User Agreement

Effective date: September 23, 2026

This is an English translation of the Russian-language User Agreement, provided for convenience. In the event of any discrepancy, the Russian version prevails.

This User Agreement (the "Agreement") governs the relationship between Limited Liability Company "Ural Tekhnokom" (OOO "Урал Техноком", OGRN 1206600007536, INN 6678106502, address: 62 Severnaya St., Apt. 19, Kamyshlov, Sverdlovsk Region, 624865, Russia; the "Company") and any individual (the "User") who uses the HADL software (the "Service"), including the web version at hadl.app, the iOS and Android mobile apps and related interfaces.

Registering with the Service, or using it without registration, constitutes the User's unconditional acceptance of this Agreement. If the User does not agree with any of its provisions, the User must stop using the Service.

1. Purpose of the Service

1.1. The Service is an analytical tool for the User's own investment record-keeping and for analysis of the User's own investment portfolio. Its features include: recording transactions in securities, currencies, crypto-assets and other assets that the User carries out on their own with their brokers, on exchanges and in other third-party services; calculating returns and tax liabilities; displaying dividend and coupon history; aggregating issuers' fundamental data; assessing diversification; analytical scoring models and other related functions.

1.2. The Service is not:

• a professional securities market participant. The Company holds no Bank of Russia licenses for brokerage, dealer, depository, securities management or investment advisory activities;
• a tool for carrying out transactions in securities, other financial instruments, currencies or crypto-assets. The Service only aggregates and visualizes data; transactions are carried out by the User on their own with their broker or in a third-party service of their choice;
• a crypto-asset (digital currency) service provider. The Service does not hold the User's crypto-assets or dispose of them, does not create wallets or hold their private keys, and is not an exchange, trading platform or currency exchange service. It does not exchange crypto-assets for funds or for other crypto-assets; does not receive, transmit or execute orders for transactions in crypto-assets; does not transfer crypto-assets; does not take part in their placement; does not manage crypto-asset portfolios; does not select crypto-assets and does not provide individual recommendations on them. In the Service, crypto-assets are solely an object of record-keeping: the Service displays information about transactions that the User carried out in third-party services;
• a source of individual investment recommendations ("IIR") within the meaning of Article 6.1 of Federal Law No. 39-FZ "On the Securities Market". Any reviews, ratings, scores and analytical conclusions published in the Service do not take into account the investment profile of a particular User and are not IIR.

1.3. The User makes all decisions to buy, sell or hold any assets independently, taking into account their own financial situation, investment goals, experience and acceptable level of risk.

1.4. Target portfolio allocations are set by the User, either manually or by accepting a proposal of the AI allocation feature. Rebalancing calculations (which assets to buy or sell, and in what quantity, to reach the target allocations) are arithmetic based on the User's own plan and are not a recommendation of the Company. The Service's artificial intelligence features are informational. They do not select crypto-assets and do not determine their share on their own: they keep the crypto-asset structure set by the User unchanged, and where there is none, they take the crypto-asset share from the User's instructions or keep the current one.

2. User Account

2.1. To access most features of the Service, the User creates an account with an e-mail address or through third-party authentication services (Apple ID, Google, Yandex). The information provided at registration must be accurate.

2.2. The User must keep their password and access tokens confidential. All actions performed in the Service using the User's login and password are deemed to have been performed by the User. If the User suspects that their credentials have been compromised, the User must notify support at support@hadl.app without delay.

2.3. When connecting broker and exchange integrations, the User provides the Service with personal API tokens (keys) for their accounts or with broker report files. The Service uses them for reading only: it retrieves information on transactions, balances and positions for synchronization and calculations in the User's interest. The Service does not carry out any transactions, transfers or withdrawals through these tokens, so read-only tokens are sufficient for connection. The processing of personal data is governed by a separate Personal Data Processing Policy.

2.4. The User may delete their account at any time in the settings. Deletion automatically terminates this Agreement and triggers deletion of the User's data within the periods set out in the Personal Data Processing Policy.

3. Data Sources

3.1. The Service aggregates financial information from public and partner sources: Russian and foreign exchanges, brokerage systems, market data providers and official regulators. The specific list of sources and the data obtained from them are the Company's trade secret and may change without separate notice to the User.

3.2. Data is provided "as is". Quotes, dividend and coupon history, fundamental data, inflation indices, key rates and other parameters may lag behind real time, be updated at intervals set by the source, contain errors of the source, or be missing for certain instruments and periods.

3.3. The Company does not own exchange and brokerage information, does not edit it and is not responsible for its content, completeness or timeliness. Before making investment decisions, the User is advised to verify key figures against primary sources.

3.4. Analytical scores, ratings and forecast indicators calculated by the Service (including the dividend attractiveness score, the portfolio health rating and the projected annual return) are derived from source data and the Company's models. They are indicative only and cannot serve as the sole basis for transactions.

4. Usage Analytics

4.1. To develop the Service, the Company collects anonymized usage statistics: which sections are visited, which features are used most often, on which screens errors occur, session duration and similar metrics. These statistics are processed in aggregate and do not allow a particular User to be identified.

4.2. Third-party analytics services (including AppMetrica and similar product analytics systems) are used to collect these statistics. The mobile apps may request the device advertising identifier (Apple IDFA on iOS, Google Advertising ID on Android) solely to match installs and sessions anonymously and to measure the effectiveness of marketing channels. Advertising identifiers are not used to show ads within the Service and are not shared with ad networks for targeting.

4.3. The User may disable the advertising identifier in the operating system settings (iOS or Android privacy settings). The Service will continue to work in full, although some analytics metrics will become less accurate.

4.4. Personal data collected while using the Service (e-mail, device identifiers, IP addresses, technical session data) is processed in accordance with the Personal Data Processing Policy and Federal Law No. 152-FZ "On Personal Data".

5. Paid Features

5.1. Some features of the Service are provided by subscription. Prices, billing periods, included features and payment terms are published in the "Plans" section and may change. The terms in effect at the time of payment apply to the period already paid for.

5.2. Payment is made in money through the payment providers available in the Service (CloudPayments, App Store, Google Play, RuStore and others). Crypto-assets and digital currency are not accepted as payment. Relations between the User and a payment provider are governed by the provider's own rules.

5.3. Refunds when the User cancels a subscription are made in accordance with the Law of the Russian Federation "On Protection of Consumer Rights" and the rules of the relevant payment provider. The Company does not compensate lost profits or any indirect losses related to the use of the Service.

5.4. The Company may grant certain categories of Users free access to paid features on terms determined solely by the Company (promotional periods, referral programs, test groups).

6. Rules of Use

6.1. The User may use the Service for personal, non-commercial purposes to keep records of their own investments and to analyze their own portfolio.

6.2. The User must not:

• carry out automated mass collection of information from the Service (scraping, parsing, export through unofficial APIs) unrelated to processing the User's own data;
• decompile or reverse engineer the Service, attempt to obtain its source code or circumvent its protection mechanisms;
• share credentials with third parties, let several people use one account, or circumvent the limits of the subscription plan;
• post in the Service false, offensive or extremist information, or information that violates laws on personal data, advertising, anti-money laundering or other applicable laws;
• use the Service in any way for market manipulation, dissemination of insider information or other actions prohibited by securities market legislation;
• resell, publish or otherwise distribute on a mass scale financial data obtained through the Service as a standalone information product.

6.3. Violation of clause 6.2 is grounds for blocking the User's account, refusing a refund for a paid but unused subscription period, and holding the User liable under the laws of the Russian Federation.

7. Intellectual Property

7.1. The Service's code, user interface, design, texts, the "HADL" logo, analytical models and scoring algorithms are the intellectual property of the Company. They may be used outside the Service only with the Company's written consent.

7.2. Data entered by the User (transactions, portfolios, target allocations, notes) remains the User's property. The Company processes it to the extent necessary to provide services under this Agreement.

7.3. Quotes, fundamental data, dividend histories and other primary financial information belong to the respective exchanges, brokers and other data providers. The Company is entitled to display them to the User on the terms set by the providers; the scope of these rights may be limited.

8. Limitation of Liability

8.1. The Service is provided "as is" and "as available". The Company takes reasonable measures to keep the Service operational and the displayed data accurate, but does not guarantee:

• uninterrupted operation of the Service or the absence of software errors;
• the safety and integrity of user data in the event of third-party actions or infrastructure failures;
• the accuracy, completeness and timeliness of data received from external providers and exchanges;
• that the Service meets the User's specific purposes, expectations and needs.

8.2. The Company is not liable for:

• the User's financial losses and lost profits arising from investment decisions made by the User;
• consequences of using the Service's analytical data as the sole basis for decisions;
• errors in data received from external sources (exchanges, brokers, market data providers, the Bank of Russia);
• temporary unavailability of the Service due to maintenance, actions of internet service providers, hosting providers or regulators, or force majeure.

8.3. The Company's total liability to the User on any grounds is limited to the amount the User paid for the subscription during the three (3) calendar months preceding the event giving rise to the claim. For Users who have not paid for a subscription, the Company's liability is limited to 1,000 (one thousand) rubles.

9. Changes to the Agreement

9.1. The Company may change the terms of this Agreement unilaterally. The current version is always available at docs.hadl.app/terms-of-use.

9.2. The Company notifies the User of material changes by any of the following means: a notice in the Service interface, an e-mail to the address provided at registration, or a push notification in the mobile app.

9.3. Continued use of the Service after a new version is published constitutes acceptance of it. If the User does not agree with the changes, the User may stop using the Service and delete their account.

10. Termination

10.1. The User may stop using the Service and delete their account at any time in the settings or by contacting support@hadl.app.

10.2. The Company may restrict, suspend or terminate the User's access to the Service without explanation and without a refund in the following cases:

• the User's violation of this Agreement;
• a justified blocking request from regulators, law enforcement agencies or payment providers;
• technical, legal or commercial impossibility of continuing to provide services to a particular User.

10.3. Termination of the Agreement does not release the User from obligations that arose earlier, including payment for services already rendered.

11. Governing Law and Dispute Resolution

11.1. This Agreement is governed by the laws of the Russian Federation.

11.2. Disputes between the parties are resolved through a mandatory pre-trial claim procedure. The response period for a claim is 30 (thirty) calendar days from its receipt. A claim is sent to support@hadl.app stating the substance of the claim and the User's contact details.

11.3. If a dispute is not resolved in the pre-trial procedure, it is subject to consideration by the court at the Company's location, unless otherwise established by mandatory consumer protection laws.

12. Contacts

Limited Liability Company "Ural Tekhnokom" (OOO "Урал Техноком") OGRN: 1206600007536 INN: 6678106502 Registered address: 62 Severnaya St., Apt. 19, Kamyshlov, Sverdlovsk Region, 624865, Russia

E-mail: support@hadl.app

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Use of the Service means that the User has read, understood and accepted this Agreement and the Personal Data Processing Policy.