CNPJ 37484255000187



Pies and AutoInvest Terms

1. General Information.

1.1. These Pies and AutoInvest Terms (“the Terms”) govern the relationship between you and
Trading BitBaxter in terms of you using the Investment Pies technical tool.
The Invest Terms and any definitions not defined in these Terms shall be applied mutatis
mutandis to the Terms. In case of any inconsistencies, the Terms shall take precedence over
the Invest Terms.
1.2. Your ISA account and any ISA Services, as defined in the Invest Terms, shall be governed
by the ISA Terms available on our Website, in addition to the present Terms. Please note that
there are specific rules in relation to your ISA account contained therein.
1.3. Any reference in the Terms to ‘we’, ‘us’, ‘our’, ‘ours’ and ‘ourselves’ as appropriate shall
mean Trading BitBaxter. Similarly, any reference to ‘the Client’, ‘you’, ‘your’, ‘yours’ and ‘yourself’ as
appropriate shall mean you as a customer of our services under the Invest Terms.

2. Definitions.

AutoInvest is a functionality that enables you to set up recurring payments into your Pies
that are for fixed amounts that happen periodically and on an ongoing basis as chosen by
you with no specified end date until terminated by you.
Auto reinvest is a functionality feature part of Autoinvest that enables you to automatically
reinvest all dividends received from a financial instrument back into the portfolio of financial
instruments in your Pie and in accordance with the proportional value of each financial
instrument configured by you.
Average annual return (AAR) is the weighted average of the 5-year annualised return of
each Slice.
Pie means a collection of financial instruments that is created by you based on your
Slice means each separate financial instrument, which a Pie consists of.
Social Functionality is Trading BitBaxter’s social functionality available on the BitBaxter Platform
and as described in Trading BitBaxter Social Terms of Use.
Weight means the percentage each Slice takes of a Pie.

3. Service Overview.

3.1. Trading BitBaxter shall provide the Investment Pies technical tool (the “Feature”) and has
concluded that the Feature:
a. provides a software solution which enables you to manually generate your own Pies;
b. enables you to add one or more financial instruments to a Pie;
c. provides information about a Pie’s AAR based on historical data that does not
guarantee in any way the future performance of a Slice or a Pie;
d. to either invest funds manually in a Pie on a one-off basis or use the AutoInvest
functionality for regular recurring payments (see section 4 for more details);
e. provides you with the option to turn on/off AutoInvest for a whole Pie; and
f. provides you with the option of copying a Pie based on another Pie creator’s
preferences (see section 7 for more details).
3.2. Trading BitBaxter shall in providing this Feature:
a. use due care and diligence to operate the Feature in line with the present Terms and
b. act on an execution-only basis, meaning we do not provide any form of portfolio
management or financial, legal, tax or similar advice relating to the Feature and are
not responsible for exercising any judgement on your behalf as to the merits of any
order you place or as to the performance of any financial instrument you invest in;
c. act on valid instructions we receive from you;
d. transmit, buy or sell orders in line with our order execution policy; and
e. hold your financial instruments within your Pie in line with Rules on client
money and the custody of assets as described in the Invest Terms.
3.3. By using the Feature, you shall be able to generate your own Pies manually to conduct
transactions with financial instruments. You will have the ability to select which financial
instruments to invest in, what proportion to be invested in which Slice, as well as deciding
how much and when to invest. The Pie can be edited or deleted at any point, and all its
settings can be amended.
3.4. The use of the Feature shall not in any way affect, amend or override the fact and the
statements made by you, confirming that no investment decisions are made on your behalf
by Trading 212 and that each transaction is still executed only at your own discretion and
shall be entirely at your expense and risk.
3.5. The available financial instruments and market hours for the services provided herein
shall be determined by Trading BitBaxter, and a list thereof shall be available to you on the
Feature. Both the financial instruments and market hours can be amended by Trading BitBaxter
from time to time.
3.6. When new funds are invested in a Pie, they will be used in accordance with your
previously set Weight to execute an order to buy a share of the financial instrument.
Purchases are made on or as soon as reasonably practicable after funds are paid in. If the
funds are insufficient for a whole share, then a fractional share will be bought (pursuant to
the Fractional Share Program, as described within the Invest Terms). The same approach will
apply for any occasions where a sell order has to be executed within the Pie.
3.7.When setting up a Pie, you will see estimates for potential average annual performance,
which is based on a Pie’s AAR for the past 5 years for the Slices included. Exceptions and
clarifications to a Pie’s AAR calculation:
a. For Slices aged between 6 months to 5 years, we calculate an annualised return over
the entire available period;
b. We substitute slices younger than 6 months (e.g. recent IPOs) with the total stock
market’s average return;
c. We assume dividend reinvestment; and
d. We do not account for your personal tax circumstances.
By agreeing to the Terms, you expressly agree that those returns are not guaranteed and
are an illustration of what the investment results might be. Past performance is not a
reliable indicator of future results. This data does not constitute investment advice, and
Trading BitBaxter cannot be held liable for the performance of a Pie.
3.8. With time, the Weight of a Pie’s Slices can change due to market conditions. For example,
if the market price of a financial instrument that represents a particular Slice rises, its Weight
in the Pie will also rise. You have the option to manually rebalance your Pie if the latter
occurs. Rebalancing will bring your Pie back to your set Weight target.
3.9. If you decide to use the above-mentioned option, you will see an overview of the buy
and sell orders that have to be made in order to rebalance the Pie and bring it back to the
targeted Weight. As you agree with the rebalance, you will be giving a number of buy and
sell orders to the Trading Platform to be executed. As market prices can be volatile certain
adjustments in the execution might occur to achieve the required result. Each of the
rebalancing transactions might have tax implications, for which you are solely responsible.
The Feature does not support limit orders or stop orders.
3.10. You can invest or extract funds from the Pie as you wish at any point in time. When
investing, you can only add from the available funds within the account. When investing or
extracting funds, you can choose between 3 options of how the funds are to be distributed:
a. Self-balance: you would invest/extract the funds, and buy/sell orders will be made so
that the Pie is rebalanced. If the invested funds are insufficient for complete
rebalance, only partial adjustment will be done to bring the Pie closer to the target
b. Target: the funds will be distributed with the targeted Weight set up by the Pie,
regardless of the current state.
c. Custom: you would specify the exact distribution of funds.

4. AutoInvest.

4.1. AutoInvest allows you to set up recurring deposits for each Pie. AutoInvest would allocate
the deposited funds automatically in proportion to the targeted Weight of each Slice. By
turning on the AutoInvest functionality for a Pie, you agree, understand, and you give specific
instructions for a buy order to be made in accordance with your previously set Weight target
every time a deposit is funded to the Pie. Any surplus cash after buy orders have been
executed will remain as a credit in your account.
4.2. Trading BitBaxter will only execute a buy order if you have sufficient deposit funded to the Pie
to satisfy the cost of each order and any related charge.
4.3. In the event that you set up your payment card as the recurring deposit method, you
duly authorise our acquiring bank to store and use your cardholder data on our behalf in
respect of every subsequent recurring deposit transaction until the recurring payment is
terminated by you.

5. Cancellation.

You have the option to cancel the Feature and/or the AutoInvest functionality on the Trading
Platform at any time. We reserve the right to suspend or terminate the Feature at any time.
When exercising this right, we will ensure you are provided with at least a 30-day prior
written notice before such suspension or termination takes place.

6. Investment decision.

6.1. You expressly declare that you do not expect Trading BitBaxter to propose or in any way
recommend transactions in order to serve specific investment objectives. You acknowledge
that the decisions made under these arrangements and the types of financial instruments
that may be included as Slices in your Pie are your own responsibility. The types of
transactions that may be carried out in such financial instruments, including any limits, if
applicable, are defined, managed and determined by you.
6.2. The Feature is addressed to investors who have decided beforehand to carry out
transactions in financial instruments and, thus, have profit-making investment objectives.
You are at all times solely responsible for establishing whether a transaction is suitable for
you, and you rely solely on your own judgement in deciding whether to enter or refrain from
entering a transaction or in deciding how to meet any profit-making objective.
6.3. You hereby acknowledge that at any time, at your sole discretion, you can stop, pause,
restrict and/or limit any execution of pending orders performed by you via the Feature. We
shall not assess the appropriateness of the Feature for you by reference to your knowledge,
experience and understanding of the risks involved.
6.4. Although the Feature has been integrated with Trading BitBaxter so that Pie orders are
executed immediately, deviations may occur due to the following:
a. In case of delay between the order and the execution price, which is attributable to
the structure and function of the market;
b. The time period, even if very short, between the moment a signal is received from the
system and the moment of the transmission for the execution of your order by
Trading BitBaxter;
c. The special events occurring in the market, such as a steep price fluctuation (for
example, in the case of a news announcement), a great volume of transactions
waiting to be executed by Trading BitBaxter or by the liquidity provider(s) of Trading BitBaxter;
d. On occasions where the funding of the Pie cannot be processed or is delayed, the
execution might not be completed or can be delayed.
6.5. Trading BitBaxter does not offer or give investment advice, any other form of recommendation,
or any type of investment management services. All transactions within the Pie (regardless
of whether they are manual or through AutoInvest) are set up by you with respect to the
parameters configured within the Pie. The opening of such transactions shall not require any
prior consultation, consent or approval.

7. Pie Copying.

7.1. Pie Copying is a tool limited to pre-filling financial instruments and their Weight during
the creation of a Pie based on another Pie creator’s preferences. No Pies will be created
based on any personal or other criteria. You retain full control and responsibility over the
process and can change any pre-filled data. Pies are not displayed or filtered in
accordance with information inputted by Trading BitBaxter’s clients, and clients are required to
self-select any Pies.
7.2. Pie Copying only sets up the initial state of the Pie and will not reflect any subsequent
changes to the copied Pie. We will notify you whenever a Pie that you’ve copied has been
updated or reshuffled. You may then review and either apply or skip the update.
7.3. You acknowledge that you are using this tool at your own discretion, and Trading BitBaxter
cannot be held responsible for any losses arising from:
a. actions taken by Trading BitBaxter in order to carry out your instructions;
b. decisions or actions taken by another Pie creator, whose Pie you have chosen to copy;
c. specific investment decisions or actions taken or omitted in good faith by any copied
7.4. The Pie Copying tool does not amount to any form of discretionary investment
management. Trading BitBaxter does not provide personalised investment recommendations,
investment advice, tax-related advice or other financial-related advice of any kind. Any
explanation or information which we give to you as part of Pie Copying or about the
performance of a Pie is not intended to be and should not be considered as advice. This
information is provided to you solely for informational purposes.
7.5. Trading BitBaxter cannot provide any guarantee as to the performance of any Pie or any Slices
of a Pie. Past performance and any information with respect to Pies are indicative of future
performance. Trading BitBaxter does not represent or guarantee that you will achieve profits or
losses similar to those shown on the Pie that you are copying.

8. Other Provisions.

8.1. The Feature may be temporarily unavailable from time to time for maintenance or other
8.2. You understand that any deposits to or withdrawals from a Pie may trigger buy or sell
transactions, as well as impact the performance of a Pie.
8.3. Trading BitBaxter reserves the right to change the design and functionality of the Feature. Any
changes to the functionality of the Feature will be performed with 30-day prior written
8.4. Trading BitBaxter reserves the right to amend these Terms at any time with a 30-day prior
written notice. We will notify you about any changes to the Terms by updating the Terms,
and we recommend that You regularly check for any such updates.
9. Limitation of Liability.
9.1. Your access to and use of the Feature is done at your own risk and responsibility. No
information, whether oral or written, obtained from us through the Feature will create any
warranty or representation if not expressly stated in these Terms.
9.2. The Feature disclaims all representation and warranties of profitability, achieving
financial results, title, merchantability or similar. The Feature cannot guarantee any specific
results from its use.
9.3. Trading BitBaxter does not warrant that the Feature will meet your needs or that they will be
uninterrupted, timely, secure or error-free. Trading BitBaxter also makes no warranty that the
results obtained from the use of the Feature will be accurate or reliable or that the quality of
any products, services, information, or other material purchased or obtained by you through
the Trading BitBaxter Platform will meet your expectations.
9.4. You hold full responsibility for the operation of a Pie, starting with setting it up, making
amendments, deleting it, depositing and withdrawing funds from it. Trading BitBaxter cannot be
held liable for any of those actions and is merely providing the tools for you to invest.
9.5. Trading BitBaxter is not responsible for any user-generated content (i.e. texts, images, links to
external websites, shared investment Pies and others) shared on our Website or Social
Functionality. Any information shared in our Social Functionality should not be considered
investment advice and should be treated with caution and verified with other sources.

When investing, your capital is at risk. Investments can rise and fall and you may get back less than you invested.

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