This document (the “Offer”, the “Terms”, the “Agreement”) is a public offer within the meaning of paragraph 2 of Article 437 of the Civil Code of the Russian Federation (the “Civil Code”) and is addressed to any legally capable individual. The Offer sets out the terms of use of the SmartFin service, including the terms on which paid access to extended features is provided.
The Offer is made by the individual Иванов Георгий Александрович (INN 645392361077), who applies the special tax regime “Tax on Professional Income” (the “Operator”, “we”). A person who accepts the Offer is referred to below as the “User”, “you”.
Acceptance of the Offer. As regards free use of the Service, the Offer is deemed accepted from the moment you register an account or sign in to the Service. As regards the Plus Plan, the Offer is deemed accepted from the moment the Subscription is paid for (paragraph 3 of Article 438 of the Civil Code). Acceptance means that you have read the Offer in full and accept its terms without reservation. If you do not agree with any provision of the Offer, do not use the Service.
1. Terms and Definitions
- Service (SmartFin) — a software and hardware system available at smartfinai.app and through its related subdomains and applications, providing portfolio aggregation and analytics features.
- Account — the set of User data that identifies the User and provides access to the Service’s features.
- Personal Area — the section of the Service available to the User after signing in to the Account, including account settings and Subscription management.
- Connected Source — a brokerage account, a custodian (depositary) account, a cryptocurrency exchange, a wallet or another data source that the User voluntarily connects to the Service, including by means of API keys (access tokens), or whose data the User enters manually.
- User Content — any data posted or entered by the User in the Service, including information on portfolio composition, transactions and assets.
- Trial Period — 30 (thirty) calendar days from the date the account is registered, during which the Service features listed in paragraph 9.1 of the Offer are available to the User free of charge. It is granted once; linking a bank card is not required.
- Plus Plan — a paid service providing access to the Service’s extended features listed in Section 9 of the Offer for the duration of a Billing Period.
- Subscription — paid access to the Plus Plan for one or more consecutive Billing Periods.
- Billing Period — the paid term of the Plus Plan: one month (monthly Subscription) or twelve months (annual Subscription).
- Auto-renewal — automatic renewal of the Subscription for the next Billing Period, with its cost charged to the User’s bank card on the basis of the User’s prior consent (a recurring payment).
- Payment Service — OOO ROBOKASSA (the Robokassa service), which handles the acceptance of payments, Auto-renewal and refunds of funds in favour of the Operator.
2. Subject Matter of the Agreement and Nature of the Service
The Service allows the User to combine, in a single interface, information about the User’s investment and financial assets from various sources, to view analytics, visualisation and the historical dynamics of portfolio value, and to use auxiliary features, including features based on artificial intelligence technologies.
Under this Offer the Operator provides the User with access to the Service features during the Trial Period free of charge, and access to the Plus Plan features for a fee on the terms of Sections 9–11 of the Offer (a contract for the provision of services for a fee). The Plus Plan service is deemed to be provided continuously throughout the Billing Period from the moment access is activated.
Information on asset prices and other market data may come from external sources, may be delayed, may contain inaccuracies and is not intended to be used for executing transactions in real time.
3. Registration and Account
- To use the Service’s main features you must create an account by providing an e-mail address and a password, or by signing in with Google.
- The Service is intended for persons aged 18 or over who have full legal capacity. By registering and paying for the Subscription, you confirm that you meet this requirement.
- The Operator may require confirmation of your e-mail address; until it is confirmed, access to some features, including taking out a Subscription, may be restricted.
- You undertake to provide accurate data and keep it up to date. The e-mail address of your account is used to send receipts, notices of Auto-renewal and other legally significant messages.
- You are solely responsible for keeping your password safe and for all actions performed using your account. Any unauthorised access must be reported to the Operator immediately.
4. Connecting Brokerage Accounts and Crypto Exchanges
The Service allows you to connect external data sources (including T-Bank Investments, Finam, BCS, and the cryptocurrency exchanges Binance, Bybit, OKX and others) in order to load information on portfolio composition automatically.
- Connection is voluntary and is initiated by the User by providing API keys (tokens) or other access issued by the relevant provider.
- It is strongly recommended to use tokens with the minimum necessary permissions, preferably “read-only”, and not to grant the Service rights to withdraw funds or execute transactions.
- By connecting a source, you confirm that you are entitled to do so and that such a connection does not breach the terms of your agreement with the relevant provider.
- The Operator does not manage your assets, does not execute transactions and has no access to your funds. How the tokens you provide are stored and protected is described in the Personal Data Processing Policy.
- You may revoke access at any time by disconnecting the source in the Service and/or revoking the token on the provider’s side.
5. Rights and Obligations of the User
The User undertakes:
- to use the Service in accordance with these Terms and the legislation of the Russian Federation;
- not to take actions that impair the operation or security of the Service or the rights of third parties;
- not to access the Service by automated means bypassing the standard interfaces, and not to carry out unauthorised copying, decompilation or load testing;
- not to transfer access to the User’s account, including one with a paid Plus Plan, to third parties;
- not to use the Service to post unlawful information, and not to impersonate another person;
- to back up independently any data that is important to the User.
The User is entitled to use the Service’s features within the scope of the User’s plan, to contact the support service, and at any time to cancel Auto-renewal and cancel the Subscription in the manner provided in Section 11 of the Offer.
6. Rights and Obligations of the Operator
- The Operator provides access to the Service in the form in which it exists at the time of provision and takes reasonable measures to ensure its availability and security, but does not guarantee uninterrupted or error-free operation.
- The Operator may develop the Service, change and supplement its features, and carry out maintenance and preventive work. The set of Plus Plan features may not be degraded during a Billing Period that has already been paid for. If such a degradation nevertheless occurs, the User may cancel the Subscription and receive a refund for the unused part of the Billing Period without any deductions.
- The Operator may suspend or terminate the User’s access if these Terms or legal requirements are breached or if there are signs of a security threat. Where access to the Plus Plan is terminated on this ground, the refund for the unused part of the Billing Period is made in accordance with paragraph 11.3 of the Offer.
- The Operator is obliged to provide the Plus Plan services throughout the paid Billing Period, to send the User the receipts and notices provided for by the Offer, and to consider enquiries within the time limits established by law.
7. Artificial Intelligence Features
The Service may provide an AI assistant and other features that generate responses and analytics using machine learning technologies, including through third-party providers of such technologies. Such features may contain inaccuracies and should not be regarded as professional financial, legal or tax advice. Requests sent to these features may be passed to the provider of the relevant technology for processing — see the Personal Data Processing Policy for details.
8. Intellectual Property
The exclusive rights to the Service, its source code, design, interfaces, trademarks and other elements belong to the Operator or are used by it on a lawful basis. These Terms do not grant the User any rights to these objects other than the right to use the Service for its intended purpose. User Content remains the User’s property; by providing data, the User grants the Operator a limited licence to process it to the extent necessary for the Service to function.
9. Plans and Pricing
9.1. Trial Period (free of charge)
Includes portfolio aggregation from connected sources and manual entry, portfolio analytics (value, returns, risk, asset allocation), alerts and summaries, basic company research features, and also the AI assistant and explanations of portfolio changes with a daily limit on the number of requests. The current limits are shown in the Service interface.
9.2. Plus Plan (paid)
Includes all Trial Period features, as well as:
- the AI assistant and explanations of portfolio changes without a daily limit on the number of requests (subject to paragraph 9.4);
- a weekly AI digest for the portfolio;
- comparison of a company with peer companies;
- company valuation by the discounted cash flow (DCF) method and scenario modelling;
- generation of an investment thesis for a company;
- in-depth AI analysis of issuers’ financial statements.
9.3. Cost of the Plus Plan
- monthly Subscription — RUB 299 per month;
- annual Subscription — RUB 2,490 for twelve months.
Prices are stated in Russian roubles. VAT is not charged: the Operator applies the special tax regime “Tax on Professional Income” (Federal Law No. 422-FZ of 27 November 2018). The current prices are also shown on the Service’s home page and on the Subscription checkout page; in the event of a discrepancy, the price shown on the checkout page at the time of payment applies.
9.4. Fair Use
The Plus Plan features without daily limits are provided for personal, non-commercial use. The Operator may temporarily limit the request rate if it clearly exceeds ordinary personal use (including in the case of automated requests or the transfer of access to third parties), having first notified the User.
9.5. After the Trial Period. When the Trial Period ends, and when a paid Subscription ends without being renewed, the Service features are available only with an active Subscription to the Plus Plan. Until one is taken out, only the Subscription checkout page is available to the User; the account data is retained. Deleting the account, disconnecting connected sources, the Service’s legal documents and contacting support nevertheless remain available to the User.
9.6. Deletion of data. If no Subscription is taken out within 6 (six) months of the end of the Trial Period or of the last paid Subscription, the Operator deletes the account and all data associated with it (portfolios, connected sources, transaction history). No later than 14 (fourteen) calendar days before the deletion, the Operator sends the User a notice by e-mail. Deleted data cannot be restored.
9.7. Accounts created before payments are accepted. For Users registered before the date on which the Service begins accepting payments, the Trial Period begins on that date. The Operator notifies such Users of that date by e-mail no later than 14 (fourteen) calendar days in advance.
10. Payment Procedure and Auto-renewal
10.1. The Plus Plan is paid for by non-cash payment through the Payment Service by bank card or by other methods available on the payment page. The bank card details are entered on the Payment Service’s secure page; the Operator does not receive or store the full card number, its expiry date or the CVC/CVV code.
10.2. When taking out a Subscription, the User selects the Billing Period and confirms agreement with the Offer and, when paying by bank card, also consent to Auto-renewal by ticking the corresponding box. The box is not ticked by default.
10.3. The User’s payment obligation is deemed fulfilled from the moment the Operator receives confirmation of payment from the Payment Service. Access to the Plus Plan is activated automatically, as a rule within a few minutes of payment. If access is not activated within 24 hours, the User should use the contact details in Section 17.
10.4. The Billing Period runs from the date access is activated. A monthly period ends on the corresponding day of the following month, an annual period on the corresponding day of the month twelve months later; if the month in which the period ends has no corresponding day, the period ends on the last day of that month.
10.5. Where payment is made by bank card with consent to Auto-renewal, at the end of each Billing Period the Subscription is renewed for the same period and its cost is charged to the linked card. The amount charged equals the cost of the Billing Period applicable to the User under paragraph 10.8.
10.6. No later than 3 (three) calendar days before each charge, the Operator sends a notice to the e-mail address of the account stating the amount and date of the charge and how to cancel Auto-renewal.
10.7. If a charge fails (including because of insufficient funds), the Operator may retry within 3 (three) calendar days. If the retries are unsuccessful, access to the Plus Plan ends and paragraph 9.5 of the Offer applies; the User’s data is retained as set out in paragraph 9.6. The User incurs no debt for the unpaid period.
10.8. The Operator notifies Users with an active Subscription of a change in the price of the Plus Plan no later than 30 (thirty) calendar days before the date of the next charge. The price of a Billing Period that has already been paid for does not change. The new price applies to an active Subscription only with the User’s consent given in the Personal Area; without consent, Auto-renewal ends when the paid Billing Period expires.
10.9. A receipt is generated in accordance with Federal Law No. 422-FZ of 27 November 2018 for every payment, including Auto-renewal payments, and is sent to the User’s e-mail address. When funds are refunded, the receipt is corrected in the manner established by the same law.
11. Cancelling Auto-renewal, Cancelling the Subscription and Refunds
11.1. Cancelling Auto-renewal. The User may at any time cancel Auto-renewal and delete the linked bank card in the Personal Area (the Subscription management section) without contacting support, or by sending a message to the Operator’s e-mail address from the e-mail address of the User’s account. After receiving the cancellation, the Operator does not use the User’s card data for further charges (Article 16.1 of the Law of the Russian Federation “On the Protection of Consumer Rights”).
11.2. Access after Auto-renewal is cancelled. Cancelling Auto-renewal does not terminate the current Subscription: access to the Plus Plan is retained in full until the paid Billing Period ends, after which paragraph 9.5 of the Offer applies. Because the service continues to be provided until the end of the paid Billing Period, cancelling Auto-renewal does not in itself give grounds for a refund for that period.
11.3. Cancelling the Subscription with termination of access. The User may at any time withdraw from the contract in respect of the paid Billing Period (Article 32 of the Law “On the Protection of Consumer Rights”, Article 782 of the Civil Code) by sending an application to the Operator’s e-mail address from the e-mail address of the User’s account. In that case access to the Plus Plan ends on the day the application is received, and the Operator refunds the part of the cost of the Billing Period proportionate to the number of full calendar days remaining until its end, less the expenses actually incurred by the Operator and supported by documents in connection with performing the contract, including the Payment Service’s fee for processing the payment and the refund.
11.4. What is not refunded. The cost of the elapsed part of the Billing Period during which access to the Plus Plan was provided is not refundable, because the service has been rendered for that time. The cost of Billing Periods that expired before the application was received is likewise not refundable.
11.5. Full refund. Funds are refunded in full, without deductions, in the following cases: an erroneous or duplicate charge; a charge made after Auto-renewal was cancelled or the card was deleted; or where paid access to the Plus Plan was not provided for reasons attributable to the Operator.
11.6. Time limit and method of refund. The refund is made within 10 (ten) calendar days of the date the application is received (Article 31 of the Law “On the Protection of Consumer Rights”) by the same method as the payment, as a rule to the same bank card. The time it takes for the funds to be credited to the account depends on the bank that issued the card.
11.7. The provisions of this Section do not limit the User’s rights as a consumer provided for by the legislation of the Russian Federation, including rights where a service of inadequate quality is provided (Articles 28 and 29 of the Law “On the Protection of Consumer Rights”).
12. Limitation of Liability
To the extent permitted by the legislation of the Russian Federation, the Operator is not liable for:
- investment and financial decisions made by the User on the basis of information from the Service, and their consequences;
- the accuracy, completeness and timeliness of market data and of information received from connected sources and external providers;
- losses arising from the unavailability of the Service, technical failures, the actions of third parties, or the User’s loss of access to the account through no fault of the Operator;
- the actions of the providers of connected sources, banks and the Payment Service.
The Service does not replace the official reporting of brokers, exchanges and other organisations; in the event of discrepancies, the data of the relevant provider takes precedence. This Section does not limit the Operator’s liability to a consumer where such liability cannot be limited by law.
Force majeure. The parties are released from liability for the failure to perform or the improper performance of obligations if it is caused by force majeure (Article 401(3) of the Civil Code of the Russian Federation) — natural disasters, epidemics, hostilities, acts of public authorities, mass failures of communication networks and power supply. A party affected by such circumstances notifies the other party by e-mail within a reasonable time. If the circumstances last more than 60 calendar days, either party may withdraw from the contract; the fee for the unused period of the Subscription is refunded pro rata.
13. Personal Data
The User’s personal data is processed in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and the Personal Data Processing Policy available at smartfinai.app/legal/privacy. By accepting these Terms, you confirm that you have read the Policy.
14. Amendment of the Terms
The Operator may amend these Terms. The new version takes effect from the moment it is posted in the Service unless another date is specified; Users with an active Subscription are notified by e-mail of changes affecting paid services. The changes do not apply to Billing Periods that have already been paid for, and a change in the price of the Plus Plan applies only in the manner provided in paragraph 10.8. Continued use of the Service after the changes take effect constitutes acceptance of them.
15. Term and Termination
The Agreement is in force from the moment of acceptance until the User stops using the Service. The User may at any time stop using the Service and initiate deletion of the account through the Service interface or by contacting the Operator. Deleting an account while a Subscription is active constitutes cancellation of the Subscription: Auto-renewal ends, and the refund for the unused part of the Billing Period is made in accordance with paragraph 11.3 on the User’s application sent from the e-mail address of the deleted account. Termination of the Agreement does not release the parties from obligations that arose before its termination.
16. Governing Law, Claims and Disputes
The law of the Russian Federation applies to these Terms and to the relations of the parties. Claims, including demands for the refund of funds, are sent to the Operator’s e-mail address. Demands for the refund of funds are considered within 10 (ten) calendar days, and other enquiries within 30 (thirty) calendar days of receipt. The parties seek to settle disputes by negotiation; a User who is a consumer may apply to a court in accordance with the jurisdiction established by Article 17 of the Law of the Russian Federation “On the Protection of Consumer Rights”.
17. Operator’s Details and Contact Information
- Operator: Иванов Георгий Александрович
- Status: an individual — a payer of the tax on professional income (self-employed)
- INN (taxpayer identification number): 645392361077
- Telephone: +7 987 359-33-53
- E-mail for enquiries, claims and refund applications: ivanovgeorgiy000@gmail.com
- Website: smartfinai.app