Terms of Use

1. Provider details

1.1. The Wallymanager service, including the website, the application and all related features (the “Service”), is provided by „Уолимениджър“ ЕООД / „Wallymanager“ LTD, UIC: 208882840, with its registered seat and management address at: 1A Skopie Street, floor 4, apt. 16, Yuzhen district, Plovdiv 4003, Republic of Bulgaria, represented by its manager Mihail Merkov, contact email: office@wallymanager.com, website/application: https://wallymanager.com (the “Provider”, “we”, “us”). 1.2. These terms of use (the “Terms of Use”) govern the relationship between the Provider and any person who accesses, registers for or uses Wallymanager (the “User”, “you”). 1.3. Where the User is a natural person who uses the Service outside the scope of a commercial or professional activity, that User also benefits from the protection that the applicable consumer-protection legislation affords to consumers.

2. Subject matter and acceptance of the Terms

2.1. Wallymanager is a digital service for managing and analysing personal finances. Through the Service the User can create an account, enter and organise financial records, track payments, budgets, categories, savings goals, charts and reports, and use additional features, including artificial-intelligence features where the User has activated them. 2.2. Creating an account, pressing an acceptance button, paying for a subscription or actually using the Service means that the User has read, understood and accepted these Terms of Use. 2.3. If you do not agree with these Terms of Use, you should not create an account or use the Service.

3. Nature of the Service and important limitations

3.1. Wallymanager is an auxiliary tool for the personal organisation and analysis of financial data. The Service is not a bank, payment institution, electronic money institution, investment firm, credit intermediary, insurance intermediary, tax adviser or licensed financial adviser. 3.2. All reports, charts, categories, forecasts, notifications, analyses and results of artificial-intelligence features are provided for information and organisational purposes only. They do not constitute financial, investment, tax, legal, accounting or other professional advice. 3.3. The User takes their own financial decisions and is responsible for verifying the accuracy, completeness and currency of the data entered into or imported into the Service. 3.4. Wallymanager may display or analyse data received from the User or from external providers, but does not guarantee that every transaction, category, receipt recognition, forecast or automated suggestion will be free of error.

4. Registration and user account

4.1. Registration may be required in order to use the main features of Wallymanager. When registering, the User provides true, current and complete information. 4.2. The User is responsible for keeping their account access credentials confidential and for all actions performed through their account, except where it is proven that the unauthorised access was caused solely by an act or omission of the Provider. 4.3. Wallymanager may offer sign-in via Google or another identity provider. Where such sign-in is used, the terms and policies of the respective provider also apply. 4.4. The User should notify the Provider immediately in the event of suspected unauthorised access, loss of a device, a compromised password or any other risk to the account.

5. Financial data, receipts and User Content

5.1. The User may enter, upload, scan or import financial data, including transactions, balances, budget categories, savings goals, receipts, images, notes and other records (“User Content”). 5.2. The User warrants that they are entitled to enter or upload the User Content and that it does not infringe the rights of third parties, statutory restrictions or these Terms of Use. 5.3. It is recommended that the User does not upload receipts or documents that contain unnecessary personal data of third parties, data concerning health, medication, medical services, membership, political opinions, religion or other sensitive information, unless this is necessary in order to use a specific feature and the User has knowingly chosen to have it processed through the Service. 5.4. The Provider acquires no ownership of the User Content. The User grants the Provider a limited right to process that content to the extent necessary to provide, maintain, protect and improve the Service, in accordance with the Privacy Policy.

6. Connecting bank / financial accounts

6.1. As at the date of the last update, Wallymanager does not support any active functionality for connecting to bank or other financial accounts through an open-banking provider. 6.2. Should such functionality be introduced in the future, it will be activated only at the initiative of the User, through a duly regulated or otherwise permissible external provider, with a clear description of the provider, the categories of data, the legal basis, the rights of the User and the conditions for terminating the connection. 6.3. If open-banking functionality is introduced, these Terms of Use, the Privacy Policy, the internal record under Article 30 GDPR and the contracts with providers must be updated before it is activated for Users. 6.4. The Provider will not request and will not store usernames, passwords, PIN codes, one-time codes or other credentials for the online banking of the User, unless this is expressly permissible and necessary under the applicable legislation and through a duly selected provider.

7. Artificial-intelligence features

7.1. Wallymanager may offer artificial-intelligence features, for example receipt recognition, expense categorisation, summaries, analyses and budgeting suggestions. 7.2. The AI features are separate from cookies and similar technologies. Where processing through an external AI provider is not strictly necessary for the core service, it is activated only after a separate express action by the User, for example through a pop-up, an activation screen or a setting in the account. 7.3. The User may accept or refuse the use of the AI features and may change that choice through the privacy/security settings in their account. The system maintains a history of the consents given and withdrawn. As at the date of this revision, the AI provider is Eden AI, used through a European endpoint, under a configuration for European data residency and subject to the applicable contracts/documentation of the provider. 7.4. The results of the AI features are generated automatically and may contain inaccuracies, omissions or inappropriate categorisations. Wallymanager does not take decisions based solely on automated processing which produce legal effects for the User or similarly significantly affect the User.

8. Paid plans, payments and subscriptions

8.1. Some features of the Service may be available for a fee. The current price, currency, subscription period, included features, applicable taxes, discounts, coupons, date of the first or next charge and renewal conditions are displayed clearly before the payment is confirmed. 8.2. Specific prices are not fixed in these Terms of Use unless expressly stated otherwise. The Provider may offer different plans, promotional codes, coupons and dynamic recalculation of price/currency through the payment provider. The final price and the conditions displayed on the payment screen before confirmation prevail. 8.3. Payments are processed through an external payment service provider. For purchases made through the Wallymanager website or web application, the payment service provider is Stripe. For purchases made through the Wallymanager mobile application, the payment is processed by Apple, through the App Store, or by Google, through the Play Store, as applicable, each acting as the payment service provider for that transaction; the respective terms of service and policies of Apple or Google also apply to that transaction. The Provider does not store full payment card data unless this is expressly stated and permissible under the applicable rules. 8.4. Where a free trial period and/or automatic renewal is provided for, the duration of the trial period, the date of the first charge, the subscription period and the conditions for termination are displayed before the plan is activated. The User may cancel renewal through their account, including through the “Subscription plans”/“Cancel subscription” menu, or through another channel indicated by the Provider. 8.5. Where automatic renewal is cancelled, the User retains access to the paid features until the end of the period already paid for, unless stated otherwise or unless the law requires a different outcome.

9. Right of withdrawal, cancelling renewal and refunds

9.1. Where the User qualifies as a consumer and concludes a distance contract, that User is as a rule entitled to withdraw from the contract within 14 days of its conclusion, except where a statutory exception applies. 9.2. Where a paid plan is activated after a free trial period and the User has not been charged before that period expires, the User may cancel the renewal/paid subscription before the first charge through the functionality available in their account. The Provider does not rely on a prior loss of the right of withdrawal on account of performance commencing immediately, unless a separate clear process for this is introduced in the future and the documents are updated. 9.3. To exercise the right of withdrawal, the User may use an automated function in their account, where available, or send an unequivocal statement to the email address: office@wallymanager.com or support@wallymanager.com. The statement is valid when it is received at either of the two addresses. A sample withdrawal form is included at the end of these Terms of Use. 9.4. Where the right of withdrawal has been validly exercised and where applicable, the Provider refunds the amount received using the same payment method as was used for the original payment, unless the parties agree otherwise and this does not create additional costs for the User. A refund may also be due in the event of a double or erroneous payment, an unauthorised payment, a service that was not provided, a material conformity problem with the digital service or another ground provided for by law. 9.5. Cancelling the automatic renewal of a subscription is not equivalent to exercising the right of withdrawal in respect of a paid period that has already begun or been used. Amounts for the current paid period are not refunded unless the law, the specific plan, an express promise to the User or an internal policy of the Provider provides otherwise.

10. Permitted and prohibited use

10.1. The User undertakes to use the Service only lawfully, in good faith and in accordance with its intended purpose. The following is prohibited: attempting unauthorised access to accounts, systems, data or infrastructure; using the Service for fraud, money laundering, the financing of unlawful activity or the circumvention of statutory obligations; uploading malicious code, automated data extraction, excessive load or disrupting the normal operation of the Service; impersonating another person or using the financial data of another person without authorisation; reverse engineering, copying or circumventing protective mechanisms, except where this is expressly permitted by law. 10.2. In the event of a breach, the Provider may temporarily restrict access, suspend the account, require additional verification or terminate the contract, taking into account the nature of the breach and the applicable rights of the User.

11. Availability, maintenance and changes to the Service

11.1. The Provider makes reasonable efforts to keep the Service available, secure and functional, but does not guarantee uninterrupted or error-free operation. 11.2. Temporary interruptions are possible due to maintenance, updates, actions of external providers, technical problems, security incidents or force majeure circumstances. 11.3. The Provider may change, add or remove features where this is necessary for the development of the Service, for security, for compliance with the law or to improve performance. In the event of material changes that affect paid features, the User will be notified in an appropriate manner.

12. Intellectual property

12.1. All rights in Wallymanager, including its name, logo, design, interface, texts, graphics, software, databases, structure, functionality and documentation, belong to the Provider or to its licensors. 12.2. The User receives a limited, non-exclusive, non-transferable and revocable right to use the Service for personal purposes in accordance with these Terms of Use. 12.3. Copying, distribution, adaptation, rental, sale, the granting of access or the creation of a competing service on the basis of Wallymanager is not permitted without the prior written consent of the Provider.

13. Protection of personal data

13.1. Personal data is processed in accordance with the Privacy Policy, which forms an integral part of the public documentation package and is available at: https://wallymanager.com/legal/privacy-policy. 13.2. The use of cookies and similar technologies is described in the Cookie Policy, available at: https://wallymanager.com/legal/cookie-policy.

14. Liability

14.1. The Provider is liable for damages only within the limits provided for by the applicable legislation. Nothing in these Terms of Use excludes or limits liability which cannot be excluded or limited by law. 14.2. The Provider is not liable for decisions of the User taken on the basis of reports, forecasts, charts or automated analyses in the Service, in so far as the Service does not provide professional financial, investment, tax or legal advice. 14.3. The Provider is not liable for the acts, omissions, policies, terms, technical problems or breaches of external providers that act as independent controllers or independent service providers, except where the law provides otherwise.

15. Complaints, consumer disputes and competent authorities

15.1. The User may send questions, reports and complaints to the email address: support@wallymanager.com. The Provider reviews the complaints received within a reasonable period and, where applicable, informs the User of the outcome. 15.2. Users may turn to the Commission for Consumer Protection or to another competent authority in accordance with the applicable legislation. 15.3. The reference to the former European online dispute resolution platform is not included in these Terms of Use, as that platform has been discontinued. Where necessary, the national and European consumer-protection mechanisms in force should be used.

16. Governing law and competent court

16.1. These Terms of Use are governed by the law of the Republic of Bulgaria, in so far as the applicable mandatory rules do not provide otherwise. 16.2. All disputes shall be settled by the competent Bulgarian court. Where the User is a consumer resident in another state, this clause does not deprive that User of the protection afforded by the mandatory rules of their state of habitual residence, where those rules are applicable.

17. Changes to these Terms

17.1. The Provider may update these Terms of Use in the event of changes to the Service, the legislation, the technical measures, the prices or the business model. 17.2. In the event of material changes, Users will be notified through the application, by email or through another appropriate channel. For paid subscriptions, changes that affect the price or the core features apply in accordance with the conditions of the specific plan and the applicable legislation. 17.3. The amended Terms of Use take effect for already registered Users on the date specified in the notification, which may not be earlier than a reasonable period after the notification, allowing the User to review them and to take a decision. 17.4. If the User does not accept the amendments, the User may terminate the contract and close their account before the amendments take effect, without owing any compensation or penalty. For paid subscriptions, the rules on termination and refunds under section 9 apply. 17.5. Continuing to use the Service after the amendments take effect is deemed to constitute acceptance of them.

18. Contact

For questions regarding these Terms of Use: „Уолимениджър“ ЕООД / „Wallymanager“ LTD, UIC: 208882840, address: 1A Skopie Street, floor 4, apt. 16, Yuzhen district, Plovdiv 4003, Republic of Bulgaria, email: office@wallymanager.com, personal data contact point: support@wallymanager.com.

Annex 1 — Sample withdrawal form

To: „Уолимениджър“ ЕООД / „Wallymanager“ LTD, email: office@wallymanager.com or support@wallymanager.com. I hereby give notice that I withdraw from the contract concluded by me for the following digital service/subscription: ________. Date of order/payment: ________. Name of the user: ________. Account email: ________. Payment identifier, if available: ________. Date: ________. Signature, if the form is submitted on paper: ________.

If you have any questions about these Terms, please contact us at office@wallymanager.com.