COMPREHENSIVE WEBSITE TERMS OF USE, INVESTMENT DISCLAIMER, AND ELECTRONIC COMMUNICATIONS POLICY

FINISSIMO CAPITAL LLC

Version 2.0
Effective Date: September 15, 2025
Last Modified: September 15, 2025

PART ONE: WEBSITE TERMS OF USE

ARTICLE I: GENERAL PROVISIONS AND ACCEPTANCE

Section 1.1: Parties and Formation of Agreement

These Website Terms of Use, Investment Disclaimer and Risk Disclosures, and Electronic Communications and Technology Acceptable Use Policy (collectively, the "Agreement") constitute a legally binding contract between Finissimo Capital LLC, a Delaware limited liability company with its principal place of business at 8 The Green, Dover, Delaware 19901, United States of America ("Finissimo Capital," "Company," "we," "us," or "our"), and you, the individual or entity accessing or using our website located at https://www.finissi.com (the "Website").

By accessing, browsing, or otherwise utilizing the Website, you affirmatively represent that you have read, understood, and agree to be bound by this Agreement in its entirety. If you are accessing the Website on behalf of an entity, you represent and warrant that you have full authority to bind such entity to this Agreement. If you do not agree to all provisions of this Agreement, you must immediately discontinue all access to and use of the Website.

Section 1.2: Modification and Amendment

The Company reserves the right, in its sole discretion, to modify, amend, or update this Agreement at any time. Material modifications will be indicated by updating the "Last Modified" date above and, where appropriate, providing notice through the Website interface or registered email addresses. Your continued use of the Website following any modifications constitutes your acceptance of the amended Agreement. You are responsible for regularly reviewing this Agreement to remain informed of any changes.

Section 1.3: Eligibility and Capacity Requirements

The Website is intended exclusively for users who satisfy the following criteria: (a) individuals who have attained the age of eighteen (18) years or the age of majority in their jurisdiction of residence, whichever is greater; (b) individuals and entities possessing full legal capacity to enter into binding contracts under applicable law; (c) individuals and entities not prohibited from accessing the Website under applicable sanctions, export control regulations, or other legal restrictions; and (d) individuals and entities accessing the Website from jurisdictions where such access is lawful.

By accessing the Website, you represent and warrant that you meet all eligibility requirements and that all registration information you submit is accurate, current, and complete. You further covenant to maintain the accuracy of such information throughout your use of the Website.

ARTICLE II: INTELLECTUAL PROPERTY RIGHTS AND RESTRICTIONS

Section 2.1: Proprietary Rights

All content displayed, transmitted, or otherwise made available on the Website, including without limitation all text, graphics, logos, icons, images, audio clips, video content, data compilations, software code, algorithms, methodologies, processes, trade secrets, and documentation (collectively, "Proprietary Materials"), constitutes the exclusive property of Finissimo Capital or its third-party licensors and is protected under United States and international intellectual property laws, including copyright, trademark, patent, and trade secret protections.

The compilation, arrangement, and assembly of all content on the Website constitute the exclusive property of the Company and are protected by copyright laws. All software used on the Website is the property of the Company or its software suppliers and is protected by copyright laws.

Section 2.2: Limited License Grant

Subject to your strict compliance with this Agreement, the Company grants you a limited, revocable, non-exclusive, non-transferable, non-sublicensable license to access and view the Website and Proprietary Materials solely for your personal, non-commercial informational purposes. This license is conditioned upon your compliance with all terms and conditions set forth in this Agreement and automatically terminates upon any breach thereof.

This limited license expressly excludes, and you acknowledge that you have no right to: (a) reproduce, distribute, publicly display, or create derivative works from any Proprietary Materials except as expressly authorized; (b) reverse engineer, decompile, or disassemble any software or technology underlying the Website; (c) remove, obscure, or alter any proprietary notices or labels; (d) utilize any data mining, robots, spiders, or similar automated data gathering or extraction methods; (e) access the Website through any technology or means other than those provided or authorized by the Company; or (f) utilize the Website or Proprietary Materials for any commercial purpose without prior written authorization.

Section 2.3: User Submissions and Feedback

Any communications, feedback, suggestions, ideas, or other materials you submit to or through the Website ("User Submissions") shall be deemed non-confidential and non-proprietary. By submitting User Submissions, you grant the Company an irrevocable, perpetual, worldwide, royalty-free, fully sublicensable license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, and display such User Submissions in any media now known or hereafter developed.

You represent and warrant that you own or otherwise control all rights to your User Submissions and that such User Submissions do not violate any third-party rights or applicable laws.

ARTICLE III: PROHIBITED CONDUCT AND ACCEPTABLE USE

Section 3.1: Prohibited Activities

You agree not to engage in any of the following prohibited activities in connection with your use of the Website: (a) violating any applicable federal, state, local, or international law or regulation; (b) infringing upon or violating intellectual property rights or privacy rights of the Company or third parties; (c) transmitting any material that contains software viruses, trojan horses, worms, or any other computer code designed to interrupt, destroy, or limit functionality; (d) interfering with or disrupting the Website or servers or networks connected to the Website; (e) attempting to gain unauthorized access to any portion of the Website, other accounts, computer systems, or networks; (f) engaging in any activity that could disable, overburden, damage, or impair the Website; (g) using any manual or automated device, software, or routine to interfere with the proper working of the Website; (h) impersonating any person or entity or falsely stating or misrepresenting your affiliation with any person or entity; (i) collecting or storing personal data about other users without their express consent; or (j) engaging in any other conduct that, in the Company's sole discretion, restricts or inhibits anyone's use or enjoyment of the Website.

Section 3.2: Monitoring and Enforcement

The Company reserves the right, but assumes no obligation, to monitor the Website for violations of this Agreement. The Company may, in its sole discretion: (a) remove or refuse to post any User Submissions; (b) take any action with respect to User Submissions that it deems necessary or appropriate; (c) terminate or suspend your access to all or part of the Website for any or no reason; and (d) cooperate fully with any law enforcement authorities or court order requesting or directing the Company to disclose the identity or other information of users.

ARTICLE IV: THIRD-PARTY CONTENT AND INTERACTIONS

Section 4.1: Third-Party Websites and Resources

The Website may contain hyperlinks to websites, resources, or content controlled by parties other than the Company ("Third-Party Content"). Such links are provided solely as a convenience and do not constitute an endorsement, sponsorship, or recommendation by the Company of the Third-Party Content or the third parties operating such websites or resources.

The Company exercises no control over Third-Party Content and assumes no responsibility or liability for the accuracy, completeness, appropriateness, legality, or any other aspect of such content. Your interactions with third parties, including payment and delivery of goods or services, and any other terms, conditions, warranties, or representations associated with such dealings, are solely between you and such third parties.

Section 4.2: Framing and Linking Restrictions

You may not frame or utilize framing techniques to enclose any trademark, logo, or other Proprietary Materials without express written consent. You may not use any meta tags or any other "hidden text" utilizing the Company's name or trademarks without express written consent. Any unauthorized use automatically terminates the permissions and licenses granted under this Agreement.

PART TWO: INVESTMENT DISCLAIMER AND RISK DISCLOSURES

ARTICLE V: REGULATORY STATUS AND DISCLAIMERS

Section 5.1: Non-Regulated Entity Disclosure

CRITICAL NOTICE: Finissimo Capital LLC is not a registered investment adviser, broker-dealer, commodity trading advisor, commodity pool operator, futures commission merchant, investment company, or any other form of regulated financial services provider under the Investment Advisers Act of 1940, Securities Exchange Act of 1934, Investment Company Act of 1940, Commodity Exchange Act, or any comparable federal, state, or international legislation.

The Company does not hold any licenses, registrations, or authorizations from the Securities and Exchange Commission, Financial Industry Regulatory Authority, Commodity Futures Trading Commission, National Futures Association, or any state securities regulator or international regulatory authority. Any activities requiring regulatory authorization are conducted exclusively through our network of appropriately licensed and regulated third-party partners, each operating under their own regulatory framework and supervision.

Section 5.2: No Investment Advice or Recommendations

Nothing contained on the Website constitutes investment advice, financial advice, trading advice, or any other form of advice, and nothing on the Website should be construed as a recommendation to buy, sell, or hold any security, investment product, or financial instrument. The Company does not provide personalized investment recommendations or portfolio management services.

All information provided on the Website is for general informational and educational purposes only and should not be construed as a solicitation or offer to buy or sell any securities or related financial instruments. You should not rely on any information on the Website as the primary basis for your investment decisions. Past performance information presented on the Website, if any, is not indicative of future results.

Section 5.3: No Offer or Solicitation of Securities

The Website does not constitute an offer to sell or a solicitation of an offer to buy any securities, investment products, or interests in any jurisdiction where such offer or solicitation would be unlawful. Any securities or investment opportunities mentioned on the Website, if any, have not been registered under the Securities Act of 1933 or qualified under any state securities laws and may not be offered or sold except pursuant to an exemption from, or in a transaction not subject to, registration requirements.

Section 5.4: Sophisticated Investor Acknowledgment

By accessing any investment-related content on the Website, you acknowledge that you are a sophisticated investor with sufficient knowledge and experience in financial and business matters to evaluate the merits and risks of any potential investment opportunities. You acknowledge that you have the financial ability to bear the economic risk of any investments, including the potential total loss of capital.

ARTICLE VI: COMPREHENSIVE RISK DISCLOSURES

Section 6.1: General Investment Risks

Investing in any financial instruments or business ventures involves substantial risk of loss that you should carefully consider before making any investment decision. Investment risks include, but are not limited to: complete loss of principal; lack of liquidity and inability to sell or exit investments; market volatility and fluctuations in value; regulatory changes affecting investment value or legality; currency exchange rate fluctuations for international investments; concentration risk from lack of diversification; counterparty risk and potential defaults; operational risks from business execution failures; and technology risks including cybersecurity breaches and system failures.

Section 6.2: Private Investment Specific Risks

Information regarding private investments, if presented on the Website, involves additional unique risks including: extreme illiquidity with no established secondary market; long investment horizons often exceeding ten years; limited transparency and information rights; dependence on key personnel and management teams; use of leverage potentially amplifying losses; complex fee structures reducing net returns; limited or no regulatory oversight; potential conflicts of interest; and difficulty in valuation with no readily ascertainable market value.

Section 6.3: International Investment Risks

Any international investment considerations involve additional risks including: political instability and regime changes; differences in accounting, auditing, and financial reporting standards; foreign exchange controls and currency devaluation; expropriation, confiscation, or nationalization of assets; changes in foreign tax laws and potential double taxation; reduced legal protections and enforcement challenges; cultural and language barriers affecting business operations; and economic sanctions or trade restrictions.

Section 6.4: No Guarantee of Results

The Company makes no representations or warranties regarding the potential success, profitability, or suitability of any investment strategies, opportunities, or information presented on the Website. All investments involve risk, and you may lose some or all of your invested capital. No information on the Website should be interpreted as a guarantee or promise of future performance or results.

ARTICLE VII: INDEMNIFICATION AND LIMITATION OF LIABILITY

Section 7.1: Comprehensive Indemnification

You agree to indemnify, defend, and hold harmless Finissimo Capital, its affiliates, subsidiaries, and their respective officers, directors, members, managers, employees, agents, representatives, successors, and assigns from and against any and all claims, demands, actions, damages, losses, costs, liabilities, and expenses (including reasonable attorneys' fees and expert witness fees) arising out of or relating to: (a) your use or misuse of the Website; (b) your breach or alleged breach of this Agreement; (c) your violation of any applicable law, regulation, or third-party right; (d) any investment decisions or actions taken based on information obtained from the Website; (e) any User Submissions you provide; (f) your negligence or willful misconduct; or (g) any unauthorized use of the Website through your account.

Section 7.2: Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL FINISSIMO CAPITAL OR ITS AFFILIATES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING WITHOUT LIMITATION DAMAGES FOR LOST PROFITS, LOST REVENUES, LOST SAVINGS, LOSS OF GOODWILL, BUSINESS INTERRUPTION, LOSS OF DATA, OR ANY OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATING TO YOUR ACCESS TO OR USE OF, OR INABILITY TO ACCESS OR USE, THE WEBSITE, REGARDLESS OF THE FORM OF ACTION OR THE BASIS OF THE CLAIM, EVEN IF THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

The Company's total cumulative liability to you or any third party for any loss or damages resulting from any claims, demands, or actions arising out of or relating to this Agreement or your use of the Website shall not exceed one hundred dollars ($100.00).

PART THREE: ELECTRONIC COMMUNICATIONS AND TECHNOLOGY ACCEPTABLE USE POLICY

ARTICLE VIII: ELECTRONIC COMMUNICATIONS

Section 8.1: Consent to Electronic Communications

By using the Website and providing your email address or other contact information, you affirmatively consent to receive electronic communications from the Company. You agree that all agreements, notices, disclosures, and other communications provided to you electronically satisfy any legal requirement that such communications be in writing. Your consent to electronic communications includes, but is not limited to: (a) terms and conditions and policy updates; (b) transactional information regarding your use of the Website; (c) administrative messages and service announcements; and (d) where you have opted in, promotional communications and newsletters.

Section 8.2: Electronic Signature and Contract Formation

You acknowledge and agree that your electronic submission of information through the Website, including clicking "I Agree," "Submit," or similar buttons, constitutes your electronic signature and your intent to be bound by and to pay for any purchases or services, as applicable. You acknowledge that your electronic signatures have the same legal force and effect as manual signatures pursuant to the Electronic Signatures in Global and National Commerce Act, state enactments of the Uniform Electronic Transactions Act, and any applicable international electronic signature laws.

Section 8.3: Communications Security

While the Company implements commercially reasonable security measures, you acknowledge that electronic communications over the Internet are not completely secure. The Company does not guarantee the security, integrity, or confidentiality of any electronic communications. You assume all risks associated with the transmission of information to the Company through electronic means.

ARTICLE IX: TECHNOLOGY USE AND SECURITY

Section 9.1: Account Security

If the Website provides for user accounts, you are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You agree to: (a) immediately notify the Company of any unauthorized use of your account or any other breach of security; (b) ensure that you exit from your account at the end of each session; and (c) not share your account credentials with any third party.

Section 9.2: Security Measures and Protocols

You acknowledge that the Company has implemented technical and organizational security measures designed to protect the Website and its systems. You agree not to circumvent, disable, or otherwise interfere with any security-related features of the Website, including features that prevent or restrict use or copying of any content or enforce limitations on use of the Website.

Section 9.3: Data Mining and Automated Access

You may not engage in any automatic data collection activities, including but not limited to: (a) using any data mining, robots, spiders, scrapers, or similar data gathering or extraction methods; (b) accessing the Website through any automated means except as expressly permitted; (c) collecting or harvesting any personally identifiable information from the Website; or (d) using the Website for any data aggregation or analysis purposes without prior written consent.

ARTICLE X: PRIVACY AND DATA PROTECTION

Section 10.1: Privacy Policy Integration

Your use of the Website is governed by our separate Privacy Policy, which is incorporated herein by reference. The Privacy Policy describes how the Company collects, uses, shares, and protects information obtained from users of the Website. By using the Website, you consent to the practices described in the Privacy Policy.

Section 10.2: International Data Transfers

You acknowledge that the Company operates primarily from the United States and that your information may be transferred to, stored, and processed in the United States or other countries where the Company or its service providers maintain facilities. By using the Website, you consent to the transfer of your information to countries outside of your country of residence, which may have different data protection rules.

Section 10.3: Communications Preferences

You may opt out of receiving promotional electronic communications from the Company by following the unsubscribe instructions provided in such communications or by contacting us at the address specified below. Please note that even if you opt out of promotional communications, we may continue to send you non-promotional, transactional, or administrative messages.

ARTICLE XI: DISPUTE RESOLUTION AND GOVERNING LAW

Section 11.1: Governing Law and Jurisdiction

This Agreement and any dispute arising out of or relating to this Agreement or the Website shall be governed by and construed in accordance with the laws of the State of Delaware, United States of America, without regard to its conflict of law provisions. The United Nations Convention on Contracts for the International Sale of Goods shall not apply to this Agreement.

Section 11.2: Mandatory Arbitration

ANY DISPUTE, CONTROVERSY, OR CLAIM ARISING OUT OF OR RELATING TO THIS AGREEMENT OR THE WEBSITE SHALL BE RESOLVED EXCLUSIVELY THROUGH BINDING ARBITRATION ADMINISTERED BY JAMS PURSUANT TO ITS COMPREHENSIVE ARBITRATION RULES AND PROCEDURES. The arbitration shall be conducted in Wilmington, Delaware, before a single arbitrator with substantial experience in corporate and financial services law. The arbitrator's decision shall be final and binding, and judgment on the award may be entered in any court having jurisdiction thereof.

Section 11.3: Class Action Waiver

YOU AND THE COMPANY AGREE THAT ANY PROCEEDINGS TO RESOLVE DISPUTES WILL BE CONDUCTED SOLELY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION. You expressly waive any right to file a class action or seek relief on a class basis. If any court or arbitrator determines that the class action waiver is void or unenforceable, then the arbitration provision shall be deemed null and void, and the parties shall be deemed not to have agreed to arbitrate disputes.

Section 11.4: Equitable Relief Exception

Notwithstanding the arbitration provisions, either party may seek injunctive or other equitable relief in any court of competent jurisdiction to prevent the actual or threatened infringement, misappropriation, or violation of that party's copyrights, trademarks, trade secrets, patents, or other intellectual property rights.

ARTICLE XII: MISCELLANEOUS PROVISIONS

Section 12.1: Entire Agreement and Integration

This Agreement, together with the Privacy Policy and any supplemental terms, conditions, or policies posted on the Website, constitutes the entire agreement between you and Finissimo Capital concerning your use of the Website and supersedes all prior or contemporaneous agreements, representations, warranties, and understandings regarding the subject matter hereof.

Section 12.2: Severability and Reformation

If any provision of this Agreement is determined to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The invalid or unenforceable provision shall be deemed superseded by a valid, enforceable provision that most closely approximates the original intent of the parties.

Section 12.3: No Waiver

The failure of the Company to exercise or enforce any right or provision of this Agreement shall not constitute a waiver of such right or provision. Any waiver of any provision of this Agreement must be in writing and signed by an authorized representative of the Company to be effective.

Section 12.4: Assignment and Succession

You may not assign, delegate, or transfer this Agreement or any rights or obligations hereunder without the prior written consent of the Company. The Company may freely assign this Agreement without restriction. Subject to the foregoing, this Agreement shall bind and inure to the benefit of the parties and their respective successors and permitted assigns.

Section 12.5: Force Majeure

Neither party shall be liable for any failure or delay in performance under this Agreement arising out of or caused by acts of God, natural disasters, war, terrorism, epidemic, pandemic, labor disputes, governmental actions, or other causes beyond the reasonable control of such party, provided that such party uses reasonable efforts to remedy the situation and provides notice to the other party.

Section 12.6: Interpretation

The headings used in this Agreement are for convenience only and shall not be considered in interpreting this Agreement. As used in this Agreement, the words "include" and "including" are illustrative and not limitative. This Agreement shall be construed without regard to any presumption or rule requiring construction or interpretation against the party drafting or causing the document to be drafted.

Section 12.7: Survival

All provisions of this Agreement that by their nature should survive termination shall survive any termination or expiration of this Agreement or your use of the Website, including without limitation provisions regarding intellectual property, disclaimers, indemnification, limitations of liability, dispute resolution, and general provisions.

ARTICLE XIII: CONTACT INFORMATION

All notices, requests, and other communications under this Agreement should be directed to:

Finissimo Capital LLC
Legal Department
8 The Green
Dover, Delaware 19901
United States of America
Email: legal@finissi.com

For technical support or general inquiries, please contact: support@finissi.com

ACKNOWLEDGMENT AND ACCEPTANCE

BY ACCESSING OR USING THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS ENTIRE AGREEMENT, INCLUDING ALL DISCLAIMERS, LIMITATIONS OF LIABILITY, AND DISPUTE RESOLUTION PROVISIONS CONTAINED HEREIN. IF YOU DO NOT AGREE TO ALL TERMS OF THIS AGREEMENT, YOU MUST IMMEDIATELY DISCONTINUE USE OF THE WEBSITE.

Document Control Information:
Version: 2.0
Effective Date: September 15, 2025
Last Review: September 15, 2025
Next Scheduled Review: December 15, 2025
Document Owner: Legal Department
Classification: Public