Effective date: 02/10/2026

These Terms of Service (“Terms”) govern access to and use of the PoMaTo website, platform, software, documentation and related services (“Service”) provided by PoMaTo Ltd, a company registered in England and Wales under company number 16524543 with registered office at 171 Ballards Lane, London, England, N3 1LP.

By creating an account or otherwise accepting these Terms through the Service, you agree to them. If you use PoMaTo on behalf of an organisation, you confirm that you have authority to bind that organisation.

PoMaTo provides cloud-based portfolio-management workflow software. Depending on the subscription and enabled features, the Service may include research and investment intelligence, portfolio analysis, portfolio construction and optimisation, risk and compliance workflow tools, implementation preparation, broker connectivity, reconciliation, performance analysis and reporting.

PoMaTo is a technology provider and is not currently authorised or regulated by the Financial Conduct Authority. PoMaTo does not hold client money, custody financial instruments or exercise discretionary authority over brokerage accounts.

PoMaTo does not provide personalised investment advice. Analytical models, scores, rankings, estimates, target allocations, optimisations and other outputs are computational tools and information for users to evaluate within their own investment process.

You retain sole responsibility for investment decisions. You are responsible for selecting or approving the investment universe, assumptions, objectives, data, parameters, constraints and other inputs relevant to your use of the Service, and for deciding whether to implement, modify or disregard any resulting output.

Where brokerage connectivity is enabled, you may connect an eligible account through a third-party connectivity provider such as SnapTrade. You remain the account owner or duly authorised user and are responsible for maintaining the brokerage relationship.

PoMaTo provides the technical interface through which you may formulate, review and communicate your own transaction instructions through the relevant connectivity provider to your connected broker. PoMaTo does not independently initiate, determine or alter a transaction without your authority.

Before a trade-enabled instruction is communicated, you must review the available transaction details and expressly confirm the instruction. You are responsible for verifying the security, account, side, quantity or notional, order type, price or limit information and any available fee or impact information.

Your connected broker, not PoMaTo, is responsible for accepting, rejecting and executing an order. An instruction may fail, be delayed, be partially filled or be executed at a different price from an estimate because of market conditions, broker rules, connectivity, liquidity, account restrictions or other factors.

Third-party services are subject to their own terms, privacy notices, availability and eligibility criteria. Where required, you must separately accept the terms of SnapTrade or another connectivity provider. PoMaTo is not responsible for the acts or omissions of an independent broker, custodian, market-data provider or connectivity provider except to the extent that liability cannot lawfully be excluded.

PoMaTo does not receive, hold or safeguard your cash or investments. Assets remain with the broker or custodian with whom you maintain the relevant account.

PoMaTo may allow users to configure investment rules, limits, pre-trade checks or post-trade monitoring. These are workflow tools. You are responsible for determining which rules apply to your organisation or portfolio, configuring them correctly, reviewing alerts and deciding what action to take. Use of the Service does not replace your own legal, regulatory, fiduciary or compliance obligations.

· Third-party data may be delayed, incomplete, incorrect or unavailable.

· Model estimates and optimisation outputs depend on assumptions, methodologies and input data and may change materially.

· Backtests and scenarios are hypothetical unless expressly stated otherwise.

· Past or modelled performance is not a reliable indicator of future results.

· The Service cannot eliminate market, liquidity, operational, counterparty, model or technology risk.

You must provide accurate registration information, keep credentials confidential, use appropriate security controls and promptly notify PoMaTo of suspected unauthorised use. You are responsible for activity performed by authorised users within your workspace.

· Do not use the Service unlawfully or to infringe third-party rights.

· Do not attempt to bypass security, usage limits or access controls.

· Do not introduce malware or interfere with operation of the Service.

· Do not use another person's brokerage account or data without authority.

· Do not misrepresent PoMaTo as providing regulated advice, discretionary management, custody or brokerage services.

Fees, billing frequency, trial terms and plan limits are shown during subscription or agreed in an order form. Unless otherwise stated, fees for independent brokers, custodians, market-data or third-party connectivity services are separate. Applicable taxes may be added where required.

PoMaTo and its licensors retain all rights in the Service, software, models, methodologies, documentation, branding and other protected materials. Subject to payment and compliance with these Terms, PoMaTo grants you a limited, non-exclusive, non-transferable right to use the Service for your permitted internal purposes during the subscription.

As between you and PoMaTo, you retain your rights in data you lawfully upload or provide to the Service. You authorise PoMaTo to process that data as necessary to provide, secure, support and improve the Service and as described in the Privacy Policy.

We aim to provide a reliable service but do not guarantee uninterrupted availability. Features may depend on third-party systems and may be changed, suspended or withdrawn where reasonably necessary for security, legal, technical or product reasons. Material changes affecting paid functionality will be handled in accordance with applicable law and contractual commitments.

Investing involves risk. The value of investments can fall as well as rise and you may get back less than you invest. Orders may experience price movement, slippage, delay, rejection, partial execution or other execution risk. You remain responsible for assessing investment and transaction risk.

Nothing in these Terms excludes or limits liability that cannot lawfully be excluded, including liability for fraud or fraudulent misrepresentation, or death or personal injury caused by negligence where applicable.

Subject to the preceding sentence and any consumer rights that apply, PoMaTo is not responsible for investment losses arising solely from market movements or a user's investment decision, or for failures caused by independent brokers, custodians, market-data providers or connectivity providers outside PoMaTo's reasonable control.

If you are a consumer, nothing in these Terms affects rights that cannot be excluded under applicable consumer law. Any cancellation or refund rights that apply to your subscription will be provided during the purchase process.

You may terminate in accordance with your subscription or order form. PoMaTo may suspend access where reasonably necessary for security, suspected unlawful use, material breach or non-payment, subject to applicable law. On termination, brokerage connections should be disconnected and access to the Service will cease, subject to any export or retention rights expressly agreed.

Personal data is processed in accordance with the PoMaTo Privacy Policy and any applicable data-processing agreement.

These Terms are governed by the laws of England and Wales. For business customers, the courts of England and Wales have exclusive jurisdiction unless an order form states otherwise. Consumers retain any mandatory rights regarding jurisdiction under applicable law.

We may update these Terms where reasonably necessary. The current version will show its effective date. Where changes materially affect existing paid users, we will provide notice as required by law or contract.

PoMaTo Ltd, 171 Ballards Lane, London, England, N3 1LP. Company No. 16524543. Contact: https://thepomato.com/contact-us