These GTB apply to all services of Findes Group, except where an individual contract or special terms expressly provide otherwise. In the event of a discrepancy between the GTB and special terms for an individual service, the special terms shall prevail.

3.1 Pre-contractual Obligations for Insurance Contracts

In accordance with the Insurance Act (ZZavar-1) and the IDD Directive, we are required to:

• Provide the client with the Insurance Product Information Document (IPID).
• Verify the client's demands and needs (Demands & Needs test).
• Explain the basis for the insurance product recommendation.
• Disclose any conflicts of interest and commissions received.

3.2 Complaints Procedure

Complaints relating to insurance services shall be submitted in writing to pritozbe@finds.si. We respond within 15 working days. The client has the right to lodge a complaint with the Insurance Supervision Agency (AZN) and the Insurance Ombudsman.

3.3 Register of Insurance Agents and Brokers

In accordance with the IDD Directive (Article 3), every client has the right to verify the validity of registration of our agencies with the Insurance Supervision Agency (AZN):

• Findes plus d.o.o. (agent) — entered in the AZN register: www.a-zn.si/register
• Findes plus 2 d.o.o. (broker) — entered in the AZN register: www.a-zn.si/register

The client may at any time request confirmation of the validity of registration at info@finds.si.

3.4 Cross-selling

In accordance with the IDD Directive (Article 24), the following applies to bundled offers (insurance + real estate, insurance + investment):

• Each product must be priced separately — the client must see the price of the insurance separately from the price of the real estate or investment.
• The client has the right to purchase each product separately without any obligation to purchase the bundled package.
• Insurance is not a condition for concluding a real estate or investment contract.
• Bundling is permitted only if it is in the client's interest and this is clearly documented in the Demands & Needs test.

3.5 Remuneration Policy and Commission Disclosure

In accordance with the IDD Directive (Article 19) and ZZavar-1, our advisors are required to disclose the nature of their remuneration before concluding a contract:

• Findes plus d.o.o. (agent) — receives a commission from the insurer it represents.
• Findes plus 2 d.o.o. (broker) — receives a commission from the insurer or a fee from the client; independently compares the market.

The exact amount or percentage of commission will be disclosed to the client upon request or prior to concluding the contract, where required by applicable legislation.

3.6 Professional Competence and Continuing Education

In accordance with the IDD Directive (Article 10), all our insurance advisors must complete at least 15 hours of annual professional training. Training records are retained for 5 years and are available for inspection by AZN. Upon the client's request, proof of completed training shall be provided.

3.7 Complaints Authorities — AZN, Ombudsman and TIRS

In addition to the internal complaints procedure (pritozbe@finds.si, deadline 15 working days), the client has the right to external dispute resolution:

• Insurance Supervision Agency (AZN) — info@a-zn.si | +386 1 300 39 10 | response deadline: 8 weeks
• Insurance Ombudsman — info@varuh-zavarovalnistvo.si | deadline: 30 days
• Market Inspectorate of the Republic of Slovenia (TIRS) — gp.tirs@gov.si | deadline: 30 days

3.8 Cross-border Insurance Services (Freedom of Services)

Findes Group operates in international markets. The following applies to the cross-border provision of insurance services:

• EU markets (BG, CY) — services are provided on the basis of a Freedom of Services (FoS) notification with AZN and the home supervisory authority.
• UK — following Brexit, services are provided in accordance with the UK Financial Services and Markets Act (FSMA) and FCA rules.
• RS, BA — services are provided in accordance with local legislation and through authorised local partners.

For information about cross-border services, please contact info@finds.si.

4.1 Nature of Intermediary Services

The partner portal Investra.io operates under a Master Franchise licence held by Findes Marketing d.o.o. for the Slovenian market. Neither Investra International Ltd nor Findes Marketing d.o.o. is an investment firm, bank, or alternative investment fund manager. All information about projects is provided for informational purposes only and does not constitute a guarantee of return. For the legal description of Investra International Ltd, see point 4.4.

4.2 AML/KYC obveznosti

In accordance with the Act on the Prevention of Money Laundering and Terrorist Financing (ZPPDFT-2), Findes Marketing d.o.o. is required to carry out a client identification procedure (KYC) for all transactions above the statutory threshold (15,000 EUR). The client is required to provide:

• A valid identity document (passport or national identity card).
• Proof of source of funds (bank statements, sale contract, tax return).
• For legal entities: an extract from the court register and data on ultimate beneficial owners (UBO).

Findes Group reserves the right to refuse a transaction if the client fails to provide the required documents or if there are reasonable grounds to suspect money laundering.

4.3 Escrow Procedure for Investments

For investment transactions above 50,000 EUR, the use of a fiduciary (Escrow) account is mandatory. Funds are held with a notary or bank until all contractual conditions are fulfilled (registration of a preliminary entry in the land register, obtaining a building permit, etc.).

4.4 Separation of Liability — Investra.io and Findes Marketing

Investra International Ltd (Company No. 16626956, 128 City Road, London EC1V 2NX, United Kingdom) is a marketplace and IT company — an advertising space for the promotion of real estate and projects and an IT tool for client management. Investra International Ltd is not a real estate agency. The partner portal Investra.io operates under a Master Franchise licence held by Findes Marketing d.o.o. for the Slovenian market. Findes Marketing d.o.o. acts as a marketing agent and is not:

• A real estate broker licensed under ZNPosr (the licence is held exclusively by an authorised partner).
• An investment firm, bank, or alternative investment fund manager under ZISDU-3.
• A guarantor for returns, project completion, or the value of the real estate.

All transactions are concluded directly between the buyer and the developer/seller. Findes Marketing d.o.o. does not act as a contracting party in the purchase of real estate.

4.5 Unifyr.space — B2B Multimarketplace (SL Enterprises EOOD)

Key features of Unifyr.space:

• B2B Multimarketplace: A platform for B2B transactions between developers, agencies, and institutional buyers.
• White-label solution: Partners can customise the platform to their own brand.
• Separate liability: SL Enterprises EOOD bears full legal liability for the platform; Findes Group acts solely as a distributor and partner.
• Applicable law: Unifyr.space is governed by Bulgarian law and the jurisdiction of the courts in Sofia.

4.6 Due Diligence — obseg preverjanja

Prior to the publication of a project on the Investra.io platform, a basic due diligence review is conducted, which includes:

• Verification of the developer's identity and basic registration data.
• Review of available documentation (title deed, building permit, project documentation).
• Basic creditworthiness check of the developer.

Findes Marketing d.o.o. does not guarantee and is not liable for the legal soundness of the property title chain, project completion within the agreed deadline, accuracy of the developer's data, or the value of the property upon completion of construction. The client is required to carry out their own independent due diligence before entering into any contract.

4.7 Currency and Market Risk

Additional market risks accepted by the client:

• Market risk: The value of the property may decline due to market conditions in the country of purchase.
• Liquidity risk: The property may not be sold within the desired timeframe or at the desired price.
• Regulatory risk: Changes in legislation in the country of purchase may affect the value of the investment.
• Developer risk: The possibility of the developer's insolvency or delay.

All real estate investments are long-term in nature. Past performance does not guarantee future returns. Do not invest money you cannot afford to lose.

4.8 Prohibition of Advertising Investments without a Prospectus

In accordance with the Act on Undertakings for Collective Investment in Transferable Securities (ZKNPVP) and the Capital Markets Act (ZKT), the following applies:

• Findes Marketing d.o.o. does not market or broker investment funds, alternative investment funds (AIS), or securities without the requisite prospectus and authorisation from ATVP.
• All listings on Investra.io are informational in nature and do not constitute a public offering of securities.
• For collective investment schemes that exceed statutory thresholds, registration with the competent regulator is mandatory (ATVP in Slovenia, FCA in the UK, CySEC in Cyprus, etc.).

A client wishing to invest in regulated investment products must do so through an authorised investment intermediary.

4.9 Booking Management — Separation of Liability

The short-term rental management service (Booking Management) is provided through the partner platform Investra.io and authorised partners. Findes Marketing d.o.o. and Investra.io:

• Do not guarantee occupancy rates, rental income, or return on investment.
• Are not liable for errors, cancellations, or changes to the terms of third-party platforms (Airbnb, Booking.com, Vrbo, etc.).
• Are not liable for damage to the property caused by guests.
• Are not liable for changes to local regulations regarding short-term rentals.

The property owner is required to ensure appropriate insurance of the property for short-term rental and to obtain all necessary local permits.

4.10 International Transactions — Tax Obligations

When purchasing property abroad, the client is solely responsible for fulfilling all tax obligations, including real estate transfer tax, VAT, income tax on rental income, capital gains tax, and inheritance tax.

5.1 Intellectual Property in IT Development

Unless otherwise expressly agreed in a software development contract, all copyrights in the developed software, algorithms, AI models, databases, APIs and documentation remain the property of Findes Marketing d.o.o. The client obtains a non-exclusive, non-transferable licence for use within the agreed purpose and for the agreed period of time. Ownership rights are transferred to the client exclusively where this has been expressly agreed in writing in the development contract and where full payment has been settled.

5.2 Exclusion of Warranties for IT Services

Software is delivered "as is". The warranty period for remedying defects in developed software is 30 days from handover, unless otherwise specified in the contract. After the expiry of the warranty period, defect remediation is charged according to the applicable maintenance price list.

5.3 SaaS Subscriptions and White-label Platforms

Subscriptions to Findes Group's own SaaS solutions are billed monthly or annually in advance. Cancellation of a subscription is possible with a 30-day notice period before the next billing period. Payments already made are non-refundable, except in cases of proven fault on the part of Findes Marketing d.o.o.

5.4 AI Solutions — Special Features and EU AI Act

In developing AI solutions, Findes Marketing d.o.o. acts in accordance with the EU Artificial Intelligence Regulation (AI Act, Regulation EU 2024/1689):

Findes Marketing d.o.o. does not develop high-risk AI systems without a prior written contract that includes a risk assessment (FRIA — Fundamental Rights Impact Assessment) and an agreement on liabilities between the parties.

5.5 Data Ownership and Protection in IT Services

All data provided by the client to Findes Marketing d.o.o. for the purpose of developing an IT solution remain the exclusive property of the client. Upon completion of the project or termination of the contract, Findes Marketing d.o.o. is required within 30 days to return or permanently delete all client data and issue a written certificate of deletion upon the client's request.

5.6 Security Standards and Cybersecurity

Findes Marketing d.o.o. observes OWASP Top 10, HTTPS/TLS 1.3, secure password storage (bcrypt/Argon2), the principle of least privilege, and regular security updates when developing IT solutions. In the event of a security incident, Findes Marketing d.o.o. will notify the client within 72 hours of discovering the incident, in accordance with the requirements of GDPR (Article 33) and the NIS2 Directive.

5.7 Escrow izvorne kode

For critical business systems, the client may request source code escrow — the deposit of source code with an independent third party. In the event of insolvency, cessation of operations, or a material breach of contract by Findes Marketing d.o.o., the client obtains access to the deposited source code. Findes Marketing d.o.o. recommends escrow for all projects with a value exceeding 50,000 EUR.

5.8 Maintenance and Support (SLA)

After the expiry of the warranty period, maintenance and technical support are billed separately. Findes Marketing d.o.o. offers the following SLA levels:

The SLA agreement must be concluded in writing before the start of the maintenance period. Without an SLA agreement, the exclusion of warranties under point 5.2 applies.

5.9 Prohibition of Reverse Engineering and Non-compete Clause

The client must not decompile, disassemble, or reverse-engineer the delivered software, remove copyright notices, distribute the software without written consent, or develop competing solutions on the basis of confidential information within 24 months following project completion.

5.10 B2B vs. B2C — Differences in IT Services

5.11 Changes to Project Scope (Change Management)

Project specifications agreed upon signing of the contract constitute the fixed scope of work. Any change request must be processed through the formal change management procedure: written request, impact assessment within 5 working days, written Change Order confirmation, and adjustment of the deadline.

5.12 Project Handover (Acceptance Testing)

Upon completion of development, a formal handover procedure follows: delivery, UAT (User Acceptance Testing) within 14 days, defect remediation, and written confirmation (Sign-off). If the client does not submit a bug report within the UAT period, the project is deemed tacitly accepted. From the date of handover, the warranty period begins and the final payment instalment becomes due.

5.13 Liability for Third-party Services

Findes Marketing d.o.o. does not assume liability for the operation, availability, security, or changes to the terms of cloud infrastructure (AWS, GCP, Azure), payment systems (Stripe, PayPal), AI APIs (OpenAI, Google, Anthropic), mapping and communication services, or open-source libraries. In the event that a third-party provider discontinues or alters its service, adaptation shall be charged as a new change of scope.

5.14 Subcontractors and Outsourcing

Findes Marketing d.o.o. reserves the right to engage subcontractors (freelancers, specialised agencies, external developers) for the execution of part or all of a project, unless otherwise expressly agreed in the contract. The client may not directly contact, engage, or conclude contracts with subcontractors of Findes Marketing d.o.o. within 24 months following project completion without written consent.

5.15 Open-source Components (Open Source Compliance)

Findes Marketing d.o.o. gives preference to permissive licences (MIT, Apache 2.0, BSD) when selecting OSS components. GPL/AGPL-licensed components are not incorporated into commercial projects without prior written consent from the client and a legal analysis. Upon request, a list of all OSS components (Software Bill of Materials — SBOM) shall be delivered.

5.16 Test Environment and Production

Hosting and infrastructure for the test environment are billed separately. The test environment is maintained for 30 days after handover, then decommissioned. Real personal data (GDPR) must not be stored in the test environment — anonymised or synthetic test data shall be used.

5.17 Versioning and Documentation

Findes Marketing d.o.o. follows the Semantic Versioning standard (MAJOR.MINOR.PATCH). Upon handover, technical documentation, user documentation (user manual), and a changelog are delivered. Findes Marketing d.o.o. is not required to maintain documentation after the expiry of the warranty period, except under a maintenance agreement (SLA).

5.18 Exit Strategy and Portability (Vendor Lock-in Free)

Findes Marketing d.o.o. commits to the principle of "vendor lock-in free": it develops on widely-used, open technologies, enables data export in standard formats, delivers all source code within 15 working days upon contract termination (where ownership has been transferred), and provides 30 days of transition support to the client's new developer.

6.1 Types of Digital Products and Scope of Application

Chapter 6 governs the purchase and use of all digital products of Findes Academy: video courses, live and recorded webinars, e-books and guides, templates and tools, coaching packages, and membership subscriptions. Specific provisions apply to each type of product.

6.2 Access to Digital Content and Technical Requirements

Upon successful completion of payment, the client obtains access. Video courses (one-time purchase) — lifetime access. Webinar (live) — date + 30 days for the recording. E-books — lifetime access upon download. Membership — duration of the subscription. Coaching packages — valid for 6 months from the date of purchase.

Findes Marketing d.o.o. is not liable for technical issues on the client's side (slow internet connection, outdated browsers, blocks by the employer or ISP).

6.3 Payment, Prices and Special Terms

Prices are in EUR and include VAT. Payment methods: credit/debit card, PayPal, bank transfer (B2B over 500 EUR). For products over 200 EUR, payment in instalments is available. Promo codes are valid until their expiry date and may not be combined with other discounts.

6.4 Right of Withdrawal — Extended Provisions

At the time of purchase, the client must actively confirm the tick-box regarding the loss of the right of withdrawal. Without this confirmation, access cannot be granted. Exceptions — when the right of withdrawal exists: the client has not obtained access, the content differs substantially from the description, the coaching package has not yet been carried out, or the live webinar was cancelled. B2B exception: Companies do not have a statutory right to a 14-day withdrawal period.

6.5 Prohibition of Access Sharing and Anti-piracy Protection

Each purchase grants access to one person only. The client agrees not to share login credentials, pass on content to third parties, record video content, publish it on YouTube, or reproduce it for their own commercial products.

• Immediate and permanent blocking of access without a refund.
• A claim for damages amounting to 10 times the value of the product for each breach.
• Legal proceedings for copyright infringement (ZASP).

6.6 Quality Guarantee and Complaints Procedure

Valid grounds for a complaint: the video does not play, the PDF is corrupted, access has not been granted within 24 hours of payment, content differs substantially from the description. Submit a complaint to info@finds.si within 14 days of discovering the defect. Findes Marketing d.o.o. responds within 3 working days.

A complaint based on subjective disagreement with the content ("I did not enjoy the content") is not a valid ground for a refund.

6.7 Affiliate and Referral Programme

Findes Marketing d.o.o. offers a partner (affiliate) programme for the promotion of digital products. The standard commission is 20–30% of the sale value. Sales are tracked through unique affiliate links with a 30-day cookie window. Commissions are paid out monthly after the expiry of the 30-day refund period. Minimum payout threshold: 50 EUR.

7.1 Narava svetovalnih storitev

Findes Marketing d.o.o. provides business, financial, and strategic advisory services. All opinions, strategies, and recommendations are informational in nature and are based on information provided by the client. Findes Marketing d.o.o. does not guarantee and makes no warranty as to business success, revenue growth, or other specific outcomes.

7.2 Exclusion of Tax and Legal Advisory

Findes Marketing d.o.o. does not provide tax or legal advisory services unless this is expressly stated in a separate agreement and the service is provided through authorised external partners (lawyers, tax advisors). The client is required to independently verify the tax and legal implications of implementing business strategies.

7.3 Odgovornost stranke

The client undertakes to provide Findes Marketing d.o.o. in a timely manner with all necessary, accurate, and complete information, documentation, and access to key persons. Findes Marketing d.o.o. is not liable for delays or incorrect conclusions resulting from incomplete or inaccurate information provided by the client.

7.4 Confidentiality and Protection of Business Secrets (NDA)

Both parties undertake to strictly protect all business secrets, financial data, strategies, and know-how. The obligation of confidentiality applies during the term of the contract and for a further 5 years after its termination.

8.1 Prices and Taxes

All prices are expressed in Euros (EUR). In B2C, prices include VAT unless otherwise expressly stated. In B2B, prices are generally stated exclusive of VAT; tax is charged on the invoice in accordance with applicable tax legislation.

8.2 Payment Methods

• Credit and debit cards: Via a secure payment system (e.g. Stripe).
• Bank transfer (UPN/SEPA): On the basis of an issued pro forma invoice or invoice.
• Online payment platforms: PayPal, Apple Pay, Google Pay (where enabled).

For card payments, the transaction is processed immediately. For payments by pro forma invoice, the service commences only upon receipt of the full amount.

8.3 Late Payments

The payment deadline is 8 days from the date of issue of the invoice. In the event of a late payment, Findes Marketing d.o.o. reserves the right to:

• Charge statutory late payment interest.
• Suspend the provision of further services or terminate access to digital products.
• Charge reminder fees amounting to 5.00 EUR.

If the client fails to settle the invoice even after the second reminder, Findes Marketing d.o.o. may refer the claim to an external collection agency or the competent court.

Findes Group is committed to protecting clients' personal data in accordance with Regulation (EU) 2016/679 (GDPR) and the applicable Act on the Protection of Personal Data (ZVOP-2). We process personal data exclusively for the purposes of:

• Fulfilment of contractual obligations (delivery of product, provision of service).
• Issuing invoices and maintaining accounting records.
• Communication with the client in connection with the order.
• Direct marketing, exclusively on the basis of the client's explicit consent.

The client has at any time the right to access, rectification, erasure, restriction of processing, and portability of their personal data. Further information is available in the Privacy Policy.

10.1 Amendments to the General Terms of Business

Findes Group reserves the right to amend these GTB at any time and without prior notice. The amended GTB shall enter into force on the date of publication on the website www.finds.si. For an individual order or contract, the GTB in force at the time of placing the order shall apply.

10.2 Invalidity of Individual Provisions

If any provision of these GTB is found to be null or unenforceable, this shall not affect the validity of the remaining provisions. The invalid provision shall be replaced by a valid one that most closely approximates the economic and legal purpose of the original.

10.3 Applicable Law and Court Jurisdiction

These GTB are governed by the law of the Republic of Slovenia. Any disputes shall be resolved amicably between the parties. If an amicable resolution is not possible, the substantively competent court in Ljubljana shall have jurisdiction to resolve disputes. For contracts with consumers (B2C), jurisdiction shall be determined by the court in the consumer's place of permanent residence.

10.4 Out-of-court Resolution of Consumer Disputes

In accordance with the Act on Out-of-Court Settlement of Consumer Disputes (ZIsRPS), Findes Marketing d.o.o. does not currently recognise any provider of out-of-court consumer dispute resolution. EU online dispute resolution (ODR) platform: http://ec.europa.eu/odr.