and radioactive waste ratio
• Violations of the UNGC and OECD guidelines
• Absence of procedures and compliance mechanisms for monitoring compliance with UNGC and OECD guidelines
• Unadjusted gender pay gap
• Gender Diversity Board of Directors
• Controversial weapons

What does Vive do in terms of negative impact and PAI?

Vive does not take into account any adverse effects of its investment decisions on sustainability factors.

This is because Vive currently only invests in unlisted investment funds. In Vive's current position, it is not yet possible to intervene directly or take targeted measures at the level of the underlying investments in these funds. For this reason, we cannot effectively limit specific negative effects in the field of sustainability.

What Vive does do is only select funds with a structured exclusion policy. Vive has not drawn up any specific exclusions that the underlying funds must use.

What do the underlying funds do in terms of negative impact and PAI?

The underlying funds that Vive invests in report on the specific negative effects (PAI indicators) that they mitigate through their own exclusion policy. Below is an overview of the negative effects that limit the funds in each Vive asset class.

3. Positive social and environmental contribution (SFDR)

Sustainable Finance Disclosure Regulation (SFDR) classifications

The SFDR provides a European framework for classifying investments based on their sustainability performance. Only investments that meet the SFDR requirements for “sustainable investments” may be labeled as such. These regulations require financial institutions to report transparently on how sustainability is integrated into their investment choices and enable investors to be better informed about the sustainability of investment products. SFDR divides products into three categories based on the extent to which sustainability plays a role:

• Article 6: Investment products that do not actively integrate sustainability and usually do not provide specific information about how to address sustainability risks within the investment strategy. These products are often referred to as “grey investments.”
• Article 8: Investment products that take into account the impact of investments on ESG criteria, without sustainability being the primary focus. These funds can pursue sustainable investment goals, but this is not mandatory. Article 8 funds are known as “light green investments.”
• Article 9: Investment products with an explicit focus on sustainable goals, with the aim of measurable positive impact on the environment, climate or social areas. Article 9 funds focus on deep sustainability and are referred to as “dark green investments.”

This classification system helps investors distinguish between the sustainability performance of investment products and provides a standardized basis for responsible investment choices.

What does Vive do in terms of positive social and environmental contribution & SFDR

Where possible, Vive only selects funds that meet at least SFDR article 8 criteria, with a strong preference for article 9 funds. However, these classifications do not apply to investments in government bonds. Vive's selection criteria do not set a minimum percentage of sustainable investments in accordance with SFDR, but only apply to the fund's SFDR classification. As an investment product, Vive itself also falls under SFDR regulations and is classified as an SFDR article 8 product. Below is an overview of Vive's funds and the SFDR classifications.

What do the underlying funds do in the area of positive social and environmental contribution & SFDR

Funds with an SFDR article 8 classification are not required to have a minimum target of sustainable investments in accordance with SFDR. Vive also does not set a minimum requirement for this. However, some of the funds that Vive invests in do have a minimum target for these sustainable investments.

Below is an overview of the objectives of the funds in which Vive invests, as well as the reported percentages of sustainable investments achieved in accordance with SFDR.

‍

What is a sustainable investment in accordance with SFDR?

Fund managers have internal policies and methodologies for measuring whether an investment is sustainable in accordance with SFDR. There is no uniform set of instruments for classifying investments as sustainable in accordance with SFDR. SFDR legislation states that an investment can be called sustainable under three conditions:

1. The investment must make a positive contribution to an environmental or social goal.
2. The investment must comply with the “Do No Significant Harm” principle, which means that the investment does not contribute to activities that can cause major damage, such as controversial weapons.
3. The company in which investments are made must comply with good governance practices with clear rules to prevent social problems.

If a fund manager determines that an investment meets all three of these conditions, then it is a sustainable investment in accordance with SFDR.

4. Environmentally sustainable investments (EU taxonomy)

EU taxonomy

An investment is only classified as environmentally sustainable by the EU taxonomy if the underlying activity contributes significantly and measurably to at least one of the six established environmental objectives. In addition, data must also be used to show that the company is not significantly harming other environmental goals (the “Do No Significant Harm” principle). The company must also comply with social standards, such as protecting employment rights and respecting human rights.

The six ecological objectives of the EU taxonomy are:

1. Climate change mitigation: Reducing the company's impact on global warming by, for example, reducing greenhouse gas emissions.
2. Adapting to climate change: Measures to control the impact of climate change on the organization, for example by building dikes to protect against floods.
3. Sustainable use and protection of water and marine resources: Promoting efficient water use and protecting water quality.
4. Transition to a circular economy: Promoting recycling, reuse and reducing waste generation.
5. Pollution prevention and control: Preventing and reducing air, water and soil pollution.
6. Protection and restoration of biodiversity and ecosystems: Preserving and restoring natural habitats and preventing biodiversity loss

What does Vive do in the field of environmentally sustainable investments & the EU Taxonomy

None of Vive's sustainable selection criteria relate to sustainable investments under the EU Taxonomy.

What do the underlying funds do in the field of environmentally sustainable investments & the EU Taxonomy

None of the underlying funds that Vive invests in has a target for environmentally sustainable investments in accordance with the EU Taxonomy.

Only the Euro Corporate Loans Fund reports ecologically sustainable investments of 1.06% afterwards (31/12/2023) in accordance with the EU Taxonomy.

Continuous improvement and adjustment

Sustainability is a constantly evolving topic. At Vive, we recognize that the standards, legislation and insights surrounding sustainable investing are continuing to evolve. That is why we are constantly refining our sustainability policy and adapting it to the latest developments. This enables us to continuously align our strategy with industry best practices.

‍Version control

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

General Terms and Conditions

Vive Invest B.V.

‍

1. Who do you make appointments with?

1.1 You make agreements with VIVE Invest B.V. (Vive).

1.2 Vive is licensed by the AFM and is registered in the AFM register. The AFM and DNB supervise all financial institutions, including Vive. Information about our registration in the AFM register is available on the website www.afm.nl.

1.3 Our address is Keizersgracht 268 (1016 EV) in Amsterdam. Our website is www.viveapp.com. We can be reached by email and chat on our website or app.

2. What do we do for you?

2.1 You have asset management with us. That means that we invest for you. So you don't decide on your Investments yourself. We do that for you, and we do our best to invest for you in the best possible way. But it's still your money. Will your Investments be worth more? Then that profit is yours. Will your Investments become less valuable? Then the investment losses are yours too, and we are not responsible (liable) for them.

2.2 How do we decide what to invest in? We do this based on the agreements you have made with us. You agree with us on the main rules for investing. For example, how much risk you want to take. These agreements are contained in the Investment Plan. We will then decide where to invest for you.

2.3 We will always send you information about your Investments and asset management. It is important that you read that information. So you know exactly what we do for you.

2.4 Do we think the Investment Plan should change? Or do you think so? Then we will make new agreements.

2.5 To invest for you, you authorize us to open and use your Investment Account. This is an (administrative) account that you will receive from the Depository, as described in article 7. We will only use your money and Investments to meet our obligations resulting from the Investment Plan agreed with you. We make an overview of the money and these Investments. That overview is in your personal environment in our app.

2.6 You are required to install, activate and use the Vive app for the duration of the agreement. Without the Vive app, we cannot communicate with you and you do not have information that is important to you.

2.7 We do not provide credit. This means that we won't buy Investments for you if you don't have the money to do so.

2.8 We agree that you will not use the Investment Account yourself. So you cannot give us investment orders.

3. Your personal circumstances matter

3.1 You have provided us with information about your personal circumstances. Your personal circumstances show whether you can bear the risk of losses. And whether you want to wear it. We take this information into account when investing. For example, you have provided us with information about the following:

a) What your financial position is, what your income and your assets are.

b) How much you know about investing and how much experience you have with it.

c) Your goal. By that, we mean exactly what you want to achieve with asset management.

d) What risks you do want to take by investing and which risks you do not want to take.

e) Other information about yourself, such as your age, education, and work.

f) Your sustainability preferences (whether and how you want to invest sustainably).

By law or the company where they work, some people are not always allowed to invest. Does this apply to you? Then you can let us know. We can help you with this. But you are responsible for not breaking the law or these rules.

3.2 We assume that the information you have given us about your personal circumstances is accurate. We can also assume that you have provided us with the information we asked for. And that you also provide the information that you know is important to us. For example, if you know that you will have to sell your home soon and you may be left with a debt as a result. Or if you are getting married or getting divorced.

3.3 Will anything change in your personal circumstances? Or do you expect something to change?

And is that why the information about your personal circumstances that we have received from you is no longer correct? Then you should let us know as soon as possible. You can make changes via your personal environment in our app. Then we will assess whether we need to change the Investment Plan. Are you not doing this or are you doing it too late? Then we are not responsible for the consequences.

Suppose you are getting divorced. Then this may mean that the Investment Plan must change. Aren't you telling us that you're getting divorced? Then the Investments that we make may no longer suit your new personal circumstances and you may no longer be able to bear an investment loss, for example.

3.4 We treat you as a private investor. So we won't treat you like a professional investor. Not even if you ask for it. We do this to protect you. Professional investors include banks or (other) asset managers, for example.

3.5 If your personal circumstances change that qualify you as a US person, you are obliged to report this to us. In that case, we are forced to terminate our services to you.

You can find out more about whether you are a US person on the website www.irs.gov.

If one or more of the following situations apply to you, please inform us about this immediately:

(i) you have a U.S. passport;

(ii) you were born in the United States;

(iii) you live in the United States; and,

(iv) you have a U.S. home or postal address.

4. How do we carry out investment orders?

4.1 We have rules about how we execute investment orders (order execution policy). The order execution policy can be found on our website.

4.2 Our goal is to achieve the best possible result for you. We will send these rules to you with the agreement and these are in your personal environment in our app.

5. You take risks when you invest

5.1 There are risks associated with investing. An investment can be worth less money.

An investment can also no longer be worth money at all. There are different types of Investments that we can invest in. The most important information about this can also be found in your personal environment in our app and on our website www.viveapp.com.

Want more information? Then let us know. Then you will receive that information from us.

5.2 Do you no longer understand your Investments? Or do you no longer understand the risks of your Investments? Then you should let us know immediately. We are happy to explain.

5.3 You declare to us the following:

a) You have received enough information from us about which risks are associated with which Investments. You have read this information. You also understood this.

b) You understand that your Investments may be worth more or become less valuable. You can never be sure how much your Investments will be worth. If you have made a profit on your Investments in the past, that does not mean that this will happen in the future.

So you can also incur a loss. You also understand that Investments that have a chance of becoming extra valuable can also fall in value. Not only do you understand this, but you also accept it.

c) You understand that you run an additional risk if you borrow money and invest with that money. Or if you have borrowed money and your Investments are certain that you will repay the loan. Your Investments may be worth less money. Or are no longer worth any money at all. Then you still have to repay the loan. Or provide other security if your Investments are no longer enough certainty that you will repay the loan. We do not recommend investing with borrowed money.

d) You do not invest with money that you need for other purposes.

6. Your compensation for our management

6.1 You pay asset management costs. These costs are collected from the Investment Account.

6.2 These costs are listed in our cost overview, which can be found on our website.

1) A fixed fee (management fee) per year. You pay this fee in the first week of each month. We will then collect the compensation for the new month before. So you pay afterwards. With the management fee, we pay, among other things, our operational costs, the custody costs for Vive Custody B.V., and costs of supervision by the AFM and DNB. These are the costs of supervision that they supervise us. And part of the fixed fee is ours.

2) Fund costs that may vary by portfolio.

3) One-time costs for incidental events, such as a transfer of value for an annuity product.

6.3 The fixed fee depends on the money and value of your Investments in your Investment Account.

6.4 Vive has the right to change its rates. In the event of an increase, you have the right to terminate the agreement within thirty days of the announcement of this change.

However, you still owe the compensation for the month in which you cancel.

6.5 You authorize us to automatically debit any fees you owe us from your Investment Account.

6.6 If the contract ends, we calculate the management fee pro rata up to and including the last day of the month in which the agreement ends.

7. Vive Custody B.V. stores your Investments

7.1 We use a repository called Vive Custody B.V. (hereinafter: “Depository”). The Depository is a separate company. The Depository stores and administers your Investments.

7.2 The Depository ensures that Vive complies with the rules of asset separation: in the event that Vive should go bankrupt, your Investments will not fall into Vive's estate.

7.3 You are entering into a separate agreement with the Depository (and Vive). We call this agreement the Vive Custody B.V. Depository Regulations (hereinafter: “Regulations”). These Rules govern the relationship between you, the Depository and Vive. You can always find these rules in your personal environment in our app and on our website.

8. You can vote

8.1 Some Investments include the right to attend a meeting. Or to vote.

The Depository is the legal owner of the Investments and, in that capacity, has voting rights.

8.2 The Depository will not exercise its voting rights in investor meetings. As a Customer, you can ask the Depository in writing to grant a voting proxy so that you can vote on your investments yourself. To exercise this voting proxy, please contact Vive at support@viveapp.com.

9. How can you send us a message?

9.1 Do you want to send us a message? Then you can do this in two ways:

1) We can be reached via the chat on our website or in the app.

2) You send an email to support@viveapp.com.

9.2 Are you still sending us a message in another way? For example by fax? Or by mail? And does that cause misunderstandings, for example? Or delays? Then that is your risk. You cannot give us investment orders.

10. You consent to the processing of personal data

10.1 You agree that we include your (personal) data in our customer registration.

This personal data includes your name, address and place of residence details, and other information provided under or in connection with this agreement.

10.2 Vive will treat this information confidentially and will not make it available to third parties, except in the following cases:

1) it is necessary to carry out transactions that are part of this agreement;

2) to comply with legal obligations.

10.3 The processing of personal data is subject to the General Data Protection Regulation (GDPR).

11. You consent to electronic information

11.1 You will receive information about asset management from us. You give us permission to send this information to you electronically. For example, by email. Or to your personal environment in our app.

11.2 We expect you and assume that you regularly monitor your personal environment in our app so that you don't miss important information.

11.3 Information that is not intended for you personally is available on our website www.viveapp.com.

So we don't have to send you that information separately. That's okay.

12. We have rules about conflicts of interest

12.1 We have rules about how we prevent a conflict of interest with our Customers or our Customers from having a conflict of interest among themselves. Or a conflict of interest with ourselves, for example with companies that belong to us.

12.2 Is there a conflict of interest after all? Then we also have rules on how we deal with this conflict of interest. You can find all these rules on our website www.viveapp.com. Want more information? Then let me know. Then we will give you more information.

13. You are responsible

13.1 The risks of asset management are all yours, so if your Investments have fallen in value and you sell your Investments, you will receive less money. We are not responsible (liable) for this. If we are responsible, please read article 16.

13.2 You are also responsible for informing us of changes in your personal circumstances immediately (see article 3 of these terms and conditions).

14. We provide you with information

14.1 We provide you with information about asset management and the development of your Investments.

14.2 We make the following information available in our app in your personal environment:

a) Information about each investment order that we have executed. This can be a purchase of an investment or a sale of an investment. Have we carried out multiple investment orders? Then we will send that information all at once. We do this no later than 1 day after the investment order has been executed.

b) Information about the asset management that we do for you. For example, about the value of your Investments at that time and which Investments you have exactly. We send you that information every 3 months. We will also send you information about the costs.

c) Information about how your Investments meet your preferences and goals and are therefore still suitable for you. We provide this information annually.

d) Information about a loss of 10% of the total value of your portfolio as determined at the start of each reporting period or multiple thereof. We will send that information no later than the end of the day on which this loss occurred. You agree that we will therefore not report a 10% decline in the value of each investment, but only if the total value of your portfolio decreases by 10% (or more).

You get all this information in your personal environment in our app.

15. Always check our information

15.1 Did you receive information? For example, confirmations or overviews? And is this information incorrect? Or do you disagree with an investment assignment that we have carried out? For example, because you think it does not fall under the Investment Plan? Then you must let us know immediately. Aren't you going to let us know within 5 days? Then we can assume that the information and associated investment instructions that we have given you were good.

15.2 If you do not let us know that you disagree with this within 30 days of us providing you with the quarterly report, we will assume that you agree with our management during that period.

15.3 Are you expecting a message from us or should you know that you should receive a message from us? But aren't you getting that message? Then you should let us know as soon as possible.

16. When are we responsible (liable) and when not?

16.1 Do you have damage? Is that damage caused by our management? And are we seriously to blame for this or is it intentionally on our part? Only then are we responsible for this and have to pay for that damage.

16.2 We are therefore not responsible for other damage. For example, if you have damage in the following situations:

1) If your damage results in other damage.

2) If you don't meet your asset management goals.

3) If we had to take measures that follow from the law or the supervisor, or due to special circumstances.

17. Force majeure

17.1 We are not responsible for damage if, due to force majeure, we are unable to do what we should or have invested. What is force majeure? This is, for example, a failure in systems, a power failure, fire, or other circumstances that are beyond our control.

18. We can change our agreements with you

18.1 We may change our agreements with you at any time. For example, the rules we have made about how we execute investment orders in order to achieve the best possible result for you (order execution policy).

We will let you know via the personal environment in our app. Or we'll send you a letter or an email. The change takes effect immediately. Or on a date that we have chosen. That date is never in the past.

We will not change your Investment Plan without consulting you.

18.2 Does a change affect you? Then the change will only take effect 30 days after we have announced the change. Do you disagree with these changes? Then you can terminate the contract. How to terminate the contract is set out in article 19 of these terms. Are we not hearing from you? Then you agree to those changes.

18.3 If a law sets new requirements for our agreement that require the agreement with us to change, that change takes effect immediately. We do not need permission for this.

19. When does your contract with us end?

19.1 Our contract has no end date.

19.2 You can terminate the contract. We can also terminate the contract. This is possible every day, but you and we must give one month's notice. This always happens at the end of a subsequent month. As long as there are funds or Investments in your Investment Account, we calculate the fixed costs we receive from you on the last day of the month.

19.3 In some situations, we may choose to terminate the contract immediately or temporarily. No notice period is then required. This concerns the following situations:

a) If you request a deferral of payment (suspension of payment);

b) If your bankruptcy is filed;

c) If you are a company that is being dissolved;

d) If the debt restructuring scheme applies to you;

e) You die and we receive a certificate of inheritance or enforcement, asking us to stop managing it;

f) When a trustee or administrator decides about your money and Investments;

g) If continuing our relationship is no longer allowed by law, court or seriously damages our reputation;

h) If you refuse to cooperate to enable Vive to comply with regulations; to combat money laundering and other financial crime;

i) If you are a US person; or

j) If you move to a country that is included in the European Union sanctions list.

Have we temporarily stopped working for you? Then, if possible, we will discuss with you, the curator or administrator whether the contract should end.

19.4 Does the contract end? Then we will stop investing for you. Did we already carry out an investment order? But hasn't that investment assignment been fully completed yet? Then that investment assignment will still be completed.

If the contract ends, we will liquidate your portfolio within two weeks and deposit the released money into the counteraccount known to us. If you still have to pay a fee to us, we will first set it off with the funds in your Investment Account. You can decide how we sell your Investments after the contract. You must let us know in good time. However, it must be easy to carry out and can be completed within two weeks. Don't you say anything? Then we decide at our own discretion. This may mean that we sell all Investments immediately in 1 day.

If your counter-account is incorrect or no longer in your name and we are still unable to reach you to refund your money after 6 months, authorize Vive to donate your money to charity.

20. Extradition

20.1 You cannot request the extradition of Securities held by the Depository.

21. If we go bankrupt

21.1 We are covered by the investor compensation scheme. The bank we work with also falls under the investor compensation scheme.

21.2 Your Investments are separated from Vive via the Depository. If we go bankrupt, your Investments and funds are excluded from Vive's bankruptcy. Your Investments and funds are held by the Depository. In the event of Vive's bankruptcy, you retain your claim against the Depository.

22. Death

22.1 If, as a natural person, you are the sole account holder or the sole director of the legal entity and you die, the scope of asset management for one year after the death will be limited to legal acts that - in our opinion - cannot be postponed without disadvantage.

This includes, for example, giving orders to the depositary to execute orders intended to sell and close positions.

22.2 One year after death, the management mandate stops automatically. We will sell or, if applicable, close your positions within a reasonable period prior to that time and store the proceeds in the counter account linked to the deposit.

23. Do you have a complaint?

23.1 Do you have a complaint or comment? Then let us know. How to do that is in your personal environment in the app and on our website www.viveapp.com.

23.2 Did you receive a response from us to your complaint? And do you disagree with that? Then, within three months, you can submit your complaint to the Financial Services Complaints Institute (KiFiD), P.O. Box 93257, 2509 AG The Hague. You can also report the complaint via www.kifid.nl.

You can find more information about KiFiD on our website.

You can also go to court with your complaint.

24. Dutch language

24.1 The contract with these terms and all other information from us about asset management are in Dutch.

24.2 Have we received information about Investments that is in English? Then you will also receive that information in English. Do you not understand that information? Then let me know. Then we'll explain it to you.

25. Dutch law applies

25.1 The contract and these terms and conditions are governed by Dutch law.

25.2 The court in Amsterdam has jurisdiction to resolve any disputes between us by issuing a judgment.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Protocol Streamlining Capital Transfers (PSK)

If you have accrued tax-friendly pension assets with another provider and you want to transfer this assets to Vive (or vice versa) without immediate income tax, the Streamlining Capital Transfers (PSK) Protocol offers a solution. This document explains how to arrange such transfers. This also applies to the transfer of pension assets from Vive to another provider.

Vive Retirement Plan

Vive's retirement plan includes:

• A personal annuity account.
• A composite investment portfolio.
  
• An investment strategy.

The annuity account is blocked to prevent accidental withdrawals that can lead to tax consequences, such as the direct withholding of income tax and possible revision interest. The deposit into this account may be tax deductible. Transfers to or from another provider, without direct income tax, are possible under certain conditions.

PACK

Vive is affiliated with the PSK to ensure that the transfer of accumulated assets runs smoothly and without direct tax consequences. This protocol, supported by the Association of Insurers and the Dutch Banking Association, ensures a “tax-free” value transfer, without having to pay directly with the tax authorities.

Preventing income tax

A value transfer must be made accurately, otherwise the tax authorities can tax the accumulated capital. The Association of Insurers and the Dutch Banking Association have therefore made mutual agreements to ensure a smooth transfer of value. This is called “fiscally silent”. This means that the transfer takes place in such a way that there is no need to settle with the tax authorities in the meantime. These agreements are laid down in the PSK. The parties to the PSK (such as banks, insurers and investment institutions and companies) have agreed procedures for transferring the value of tax-facilitated products to another provider. Vive is a member of the PSK and works according to this protocol.

Read more about the PSK on the website of the Dutch Banking Association (NVB) or on the website of the Association of Insurers.

Advice on value transfer

You are responsible for choosing to transfer value to or from Vive. Optionally, ask a financial advisor for advice to determine whether it is a wise choice to do this. Value transfers can have long-term tax consequences.

How does it work?

a. Value transfer to Vive

Download the form at the bottom of this text. Sign it and submit it to the current provider. Once the current provider has received the form and all required documents, it will initiate the value transfer.

After that, the transfer will be carried out within fourteen calendar days. Does the fourteenth day fall on a weekend or holiday? Then the next business day counts as the fourteenth day, and Vive will send you a message as soon as the money has been transferred to Vive by the transferring PSK participant. The provider that carries out the value transfer may charge costs.

Link to the form

b. Value transfer from Vive to another provider

If you decide to continue the value of your pension investment account (interim) with another PSK provider, report this in the chat function of the Vive app or by emailing to support@viveapp.com. Vive then sends an email with the transfer form and an explanation of the form. The form must be fully completed and returned signed. After receipt, Vive will make the transfer within fourteen days. The administrative fees charged by Vive for transferring your value to another provider are: (to be determined).

Additional documents required

In some situations, additional documents are required, such as when there is a divorce or death. Without these documents, Vive is not allowed to transfer your funds to another provider.

• Divorce: Divorce Settlement.
• Death: Death certificate and certificate of inheritance.
• Power of Attorney: Proof of Power of Attorney.
  ‍

In the event that the financial institution to which you want to transfer the value does not participate in the PSK, Vive's acquiring financial institution requires an indemnification statement. Vive agrees to this indemnification statement with the acquiring financial institution.

Reimbursement

If the fourteen day period for value transfer is exceeded, the transferring party is obliged to reimburse statutory interest.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Fully customized

Everything we do is 
based on your situation, wishes
and goals.

Your ideal wallet

We set up the ideal investment portfolio
 for you together that exactly suits your situation, 
wishes and goals.

Always adaptable

You can plan your plan anytime, anywhere
 change or stop, where and when you want.

A plan that fits perfectly.

We'll put together an investment portfolio for you that's perfect for you and your goals. To get a good idea of who you are, we'll ask you a few questions beforehand. We also map out your financial situation. We give it a score and call it your financial profile. Based on this, we estimate which risks you can take and which style of investing suits you best.

Then specify what you want to invest for. For example, for your home, camper van or pension. You can also make your money work without a concrete goal.

Then we will implement this plan for you by executing your investment strategy. You can always choose to change your plan. We incorporate your new wishes directly into your strategy. Do you want to take less risk? Then we will ensure that we purchase safer investments for you. Do you want to invest less per month, but just as much return? Then we will invest more boldly for you.

You can always see exactly what investments your portfolio consists of. You can find this in the app at plans > your plan > portfolio.

Good to know: every goal is different and needs a different plan. That's why we create a unique strategy with an appropriate investment portfolio for every purpose.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Introduction to risk policy

Risk policy forms the core of Vive's investment approach. Vive bases its strategies on risk budgets, which optimally align investments with the goals and risk preferences of its customers. This enables Vive to make the investment process not only scientifically based and efficient, but also personal and flexible.

Vive believes that a good risk policy is more than just risk management at the portfolio level. It is a dynamic process that focuses on personal control. The best form of risk management is you. That is why Vive's risk policy is not only designed to optimize risks and returns, but also to provide you, as an investor, with continuous insight and an action perspective.

By establishing a dynamic risk budget for each client and each financial plan that can change over time, Vive ensures that investors are exposed to investment risks very accurately and efficiently. This means that you do not run unnecessary risks but also miss out on potential returns. Vive ensures that you, as an investor, always have insight and an action perspective to control your investment risks.

What risk policy is being implemented?

Vive's risk policy is fully tailored to the investor's individual needs and financial situation. Vive sees risk not as a limitation, but as a means to achieve your financial goals. The risk policy ensures that you not only have a well-diversified and efficient investment portfolio, but also the insights and tools to manage it.

Where traditional institutions often work with fixed risk profiles such as defensive, neutral or offensive, Vive opts for a customized approach. Vive acknowledges that each investor is unique and that risk preferences may even vary by financial goal.

That is why Vive uses Value at Risk (VaR) as a core measure for risk management. This means that the maximum loss rate over a period of one year is calculated and adjusted to what you consider acceptable. Based on this measure, Vive optimizes investment strategies so that your investments stay in line with your personal risk budget and goals.

To do this, Vive uses an internally developed Economic Scenario Generator (ESG). Using this technology, Vive can scientifically calculate the downside risks and expected returns of various asset classes - such as stocks, bonds and money market instruments.

Vive offers continuous monitoring of your portfolio and closely monitors developments in relation to your personal goals. This means that you not only gain insight into the performance of your investments, but also receive concrete signals when action is needed.

Using advanced technology and scenario analysis, which calculates hundreds of thousands of market scenarios, Vive ensures that:‍

Risks are identified early— You will receive timely alerts if market developments or portfolio performance deviate from the expected price.

Dynamic adjustments are possible —Your risk budget can be adjusted if necessary so that it remains in line with your personal situation and goals.

Transparency and control are key — You always have insight into how your portfolio is developing and remain in control of your financial future.

In addition to personal control, Vive also applies advanced risk management at the portfolio level. In this way, risks are actively managed and adjusted where necessary. To do this, Vive makes use of:

Dynamic risk management — The risk budget is continuously evaluated and can be adjusted based on changing market conditions or personal goals.

Rebalancing — The portfolio is automatically adjusted as soon as it falls outside the strategic range, so that the intended risk-return ratio is maintained.

Broad diversification — Investments are spread across multiple asset classes, regions, and sectors to minimize concentration risks and limit the impact of market volatility.

Scenario analyses and stress tests — The portfolio is constantly subject to hundreds of thousands of simulated market scenarios, allowing Vive to assess how your investments perform under different conditions and take proactive action when necessary.

With this approach, Vive offers a carefully managed and flexible investment process, where you, as an investor, are in control and can make conscious choices. In this way, together, we ensure an optimal balance between risk and return, tailored to what really matters to you.

How is the risk limited and what risk measures are used?

Vive applies coherent and carefully structured risk management to ensure that risks remain within acceptable limits. This is done through a combination of broad diversification, strict selection criteria, active monitoring and risk measures that match the customer's personal goals. The following measures are used to reduce risks:

Widely diversified portfolios
By investing globally in different regions, sectors and asset classes (such as stocks and bonds), the portfolio becomes less sensitive to specific market or sector shocks. This broad diversification helps to reduce overall risk and prevents excessive dependence on individual markets or companies.‍

Strict selection of investment funds
Vive only invests in UCITS funds with daily tradability, sufficient diversification and transparent costs. When selecting funds, several risk mitigation criteria are used, such as:

— Currency risk — Where possible, unnecessary currency risk is avoided.

— Interest rate risk — The duration of bonds is carefully tailored to the client's risk references.

— ESG criteria — Funds are assessed for sustainability risks to minimize long-term risks and encourage responsible investment.

‍Lifecycle approach and rebalancing

— For plans with a fixed end date, the risk level can be gradually reduced as the end date approaches, reducing the risk of major losses at a critical time.

— Rebalancing takes place when the portfolio deviates too much from the agreed risk limits (VaR) and the desired level of end goal security. As a result, the portfolio remains optimally aligned with the investment strategy and objectives.

No complex or non-transparent products
Vive avoids investing in complex or opaque products, such as hedge funds and funds with complex derivative structures. This prevents unpredictable risks, hidden costs and illiquidity, so investors always have a clear insight into their portfolio.

What risk measures are used?

To accurately assess both short and long term risks, Vive uses various risk measures that may vary from plan to plan:

Value at Risk (VaR): The maximum accepted (negative) return within one year — given a 95% confidence level — in a bad weather scenario. Preview: A VAR of 15% means that, in a bad scenario, the portfolio can fall by up to 15% within one year, with a 5% chance of a greater loss.

Impairment to Mission (ITM): The maximum allowable deviation from the final goal of the plan with a 95% confidence level. Preview: an ITM of 30% means that, in a bad weather scenario, the portfolio may deviate from the final goal by a maximum of 30%, with a 5% chance of a larger deviation. This measure is used in plans with a concrete final goal.

These measures form the basis for the design and risk management of each portfolio and each has its own function in determining the dynamic risk budget:

— VaR focuses on short-term risks (maximum loss within one year).

— ITM focuses on the long-term goal (maximum deviation from the final value).

In addition to customer-oriented risk measures, Vive also performs internal analyses to ensure portfolio stability and efficiency:

Volatility (standard deviation): This measures the mobility of the portfolio to gain insight into the extent of price fluctuations.

Tracking Error: This measures the extent to which the passive investment funds differ from their underlying index.

Through this combination of risk measures and management tools, Vive can make a thorough and objective assessment of the risk level and ensure that the portfolio optimally matches the client's investment goals and risk preferences.

How is the portfolio monitored for risk?

Vive only works with strategic asset allocation. The portfolios are automatically checked daily to see if they are still in line with the strategic asset allocation. For example, when stocks rise or fall too sharply compared to bonds, a rebalance automatically follows, so that the portfolio fits the desired risk profile again. The underlying strategic asset allocation is periodically recalculated and changed if necessary.

1. Quarterly update: Every quarter, all scenarios are recalculated based on current market conditions.
2. Annual update: Every year, the risk premiums of each asset class are evaluated and it is assessed whether the previously made assumptions are still up to date.

Vive continuously calculates your investment plan based on the latest developments. If it appears that the expected end goal differs from the original forecast, the investment plan will not be adjusted automatically. Instead, you'll receive an “on-track/off-track” notification. This gives you control and, if you wish, you can make changes to:

— The portfolio's risk level

— The monthly deposit

— The target amount

— The end date of the plan

This data-driven, systematic monitoring ensures that Vive's risk policy remains in line with your personal goals and risk preferences at all times.

To provide full control and insight, investors can always view the current layout of both the portfolio and the plan in the Vive app under “Strategic Portfolio”. If desired, adjustments can be made here immediately.

With this approach, the portfolio not only remains optimally aligned with your financial goals, but you, as an investor, also maintain maximum control and transparency about your risk level and the value development of your investments.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Countless economic scenarios mapped out

So that we know exactly how our funds move due to market changes.

Thousands of investment strategies calculated

Based on countless economic scenarios.

Broad portfolios with varying levels of risk

Our model invests in a mix of stock, bond and money market funds.

Now available for you.

Vive has built a financial model that creates thousands of investment strategies based on countless economic scenarios. This model puts together a mix of funds that perfectly suit your goals, wishes and situation. Should your plan change, our model will immediately calculate a new strategy that matches your new settings.

A strong investment portfolio consists of a broad portfolio with different types of investments. This way, the risk is spread as much as possible. Our investments are divided into different Asset Classes (asset classes). These, in turn, are spread across different geographical regions and sectors. Through our financial model, your money is invested in a mix of stock, bond and money market funds. All carefully selected for cost profile, performance, risk and sustainability.

The estimates of this model are also updated quarterly to incorporate the latest market developments.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

ESG MSCI

Our funds are measured for sustainability based on the MSCI ESG criteria.

People, Environment and Society

Our funds take people, the environment and society into account as much as possible.

Investing for the future

Our funds are chosen with a good expected return for the medium and long term.

Investing is more than putting your money to work.

After all, how your money works for you has an impact on the world. That's why we take MSCI's ESG criteria into account with our funds. These are measures that measure the effect on people, the environment and society.

It is also important to know that sustainable investing does not have to come at the expense of performance. In fact, more sustainable funds are increasingly performing better than funds that are not. This is because recent laws and regulations have increasingly rewarded sustainability in recent years. Take companies with low CO2 emissions, for example. They are less at risk of negative consequences of new laws and regulations than companies with high emissions. This can ensure that they have wider social support in the future, and therefore become more valuable.

We are constantly looking for the balance between sustainability, costs and as much return as possible. That's why we pay a lot of attention to our fund selection.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Under laws and regulations, financial institutions are required to have procedures and measures to prevent and deal with conflicts of interest. Below you can read how Vive has incorporated the conflict of interest policy into its business operations and the measures that Vive has taken to protect the client's interests. At all times, it is paramount that the applicable laws and regulations prevail and are also the guide in case of conflicts of interest.

Policy principles‍

Vive has created the policy under its license as an investment firm. The policy applies to all companies affiliated with Vive Group.

The policy

Vive acknowledges that, like any other investment firm, there may be possible (potential) conflicts of interest. Vive's policy is aimed at protecting the client's interests, so that a client cannot suffer material damage. In this policy, Vive has defined the circumstances that may lead to a conflict and what measures have been taken to manage and/or prevent these conflicts.

Possible conflicts of interest

Conflicts of interest may arise, among other things, in the following (not exhaustive) listed situations:

• Having an interest in the result of a service or transaction provided for the client that is different from the client's interest in this result;
• A conflict of interest between clients.
• Having a financial or other incentive to let the interests of one client or group of clients prevail over the interests of other clients;
• Providing services by affiliated companies; The structure and (financing of) the business activities

‍

Because Vive's services are highly automated, the chance that Vive, or a Vive employee, will have an inappropriate influence on how asset management is carried out for a single customer, or group of customers, is considered extremely small. Where the clients may have a conflict of interest among themselves, or otherwise have different interests, this will be reported to the Compliance Officer.

Although the risk of this conflict of interest is considered low, given the services and the extensive method of automation, the Compliance Officer will appoint persons to represent the interests of these customers who may have conflicting interests.

In the event of conflicting interests, the Compliance Officer will weigh interests together with the board member who is not responsible for commercial matters.

‍
With regard to the services provided by affiliated parties, decision-making is organized in such a way that, in the event of a conflict of interest, the interests of the affiliated party are secondary to the interests of (the customers of) Vive.

To ensure this, the Compliance Officer, together with Vive's management, will decide that the person in whom the affiliated party is or may be represented does not participate in decision-making.

‍
Vive has created various measures, procedures and policies to recognize, prevent and manage a conflict of interest. The following is a non-exhaustive list of a number of measures that Vive has taken to ensure the client's material interest.

Internal supervision

Vive has a board member who is ultimately responsible for compliance issues. In addition, the Compliance Officer monitors compliance with the conflict of interest policy. Agreements with affiliated parties will be assessed by the management jointly with the Compliance Officer on the “at arms length” principle, where the ultimate responsible decision-making authority lies with the board member who is not involved with the affiliated party. Periodically, at least annually, the effectiveness of the anti-conflict of interest policy shall be reviewed and, where necessary, updated. In the event that a conflict of interest occurs that is not provided for in the policy, the Compliance Officer will immediately adjust the policy accordingly.

Remuneration policy

A specific remuneration policy has been established where the service model and how reimbursements are passed on to customers are not based on services that are not in the customer's interest. Employees who can influence investment decisions do not receive variable remuneration. That is why the integration of sustainability risks into remuneration policy does not apply.

Private investment transaction

The personnel policy states that, if an employee wants to make a private investment transaction, this must be reported to the Compliance Officer in advance.

Donations

In addition to the private investment transactions scheme, personnel policy includes the donation scheme and ancillary activities scheme to manage conflicts of interest.

Commission

Vive does not receive commissions, commissions, or monetary or non-monetary benefits paid or provided by a third party.

Market abuse

To prevent Vive employees from using (price) sensitive information for their own profit, Vive has drawn up a private investment transaction scheme. The scheme must ensure that (the appearance of) insider trading and the mixing of business and private interests are prevented.

‍Separation of duties

To ensure that people can abuse the system, segregation of duties is ensured. There is a separation between functions in which investment services are provided and functions in which the operational processes are handled for the purposes of the activities.

Communication

Any (possible) conflict of interest within Vive will be reported to the Compliance Officer and he will inform the Executive Board about this. Compliance will investigate the reports in consultation with the Management Board. Each report is assessed against the conflict of interest policy. Each relevant report is recorded in writing, with Vive indicating how the conflict of interest was dealt with.

Given the specific nature of conflicts of interest, Vive will review each report on an individual basis. If the organizational and administrative arrangements put in place by the investment firm to prevent or manage a specific conflict of interest are not sufficient, this will at least be made known to the clients involved in this case.

Version control

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Vive's investment beliefs

Vive wants you to be able to achieve your goals through your investments. The investments and investment portfolios are at the service of achieving your financial goals. Vive's asset management to private clients provides the desired investments with an efficient ratio between return and risk, at low costs, in a transparent manner and taking into account widely accepted ESG criteria (i.e. in the areas of living environment, social relationships and good corporate governance).

Sustainability policy

At Vive, investing goes beyond just financial aspects. Vive includes sustainability criteria in its selection policy. In doing so, Vive strives to select investment funds and managers that excel in their category when it comes to sustainability. This involves a two-way approach to sustainability.

Sustainability risks (outside-in): Vive analyses environmental, social and governance (ESG) sustainability risks that can affect investments. We include these in our investment process to make better choices and strengthen our portfolios.

Sustainability impact (inside-out): Vive does not have a goal for sustainable investments but promotes social characteristics through its selection policy. Vive does this based on the frameworks of the Sustainable Finance Disclosure Regulation (SFDR), the European legislation that promotes transparency around sustainability.

Vive selects investment funds based on a selection policy that takes into account sustainable characteristics, with the aim of a balanced risk-return ratio. The sustainability selection criteria are based on the following principles:

1. Exclusion policy

Vive only invests in funds that exclude investments based on a structured policy, within the asset class where possible.

2. Best-in-Class Selection

We only select funds that excel in sustainability:

• At least one BBB's MSCI ESG Rating, to reduce sustainability risks.
• At least one SFDR article 8 classification (preference for article 9).
  This requirement is not applied by default to government bonds.

3. Voting Rights and Engagement

For equity funds, we only invest in funds that actively use their voting rights and encourage companies to behave more sustainably.

4. Social Features

Vive promotes social values such as:

• No investments in controversial weapons.
• Limiting investments in the tobacco industry
• Respect for human rights, labour rights and combating corruption according to the UN Global Compact.

With this policy, we ensure that our investments are not only financially strong, but also contribute to social and sustainable goals, in line with changing laws and regulations. See it Vive Sustainability Policy and the SFDR documents for more information.

Diversifying risks and keeping costs low are important

Vive believes that investing is best done with widely diversified portfolios. Vive strives to spread as much as possible across asset classes, and within them across geographical regions and sectors. Avoidable risk that is not rewarded with a positive expected risk premium (more return above the risk-free rate) should in principle be avoided.

Vive does not believe that market timing and tactical asset allocation add value to the customer after deduction of costs. Vive does not believe that trying to beat the market structurally adds value for the customer after deducting costs. With active management, it is very difficult to do better than the market average. That is why the policy is to select funds on the basis of “passive where possible”. Vive believes that active management makes sense for less efficient or inefficient markets if it leads to better risk management. Vive's focus in portfolio management is on the best possible composition of portfolios per risk level based on realistic and plausible (long-term) economic scenarios. Clients' investment horizons range from short to long term. With the help of outsourcing to external asset managers, i.e. the suppliers of unlisted investment funds in which Vive invests for its customers, Vive can focus on the added value for you as a customer. Vive can select the investment funds itself. Vive only invests through unlisted UCITS in the selected asset classes.

Focus on risk management

Risk management is crucial for sustainable asset management. This means that the risk is measured frequently and that the portfolio is adjusted if necessary. Vive uses the principle that the downside risk value of the optimal portfolios is updated quarterly and that the composition of the optimal portfolios can be adjusted accordingly to achieve the best ratio between expected return and downside risk. To ensure that clients' investment plans remain close to the intended risk profile, Vive monitors your investment portfolios daily and Vive rebalances the portfolios if they differ too much from that risk profile. The actual composition is then brought into line with the strategic portfolio associated with the investment plan at the time of rebalancing.

In which asset classes is the money invested?

The asset classes that qualify for the optimal portfolio should have a positive expected risk premium that is scientifically based.

Based on its investment beliefs, Vive can fill the portfolios with the following asset classes:

• Money market investments in euros;
• Government loans in euros or hedged to the euro;
• Investment Grade business loans in euro or hedged to the euro;
• Global, mature and emerging markets stocks;
• High Yield business loans, i.e. business loans with lower credit quality than Investment Grade class.

Vive determines a representative index series for each category, which is used to determine the statistical characteristics in Vive Technology's Economic Scenario Generator model. These characteristics determine the degree of risk diversification across categories.

How does Vive select funds for each asset class?

Vive offers asset management by investing in unlisted investment funds (“funds”). Vive does not invest in its own funds but uses third-party funds; this prevents an unwanted conflict of interest.

Vive selects third-party funds based on the following criteria:

Liquid: The portfolio is set up with unlisted open-end investment funds that can be traded on a daily basis.

High degree of risk diversification: There is a wide range within the fund: there are sufficient names in each investment fund and it is ensured that no individual investment has too large an allocation within the fund, both in terms of euro and risk weight. This is tested by applying a 5% worst case scenario to the two largest positions in the portfolio and checking that it does not exceed the Value at Risk of the asset class in question. If exceeded, the fund does not meet the risk diversification criterion and is not eligible for selection.

Low costs: The running cost factor (OCF) must be low. This is tested by comparing the OCF of a fund to be selected with the median of the OCF of comparable funds. The amount of any entry fee or exit allowance must be in line with the market.

Sustainability criteria: Vive only invests in funds that meet our sustainability criteria (see above for more information).

Appropriate mandate of the instrument: The fund's benchmark is reasonably in line with the representative index series on which the statistical characteristics are based; the tracking error between the two indices is not expected to exceed 1%. This is about two index series. The index series on which the statistical characteristics are based refers to the index series used to determine the parameters in the Economic Scenario Generator model. The other index series, from the benchmark, concerns the fund's benchmark. The investment universe and risk restrictions contribute to sufficient risk diversification. With an index tracker, the replication method ensures a good connection to the benchmark (for example, full replication). The fund's management style is passive and responsible where possible.

Good quality asset manager: The asset manager has a proven track record (i.e. has demonstrated that asset management in the respective asset class is carried out reliably), has its own risk management in order and has a stable organization. Vive specifically sets an AFM registration of the fund manager and the fund as a criterion. In addition, the fund must have a reliable depositary.

Suitable and permitted for retail investors within the European Union: The fund has UCITS status (UCITS) and for the fund, the Key Investor Information Document (EBI, in English: KIID) is available in English and in the language of the country where Vive offers the app. This means that the EBI is available in the Dutch language for funds used for customers in the Netherlands.

Security-lending funds and unnecessary use of derivatives should be avoided: Vive strongly prefers funds without securities lending and without the use of derivatives (such as total return swaps). Vive considers adding counterparty risk by lending securities undesirable, because this is not a transparent source of risk for the customer. The use of derivatives in a fund involves additional risks that cannot be clearly understood by retail investors. If a fund without securities lending or derivative use is not available for a specific asset class, but the improvement in the risk-reward ratio for Vive's customers is significant, Vive may still consider adding this fund. In that case, it will be specifically recorded and communicated to customers how Vive deviates from Vive's principle of lending securities and derivatives, and why Vive considers it in the interest of customers that the fund in question can be part of customer portfolios. Excluded are funds that use so-called exotics (custom derivatives).

How are investment plans made?

Vive helps clients set investment goals based on preferences that customers specify and within the customer's risk tolerance profile based on the risk acceptance expressed by the customer. Through a software-defined procedure, an optimal investment strategy is then derived for each target plan. This strategy is a so-called lifecycle strategy: the “investment risk decreases as the end date approaches”.

Vive determines an optimal investment portfolio within the client's risk profile. Vive ensures portfolio optimization and rebalancing after adjusting the risk-return characteristics of the underlying asset classes. The optimal portfolios and forecasts for the median scenario and the bad weather scenario are based on an economic scenario set that is generated quarterly by the Economic Scenario Generator model.

The investment plans are executed by investing for each investment plan in an optimal portfolio corresponding to the level of risk that the client accepted when preparing the plan (or last revision of the plan). Vive uses the same consistent portfolio optimization to fill in the investment mix in the different types of investment plans.

Portfolio optimization with the eligible asset classes takes place by choosing the portfolio with the highest expected return (median scenario) at any desired Value-at-Risk (VaR) level based on a realistic 1-year scenario. Vive uses a robust optimization technique to minimize the impact of extreme anomalies. The VAR level is determined as the 5% percentile of the probability distribution of portfolio returns.

Vive's services include rebalancing the portfolios in the investment plans created by the customer. Differences between the actual portfolio and the strategic portfolio for the customer's investment plan may arise due to price developments and changes in the strategic portfolio. The purpose of rebalancing is to align the actual portfolio with the strategic portfolio that currently accompanies the specific investment plan.

‍

This policy is designed to inform you about our use of cookies, local storage objects and similar Technology. For ease of reference, unless otherwise stated below, we will use the term "cookies" in this policy to refer to all of these Technology. This Cookie Policy is part of our Privacy Policy (link) which also includes additional details about our collection and use of information. This cookie statement applies to www.viveapp.com, VIVE mobile application and all associated domains of VIVE Invest B.V., registered at the Dutch Chamber of Commerce with registration number 62098896. Our address is Keizersgracht 203, 1016 DS Amsterdam, the Netherlands.

About Cookies

Websites use techniques that increase user-friendliness and make the websites as interesting as possible for each visitor. The best-known examples of such techniques are cookies and scripts. (hereafter "cookies"). Cookies may be used by website owners or by third parties – advertisers, for example – who communicate via the website you visit.

The use of cookies is safe. No personal information, such as a telephone number or an e-mail address, can be traced back to cookies. As a result, cookies cannot be used for e-mail and/or other marketing actions.

We think it is important that you know which cookies our Website and mobile application use and for which purposes they are used. We want to guarantee your privacy and user-friendliness as much as possible. Below you can read more about the cookies we use and for which purposes.

For which purposes do we use cookies?

We use cookies for the following reasons:

• To make sure the Website and mobile application function properly
  
• To measure usage of the Website and mobile application
  
• To display advertisements on our Website and mobile application
  
• To measure the relevance of our information and your interest in the offer
  

Below we make clear how we use cookies for these applications.

Cookies to measure usage of the Website and mobile application

In order to determine which parts of the Website and mobile application are most interesting for our visitors, we continuously try to measure, with the help of a third-party software, the number of visitors/users and the most frequently viewed parts. We use cookies for this purpose.

The information we collect in this way is used to compile statistics. These statistics give us insight into how often our web page is visited, where exactly visitors spend most of their time, and so on. This enables us to make the structure, navigation and content of the Website as user-friendly as possible for you. The statistics and other reports are not traced back to persons unless they register on the Website.

See below for a list of the cookies we use to gather statistics, what data they collect and how long they are used.

For the cookies that our third parties place and the possible data that they collect, we refer to the statements that these parties provide on their own websites about this; see the links below. Please note that these statements are subject to change on a regular basis. A third party is Google Analytics: https://www.google.com/policies/privacy/

Cookies for the display of advertisements

These cookies are used by advertising networks who act as intermediaries between Vive Invest and advertisers. They are used to show relevant, personalised advertisements or offers through every type of medium (e.g. e-mail, social media, banner ads) based on your behaviour on our Website. They are also used for remarketing advertisements.

These cookies are used to:

• Show relevant, personalised advertisements or offers through every type of medium (e.g. e-mail, social media, banner ads) based on your behaviour on our Website and mobile application
  
• Limit the number of times each advertisement is displayed;
  
• Measure the effectiveness of an advertising campaign;
  
• Make a link to social media, so that you can be recognised when you wish to use social media through Vive Invest Website and mobile application.
  

See below for a list of the cookies media agencies, advertising networks, and/or we use in combination with advertisements, what data they collect and how long they are used. This list is subject to change.

If such cookies are not used, you will still see advertisements. This is because advertisements are also shown to users who do not use cookies. These advertisements may, for example, be adapted to the content of the Website and/or mobile application.

For the cookies that our third parties place for advertising purposes, we refer to the statements that these third parties provide on their own websites. Please note that these statements are subject to change on a regular basis. Vive Invest has no influence over this.

• Google AdWords Conversion (Google): https://policies.google.com/privacy
  

Other / Unforeseen Cookies

Due to the way the internet and websites work, we may not always have insight into the cookies that are placed by third parties via our Website or mobile application. This is particularly the case if our web pages contain so-called embedded elements; these are texts, documents, images or films that are stored with another party, but which are shown on, in or via our Website and/or mobile application.

Browser Settings

If you do not want websites to place cookies on your computer at all, you can change your browser settings so that you receive a warning before cookies are placed. You can also change the settings in such a way that your browser rejects all cookies or only the cookies of third parties. You can also delete cookies that have already been placed. Please note that you will need to change the settings separately for each browser and computer you use.

Please be aware that if you do not want cookies, we will no longer be able to guarantee that our Website is working properly. It is possible that some functions of the Website are lost or even that you can't see certain websites at all. In addition, the refusal of cookies does not mean that you will no longer see any advertisements. The ads will no longer be tailored to your interests and will be repeated more often.

How to adjust your settings varies from browser to browser. If necessary, consult the help function of your browser. If you want to disable cookies from specific parties, you can do so via www.youronlinechoices.com.

Other Remarks

We will have to amend these statements from time to time, for example because our Website or the rules surrounding cookies change. We may change the content of the statements and the cookies at any time and without prior warning. You can consult this web page for the latest version.

If you have any questions or remarks, please contact privacy@viveapp.com.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Guarantee scheme Vive Invest B.V.

The Asset Separation Act and Investor Compensation Act. By law, companies that provide investment services must keep their own funds separate from clients' invested assets.

If things go wrong, their clients' investments are safe in a separate jar. Vive complies with the rules of property separation.

The Financial Markets Authority checks whether the Vive complies with the rules that apply to asset separation. These rules ensure that should Vive go bankrupt, our clients' investments are separated from Vive's assets. As a result, clients' investments do not fall into the bankruptcy estate.

In the unlikely event that a case of fraud and/or mismanagement occurs at Vive and Vive cannot guarantee the rules of asset separation, there is the investor compensation scheme for affected investors.

Investor compensation offers protection up to a maximum of EUR 20,000 per person and per company.

Do you and your partner have an and/or investor account? Then you have the guarantee that together you will receive a maximum of EUR 40,000 in return.

‍More information about the investor compensation scheme can be found on the website of The Dutch Bank.

Please contact support@viveapp.com if you would like to be provided with the English Version of this document.

‍

Your situation

Not satisfied with Vive's services? Then we recommend that you contact customer service by emailing: support@viveapp.com, or send a chat message in the app (account/ support/ chat with us). The customer service employees are happy to work with you to find a suitable solution.

Are you unable to resolve the issue with customer service and does your complaint remain unresolved? In that case, make it clear that you are not satisfied with the solution offered. The customer service representative will start the complaints process for you so that your complaint can be formally dealt with.

Complaints procedure

1. We receive your complaint.
This can be done via the communication channels that Vive uses. It is insurmountable that messages are sometimes lost due to technical failures, for example or otherwise. That is why you always want to verify with us whether the message has been received by us if we have not received a response from us after 10 business days?

For the sake of completeness, it should be noted that this complaints procedure does not prevent you from the normal course of law in the Netherlands.

We also note that you would do well to file a complaint with us as soon as possible to prevent the complaint from being dealt with due to the period that has already elapsed. The right to file a complaint generally expires at least five years after you become aware of what the complaint is about.

In addition to this complaints procedure, we have taken a special procedure and measures to prevent and manage conflicts of interest. These also apply to complaints. If you wish, you will receive a copy of this. ‍

‍

2. The complaint will be registered upon arrival.
In any case, within five working days, your complaint will be registered in at least the manner prescribed by the supervisors and included in our complaints register. The Compliance Officer supervises this and, where necessary, will also request additional information to fully understand and record the complaint. In this and throughout the handling of the complaint, the applicable privacy regulations will be respected at all times.

The Compliance Officer supervises business operations and therefore also the entire complaint handling process.

In your complaint, you may hold us liable for the damage you have suffered. In that case, we must also report your complaint to our professional liability insurer. He will then take over the handling of the complaint for us. We will then always inform you about this.

If the complaint concerns the actions of one of the board members, at least the opinion of the director whose actions are being complained about, but also of at least one of the other board members will be sought.

All complaints are registered using the complaint form. A complaint is any expression of dissatisfaction addressed to Vive by an individual (both a natural person and a legal person) relating to a Vive investment service provided by Vive, through a channel through which Vive communicates with customers.

‍

‍3. We aim to respond to your complaint within 10 business days.
Preferably, we will deal with your complaint immediately by resolving it. If that is not yet possible, you will at least receive a confirmation of receipt of your complaint within this period, stating the period within which you can expect a response and what steps we will take to deal with your complaint.

The review of the complaint will only be sent to you after approval by the Compliance Officer. Optionally, the Compliance Officer will also inform the Depository Bank concerned, where your investments are held, about the complaint. In addition, Vive provides the AFM with timely information about complaints and complaint handling.

4. You will be given the opportunity at any time to comment on the review of the complaint sent to you.
‍If there is reason to do so, we will send you a second review of the complaint, taking into account your objections to the first review of the complaint. Where possible, the second review will involve a director who was not already involved in the review of the first complaint. In addition, the steps such as those under 1 to 5 will apply again.

5. If, after dealing with the complaint, you still do not agree with the first and/or any second or further reviews, you can contact KiFiD.
Below you will find the contact details of the KiFiD. For the sake of certainty, for the current data, please visit www.kifid.nl.

Kifid
KiFiD postal address: P.O. Box 93257, 2509 AG The Hague
KiFiD visiting address: Stichthage offices, Koningin Julianaplein 10, 2595 AA The Hague
Telephone number: +31 (0) 70 333 8 999
E-mail: consumenten@kifid.nlWebsite: https://www.kifid.nl

Privacy & cookies

At Vive Invest, we care about the protection of your data and privacy and how it applies to you, as a user of our website(s). In this Privacy Policy ('Policy'), you can find information about how, whether, and why we collect and use your personal information on our Vive Invest website www.viveapp.com and on our mobile application Vive App. This Policy applies to any personal information that is gathered when you use our services, visit our Website, or otherwise interact with us. We have divided this Policy into different sections. The processing of your personal data complies with the General Data Protection Regulation (GDPR), the Dutch GDPR Execution Act and the Dutch Telecommunications Act.

About us

The data controller for the processing of your personal data is VIVE Invest B.V., registered at the Dutch Chamber of Commerce with registration number 62098896. Our address is Keizersgracht 268, 1016 EV Amsterdam, the Netherlands.

If you have any questions about the processing of personal data resulting after reading our Privacy Statement, you can contact us at privacy@viveapp.com.

Types of personal data we collect

To assess and open Vive Website and Mobile Application accounts, we can collect and use the following personal data:

• First and last name
  
• Date, country and place of birth
  
• Nationality
  
• Gender
  
• Residential address
  
• Telephone number
  
• Email address
  
• Social security numbers and/or other tax identification numbers
  
• Counter IBAN
  
• Device data (such as type of device, operating system, IP-addresses and advertising IDs)
  
• Location data via GPS
  
• Uploaded images/content
  
• Device data of added devices and API-keys
  
• Financial and banking data, product subscriptions and transaction history
  
• Cookies and usage date on how you use our products and services
  
• Correspondence with Vive Invest and support data (telephone, chat conversations and email)
  
• Additional information related to opening an account and creating your personalized investment
  
• Plans such as your knowledge and experience of financial markets, your financial situation, investment situation and preferences and your risk preferences
  
• Marketing data (statistics related to our marketing campaigns and data to measure this)
  

Information about our communication

• When you send us an email, or chat with us online or via social media, we save your correspondence with us if you are already a customer or in the process of becoming one or contacting us to find more about our products and/or services.
  
• Information we collect when you use our Website and/or our mobile application.
  
• When you visit our Website and mobile application or use our services, we may register your IP address, browser type, operating system, referring website, web-browsing behaviour.
  
• We may receive an automatic notification when you open (or open a link from) newsletters from us.
  

Information in relation to social media

Depending on your social network settings, we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may gather publicly available information you give us access to from your social network profile, including your contact details, interests, and social network.

For more information on the personal data that we receive from your social network provider, and how to change your privacy settings, please refer to the website and the privacy policy given by your social network provider.

Information you choose to share with us

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

Purposes of processing your data

Vive Invest processes your personal data in accordance with the laws and regulations based on several legal grounds. Vive Invest processes personal data to provide our services. For example, personal data is processed to:

• Comply with legal obligations
  
• To preserve our agreement and to provide our services in a secure manner, we process your personal data. For example, we need your contact information to keep you informed about relevant developments, and we store correspondence data to improve our customer services
  
• To make your user experience easier and more effective, we may assess how you use our services, and combine this data with information collected via your personal account, registration details, cookies, and similar technologies. This combination enables us to, for example, optimize our search algorithms and offer a better customer experience
  
• To create better and personaliszed investment strategies
  
• To process personal information for (direct) marketing purposes. This means we may use your personal information to send you newsletters, emails, promotions, or other marketing communications. We use the results of our analysis to tailor our marketing communications to your specific interests and preferences. For example, if our analysis shows that you may be interested in certain services, we may customize our newsletters and Website with content that is relevant to you. We may use different channels for our marketing communications, such as emails, social media, and your personal online account during different time frames and in recurrent manner.
  
• To initiate and evaluate business relationships. Your personal data will be processed for the entering into agreements and the performance thereof to the point of commercial services and the managing of the business relations which emerge from them, including the performance of activities aimed at the expansion of our client database.

‍

Vive Invest is allowed to process personal data for this purpose because you gave consent or because Vive Invest has a legitimate interest. The consent can be withdrawn at any moment, and you can object at any moment to the processing of your personal data for direct marketing purposes. The withdrawal of consent or exercise of your right to object does not affect the lawfulness of the processing prior to the moment of withdrawal or exercise of the right to object.

You may object or revoke your consent for receiving marketing communications at any time, by following the instructions in the relevant marketing communication or by sending an email to privacy@viveapp.com

Legitimate and legal interests

In many cases, we are legally required to store certain data about you, for example to verify your identity, for research and to create personalized investment plans.

We can also process certain data when we have a legitimate interest to do so. For example, to prevent and combat misuse, to research and analyze the use of our products and services for marketing purposes, for information and system security or to share certain data with governmental institutions.

Disclosing or sharing data with third parties

General

We reserve the right to release personal information without your consent or without consulting you, when we deem it necessary to comply with our legal obligations, to enforce our terms and conditions, to protect the security of our Website and application, or to prevent fraud.

To be able to provide our services, we share certain personal data with third parties. We keep the sharing to a minimum and ensure these third parties will handle your personal data with the same care as we do. This means, among other things, we sign Data Processing Agreements. The third parties or categories of third parties with whom we share data are: Auth0, Onfido Limited, Online Payment Platform, Pipedrive, and Twilio.

Governmental institutions

To comply with laws and regulations we can share data with the concerned institutions. For example, the Tax Authorities can request financial data and we can share data with the Dutch Central Bank for participating in the Deposit Guarantee Scheme. Next to this, Vive Invest can have a statutory or legal obligation to share personal data with investigating authorities to prevent and combat misuse, fraud and crimes.

Security and retention

Vive Invest takes the safeguarding of your information very seriously. Vive Invest will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use. These measures include but are not limited to: facilities protected by appropriate security measures, encryption of devices, version tracking and access to our databases is limited to key personnel and IP addresses and use of it is logged. Personal identifiable information and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password.

How long we keep your personal data

We will hold all the data for so long as we have an obligation to the Customer to provide the Services, and thereafter until such time as we delete the Customer's account in accordance with our Customer Terms and Conditions.

Your personal information will be deleted on one of the following occurrences: - deletion of your personal information by you (or by another person engaged by the Customer); or - receipt of a written request by you (or another person engaged by the Customer) to us

For a large amount of data, we are legally obliged to retain this for a minimum of 5 to 7 years after ending the customer relationship. After this period, we don't store your personal data longer than legally allowed and no longer than necessary for the purposes the data was collected for.

We are able to store personal data for longer periods with a valid legal ground, or when the data is sufficiently (for example) pseudonymised or anonymised.

Your Rights

You can request access to or a copy of your personal data collected by us. You may also request the rectification and removal of personal data or the restriction of the processing of your personal data, if there is a reason for doing so. You also have the right to data portability. You also have the right to object to a processing on grounds relating to your particular situation or against the processing of your personal data for direct marketing purposes. More information on your rights is available at: https://autoriteitpersoonsgegevens.nl.

To exercise your right(s), please send us an email at privacy@viveapp.com or mail us: VIVE Invest B.V., Keizersgracht 203, 1016 DS Amsterdam, The Netherlands.

Revoking & limiting consent

When you have provided us with permission to process personal data, or when we process your personal data based on legitimate interests, you are able to revoke this permission in an easy manner or ask us to limit the use of your data. Revoking your permissions does not mean that stored data is deleted.

Direct marketing & usage data

If you do not want your data to be used for direct marketing activities and analysis of the usage of our products and services, you can let us know via the VIVE app anytime. Next to this, our communication via email contains the possibility to unsubscribe from these messages.

GPS and image and content access

While using the VIVE app, you can provide permission to process location data. If you no longer want us to use location data, you can revoke these permissions easily. This permission is also offering the possibility to protect your account, sending, for example, notifications when there is a login from an unknown location. You'll find these settings in the VIVE app. You can revoke provided permissions at any given moment.

Images and content that you use to personalise your VIVE account can be easily changed in the VIVE app.

Cookies

For more information on how to delete cookies, please see our Cookie Statement.

Modifications to this Policy

This Policy is effective as of 23 of October 2018. We reserve the right to alter or otherwise make changes to this Policy. Notices may be by email to the last email address you provided us, by posting notice of such change on our Site or the Optimizely Service, or by other communication channels. You consent to receiving notices in these ways. We reserve the right to determine the form and means of providing notifications to you, consistent with applicable law. Changes take effect as soon as the Policy is posted.

Questions or complaints

If you have any question or complaints about the processing, please send an email to us at privacy@viveapp.com . If you feel that your rights have been violated, you may also make a complaint with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl). For more information on the protection of personal data, please consult the website of the Autoriteit Persoonsgegevens.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@viveapp.com

General

VIVE Invest B.V. (Chamber of Commerce 62098896), in the rest of this document referred to as Vive Invest, hereby grants you access to www.viveapp.com and all of our VIVE Invest B.V. websites where it publishes texts, images and other materials which have been supplied by Vive Invest and others.

Vive Invest retains the right to alter the contents of the Website and mobile application or remove material without having to notify you at any point in time about such changes. The information and materials on the Website and mobile application are provided “as is” and cannot be considered an offer of services or a contract proposal. Contracts and services are only established by the acceptance of duly indicated quotations or offers by Vive Invest.

Liability

Although for the content of this Website and our mobile application great care has been taken, Vive Invest shall never be liable for losses or other damages that may result from inaccuracy or incompleteness of information on this Website and/or its mobile application. The materials on the Website and our mobile application are offered without any warranties, expressed or implied, and without any claims as to their accuracy. These materials can be subject to change at any given time without prior notification from Vive Invest. Especially all sums, prices and fees on the Website and mobile application are provided with reservation of type-, conversion-, and programming errors.

For the consequences of such errors no liability is acknowledged or accepted by Vive Invest. No agreement or contract with Vive Invest is established based on such errors. Studying the contents of this Website and/or our mobile application, signing up for newsletters or to send information requests can not cause any kind of relationship between Vive Invest and the receiver of the information.

This website may contain links to other websites. Vive Invest has no control over the content of those other sites and is not responsible for the content of those websites or other links to other websites. Transmission of web forms or other communications to Vive Invest without encryption or other secure means of communication and shall always be for the risk of the sender.

Intellectual Property Rights

This website contains information, data, software, photos, graphics and other materials protected by copyright, trademark or other proprietary rights. The content on this Website and our mobile application may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or exploited in any manner without the express prior written consent of Vive Invest. All intellectual property rights with regards to these materials offered and available on the Website and our mobile application are the property of Vive Invest and its licensors. All intellectual property rights relating to this Website, including software, text, photographs, images and / or sounds are owned by us and / or the person from whom we have obtained a license.