Terms of Service

Version 2026-05-18 · MVP draft.

1. Roles

fintok is a software vendor. fintok provides the technology that displays tokenised bond products, captures investor onboarding data, and surfaces unsigned blockchain transactions for the relevant party to sign locally in their own wallet. fintok does not hold investor funds, does not custody investor wallet keys, does not execute blockchain transactions on behalf of investors or the issuer, and is not a party to any investment contract between investors and the issuer.

the bond issuer is the issuer of the tokens (the "Issuer"). The Issuer is the legal counterparty to every investment. Funds an investor wires for a primary-market purchase land directly in the Issuer's bank account; tokens are transferred from the Issuer's wallet to the investor's wallet through an on-chain transaction signed by the Issuer.

You (the investor) connect a self-custodial wallet, perform identity verification, accept these terms and the disclosures, and authorise on-chain transactions yourself from your wallet.

2. fintok is not a regulated provider

fintok is not a Pružalac usluga povezanih s digitalnom imovinom within the meaning of Article 3 of Zakon o digitalnoj imovini (Sl. glasnik RS 153/2020). The Issuer is the entity required to hold any applicable licence from the Republic of Serbia's Securities Commission and to publish the white paper (if required under Articles 17 + 19–25 of the same law).

3. Self-custody

Your wallet — whether created in-browser through fintok's embedded-wallet flow or connected via an external wallet extension — is yours. Only you hold the private key or the password protecting the encrypted seed phrase in your browser's local storage. fintok cannot recover, freeze, or move your tokens. If you lose your seed phrase or password, fintok cannot help you regain access.

4. Risk

Investing in tokenised corporate bonds involves substantial risk, including the partial or total loss of invested funds. Returns are not guaranteed by the Republic of Serbia, the National Bank of Serbia, the Securities Commission, fintok, or any other public authority. The Issuer may default. Digital-asset transactions are not covered by the Serbian deposit-insurance scheme, nor by the rules protecting users of financial services or investors in regulated capital markets.

5. KYC / AML responsibility split

You agree to provide accurate identity and address information as required by the applicable AML laws. Your personal data is processed in accordance with our Privacy Policy and applicable data protection regulation.

All anti-money-laundering and counter-terrorism-financing obligations under the Zakon o sprečavanju pranja novca i finansiranja terorizma and Articles 56–58 of the Zakon o digitalnoj imovini — including but not limited to (i) identity verification and customer due diligence, (ii) screening of investors against international sanctions lists (such as the EU consolidated list and the OFAC SDN list) and politically-exposed-person (PEP) databases, (iii)enhanced due diligence for higher-risk customers, (iv) ongoing transaction monitoring, (v) periodic re-screening of active investors, and (vi) filing of suspicious-activity reports with the Uprava za sprečavanje pranja novca (APML) — are the sole responsibility of the Issuer as the obliged entity that holds the customer relationship and receives customer funds.

fintok performs no AML screening, no sanctions screening, no PEP screening, and no ongoing transaction monitoring on its own behalf or on behalf of the Issuer. fintok provides the supporting software and data — the onboarding form, the encrypted document storage, the audit log of ops-side decisions, and the on-chain event history — and the Issuer (or an AML vendor the Issuer contracts) uses those tools to discharge its regulatory duties. fintok's role with respect to personal data is that of a data processor under Article 4(8) of the EU General Data Protection Regulation; the Issuer is the data controller.

6. No advice

fintok does not provide investment advice. Nothing displayed on the platform is a recommendation to buy, sell, or hold any token. You must make your own investment decisions based on your own analysis or that of an independent adviser.

7. No secondary market on fintok

The tokens displayed on this platform are not traded peer-to-peer through fintok. Investors can sell tokens back to the Issuer at the nominal price (subject to the Issuer's acceptance and the contract's rules); fintok facilitates the form but does not match orders.

8. Changes

fintok may amend these terms. Material changes will be communicated at least seven days before they take effect (per Art. 82 Zakon o digitalnoj imovini). Continued use of the platform after that date constitutes acceptance of the updated terms.

9. Governing law

These terms are governed by the laws of the Republic of Serbia. Disputes are resolved by the courts of the Republic of Serbia.