Aanvullende voorwaarden lijfrente

Vive Invest B.V.

De onderstaande aanvullende voorwaarden gelden als u fiscaal belegd (lijfrente beleggen).

1. Voorwaarden voor Lijfrente beleggen

1.1 Deze Voorwaarden gelden alleen als u gebruikmaakt van fiscaal vriendelijk beleggen. Dit wordt vaak aangeduid als een lijfrente. Deze voorwaarden gelden naast de voorwaarden voor vermogensbeheer. Deze aanvullende voorwaarden noemen wij Lijfrente Voorwaarden.

De Lijfrente Voorwaarden zijn in overeenstemming met de op dit moment toepasselijke fiscale wet- en regelgeving, waaronder de Wet inkomstenbelasting 2001. Veranderen de fiscale regels? Dan passen we automatisch deze voorwaarden, maar uitsluitend voor zover nodig om te voldoen aan de fiscale regels.

1.2 Een Lijfrenterekening bij Vive Invest mag alleen worden gebruikt voor pensioenopbouw. De lijfrenterekening is een zogenaamd opbouwproduct.

1.3 De Lijfrenterekening is niet bedoeld voor pensioenuitkeringen. Daarvoor heeft u een uitkeerproduct nodig. Voor uw pensioendatum moet u kiezen waar u een uitkeerproduct wilt kopen. Dat kan bij een andere aanbieder. Het opgebouwde pensioen wordt dan gebruikt om op vaste momenten geld uit te keren. Zo ontvangt u iedere periode een bepaald bedrag. Hoeveel dat is hangt af van hoeveel u pensioenvermogen heeft opgebouwd.

1.4 Let op! U mag zelf beslissen hoeveel u stort op uw Lijfrenterekening. Maar als u meer stort dan uw jaarlijkse ruimte dan heeft dat fiscale gevolgen. Lees meer over de fiscale ruimte en wat dat is op www.belastingdienst.nl. Vive Invest controleert niet of u minder of meer dan uw fiscale ruimte aan inleg stort. Vraag hierover advies aan uw fiscaal of financieel adviseur.

1.5 Het ingelegde bedrag kunt u, zolang dat past binnen de regels van de Wet inkomstenbelasting 2001, aftrekken bij uw belastingaangifte. Vraag hierover advies aan uw fiscaal of financieel adviseur.

2. Wat is fiscaal beleggen?

2.1 Fiscaal beleggen betekent dat u vermogen opbouwt voor de oude dag. Het is niet de bedoeling om tussentijds geld op te nemen. De beleggingen vinden plaats via een beleggingsrekening die specifiek is bedoeld voor uw pensioen. Dit noemen wij de Lijfrenterekening. Deze rekening valt in box 1. Meer over fiscaal beleggen vindt u op de website van de Belastingdienst www.belastingdienst.nl.

3. Wie kan fiscaal beleggen?

3.1 Het openen van een Lijfrenterekening is uitsluitend mogelijk voor een particulier die:

(i) 18 jaar of ouder is;

(ii) Niet handelt in de uitoefening van een beroep of bedrijf;

(iii) In Nederland woont en daar belasting betaalt; en,

(iv) De rekening alleen gebruiken om pensioen op te bouwen als u te weinig pensioen heeft.

3.2 De Lijfrenterekening staat op naam van één persoon. Die persoon is de rekeninghouder. U zelf dus. Een en/of Lijfrenterekening is dus niet mogelijk.

4. Vraag fiscaal advies aan!

4.1 Vraag fiscaal advies aan voordat u fiscaal gaat beleggen. Wij geven daarover geen advies.

5. Wanneer en hoe ontvang ik mijn pensioen?

5.1 Om het geld op uw Lijfrenterekening te ontvangen, moet u een uitkeringsproduct kiezen. Dit kunt u doen bij een andere aanbieder.

5.2 De uitkeringsfase vangt aan uiterlijk op 31 december van het vijfde kalenderjaar na het jaar waarin u met pensioen mag. Houd hiermee rekening als u een uitkeringsproduct afsluit. Vive Invest biedt geen uitkeringsproduct aan.

6. Kan ik tussentijds geld opnemen?

6.1 U mag tussentijds geld opnemen van uw Lijfrenterekening. Maar dat is niet verstandig omdat u een soort boete moet betalen aan de Belastingdienst. U gebruikt namelijk het geld dat u opneemt dan niet voor uw pensioen en juist daarvoor gelden de belastingvoordelen.

6.2 Wilt u toch geld opnemen? Stuur dan een verzoek aan Vive Invest. Wij zullen dan het opgenomen bedrag overmaken naar uw tegenrekening. U rekent zelf af met de Belastingdienst.

7. Wat gebeurt er bij overlijden?

7.1 Uw erfgenamen moeten ons zo spoedig mogelijk informeren over uw overlijden. Wij hebben ook bewijs van uw overlijden nodig, bijvoorbeeld een kopie van een overlijdensakte.

7.2 Na uw overlijden mogen uw erfgenamen binnen de wettelijke beslistermijn gebruiken voor een nabestaandenlijfrente. Uw erfgenamen kunnen dat bij ons doen. Deze termijn eindigt op 31 december van het tweede kalenderjaar na het jaar van overlijden. Als dat niet op tijd gebeurt, dan ziet de Belastingdienst dit als afgekocht. Uw erfgenamen moeten dan afrekenen met de Belastingdienst.

7.3 Tussen het moment van overlijden en het moment waarop de erfgenamen het geld gebruiken voor een nabestaandenlijfrente bij Vive, geldt het volgende:

(i) Er is geen stortingsverplichting van uw erfgenamen; en,

(ii) Het saldo dat op het moment van overlijden aanwezig is op de Lijfrenterekening blijft onder beheer van Vive Invest totdat uw erfgenamen bij Vive Invest aangeven dat zij iets anders willen. Vive Invest zal tot dat moment het beheer van de beleggingen doorzetten volgens de voorwaarden zoals die met u zijn overeengekomen voorafgaand aan het overlijden. Erfgenamen kunnen Vive Invest schriftelijk vragen om het beleggingsbeleid aan te passen.

7.4 Zijn er erfgenamen? En wil iedere erfgenaam een uitkeringsrekening? Dan moet een uitkeringsproduct worden gekozen bij een andere aanbieder. Vive Invest doet dit niet.

8. Fiscale zaken die u moet weten

8.1 Als u te veel inlegt, het geld niet op tijd gebruikt of te vroeg opneemt, moet u misschien belasting betalen. U bent zelf verantwoordelijk voor hoe u dit fiscaal regelt. Vive Invest verstrekt geen advies en is voor uw belastingzaken niet verantwoordelijk.

Wij beheren uw vermogen

1. U heeft vermogensbeheer bij ons. Dit betekent dat u ons opdracht geeft om voor u te beleggen. Dat doen wij op basis van de afspraken die wij met u maken, bijvoorbeeld om pensioen op te bouwen. Die afspraken staan in uw beleggingsplan. U hoeft dus zelf geen effectenorders op te geven. Worden uw Beleggingen meer waard? Dan is de winst voor u. Worden uw Beleggingen minder waard? Dan is het beleggingsverlies ook voor u.

U informeert ons

2. U heeft ons informatie gegeven over uw persoonlijke omstandigheden waaronder uw doelstelling. Wij houden daar rekening mee als wij voor u beleggen. Veranderen uw persoonlijke omstandigheden? Dan moet u ons dat zo snel mogelijk laten weten. Doet u dat niet? Dan moet u rekening houden met financiële teleurstellingen.

Uw beleggingsplan

3. U heeft met ons een beleggingsplan afgesproken. Hierin staat hoe en met welke risico’s wij voor u beleggen. Ook staat in dit plan waarin wij voor u beleggen. Dit plan voeren wij voor u uit. In de Vive App ziet u precies hoe wij beleggen en met welk resultaat.

Bewaarinstelling

4. U heeft een Beleggingsrekening. Op deze rekening staan uw Beleggingen (en geld) bij Vive Custody B.V. geadministreerd. Deze B.V. bewaart en administreert uw Beleggingen. Hoe dit precies werkt en wat dit betekent staat in het Reglement bewaarinstelling Vive Custody B.V. Belangrijk is dat uw Beleggingen en geld veilig zijn als Vive failliet gaat.

Toestemming (volmacht)

5. U geeft aan ons toestemming om uw Beleggingsrekening te gebruiken om voor u te beleggen. Controleer altijd uw Beleggingsrekening en de informatie die wij u geven. Doet u dat niet? Dan kunnen wij u misschien niet helpen als er bijvoorbeeld iets mis is gegaan.

Belangrijke informatie

6. Alle belangrijke informatie over ons vermogensbeheer staat in dit contract en wat daarbij hoort. U heeft van ons ontvangen en gaat akkoord met:

a) algemene voorwaarden vermogensbeheer;

b) aanvullende voorwaarden lijfrente;

c) het Beleggingsplan dat u met ons afspreekt;

d) het Reglement Bewaarinstelling Vive Custody B.V.

Onze fee

7. U betaalt voor ons vermogensbeheer. Welke kosten dat zijn leest u in ons tarievenoverzicht op onze website.

Reglement Bewaarinstelling

Vive Custody B.V.

1. Hoe werkt de Bewaarinstelling van Vive Invest?

1.1 Hieronder leggen wij uit hoe de Bewaarinstelling Vive Custody B.V. (“Bewaarinstelling”) werkt. Deze Bewaarinstelling hoort bij Vive Invest maar is juridisch apart gezet in een B.V. Dat doen wij om uw Effecten en gelden veilig te stellen als Vive Invest onverhoopt failliet gaat. Dat moet ook van de wet.

1.2 In de onderstaande tekening staat wie wat doet. Onderaan de tekening staat een uitleg

Uitleg:

1. U heeft een vermogensbeheerovereenkomst gesloten met Vive Invest.
2. U heeft een overeenkomst gesloten met Vive Invest en de Bewaarinstelling op grond waarvan de Bewaarinstelling de juridisch gerechtigde is en u economisch gerechtigde bent tot de financiële instrumenten. De Bewaarinstelling administreert en neemt de Effecten op eigen naam, maar ten behoeve en voor rekening en risico voor u in bewaring. U verkrijgt een vordering luidende in Effecten op de Bewaarinstelling.
3. De Bewaarinstelling bewerkstelligt dat Vive Invest voldoet aan de regels van vermogensscheiding: in geval van faillissement van Vive Invest, behoren de beleggingen niet toe aan de boedel van Vive Invest.
4.  De Bewaarinstelling koopt (ten behoeve van u) direct Effecten aan in bepaalde Fondsen of uitgevende instellingen.

2. Uw afspraken met de Bewaarinstelling

2.1 Dit Reglement bevat de afspraken die gelden tussen u, Vive Invest en de Bewaarinstelling.

2.2 De afspraken tussen u en Vive Invest staan in de Klantovereenkomst (en de daarin vermelde voorwaarden en documenten). Dit Reglement hoort bij de Klantovereenkomst.

2.3 Vive Invest garandeert dat de Bewaarinstelling haar verplichtingen tegenover alle Klanten nakomt. Om die reden is Vive Invest partij bij dit Reglement.

3. Wat doet de Bewaarinstelling voor u?

3.1 Vive Invest maakt gebruikt van de Bewaarinstelling om uw vermogen van haar vermogen te scheiden. Gaat Vive Invest failliet dan blijven uw Beleggingen en de Effecten buiten het faillissement van Vive Invest.

3.2 Als Vive Invest voor u belegt, dan koopt of verkoopt de Bewaarinstelling Effecten.

3.3 De Bewaarinstelling doet dat alleen op verzoek van Vive Invest. De Bewaarinstelling beheert uw Beleggingen niet. Dat doet Vive Invest. Het geld dat Vive Invest voor u belegt komt van uw Beleggingsrekening.

3.4 De Effecten zijn (juridisch eigendom) van de Bewaarinstelling. De Effecten staan op naam van de Bewaarinstelling. De Bewaarinstelling heeft hiervoor een effectenrekening bij een bank.

De Bewaarinstelling doet dit ook voor andere Klanten. Op die rekening van de Bewaarinstelling bij de bank staan dus alle Effecten van alle Klanten van de Bewaarinstelling.

3.5 U krijgt Beleggingen. Dat zijn vorderingen op de Bewaarinstelling luidende in financiële instrumenten in de zin van de Wet op het financieel toezicht. Deze vorderingen luiden uitsluitend in hele Effecten.

3.6 De Bewaarinstelling zorgt ervoor dat al haar Effecten gelijk in waarde zijn aan alle Beleggingen.

3.7 Uw Beleggingen staan geadministreerd op de Beleggingsrekening die u aanhoudt bij Vive Invest.

3.8 U kunt niet de Bewaarinstelling vragen om aan- of verkoopopdrachten van Beleggingen. Dat kan alleen Vive Invest. Vive Invest doet voor u aan- en verkopen zoals is afgesproken in de Klantovereenkomst.

3.9 U kunt schriftelijk verzoeken om uitlevering van Beleggingen of Effecten bij de Bewaarinstelling of bij Vive Invest. Vive Invest brengt hiervoor een vergoeding in rekening.

4. Stemrecht

4.1 Uitgevende instellingen houden regelmatig – meestal één keer per jaar - een vergadering voor beleggers waarin kan worden gestemd. De Bewaarinstelling is juridisch eigenaar van de Effecten en heeft in die hoedanigheid een stemrecht. De Bewaarinstelling zal haar stemrecht in vergaderingen voor beleggers niet uitoefenen. U kunt als Klant via Vive Invest de Bewaarinstelling vragen om een stemvolmacht te verlenen zodat u zelf uw stem kunt uitbrengen met betrekking tot uw Effecten. Om gebruik te kunnen maken van deze stemvolmacht, dient u contact op te nemen met Vive Invest via support@viveapp.com.

4.2 De Bewaarinstelling is niet verplicht om het stemrecht op Effecten uit te oefenen.

5. Dividend

5.1 Keert een uitgevende instelling dividend/coupon uit in geld? Dan zal Vive Invest aan de Bewaarinstelling opdracht geven om dit dividend te herbeleggen conform uw beleggingsmandaat. De uit dit dividend verkregen Beleggingen worden dan bijgeschreven op uw Beleggingsrekening.

5.2 Keert een uitgevende instelling dividend/coupon uit in Effecten? Dan wordt dat dividend in de vorm van Beleggingen op uw Beleggingsrekening bijgeschreven.

5.3 Keert een uitgevende instelling naar keuze dividend/coupon uit in geld of Effecten? Dan zal Vive Invest aan de Bewaarinstelling opdracht geven te kiezen voor Effecten. De Beleggingen worden bijgeschreven op uw Beleggingsrekening.

6. Verantwoordelijkheid beleggingsverliezen en schade

6.1 De Bewaarinstelling is aansprakelijk voor de eventuele door u geleden schade, voor zover die schade het gevolg is van verwijtbare niet-nakoming van de op de Bewaarinstelling tegenover u rustende verplichtingen.

6.2 Vive Invest garandeert tegenover u dat de Bewaarinstelling haar afspraken uit dit Reglement nakomt.

6.3 De Bewaarinstelling en Vive Invest zijn niet verantwoordelijk voor schade die ontstaat doordat een uitgevende instelling haar afspraken niet nakomt tegenover haar eigen beleggers (waaronder de Bewaarinstelling).

7. Wanneer eindigt dit Reglement?

7.1 Dit Reglement (uw rechtsverhouding met de Bewaarinstelling) eindigt op hetzelfde moment als waarop de Klantovereenkomst tussen u en Vive Invest eindigt. Zegt u de Klantovereenkomst met Vive Invest op? Dan zegt u ook uw afspraken met de Bewaarinstelling op.

7.2 U kunt niet alleen dit Reglement (uw rechtsverhouding met de Bewaarinstelling) beëindigen; het is onderdeel van de Klantovereenkomst.

7.3 Als de Klantovereenkomst eindigt dan voert de Bewaarinstelling alle (eventuele) door Vive Invest gegeven opdrachten nog uit. Dat zijn lopende opdrachten of opdrachten die nodig zijn om het voor u gevoerde vermogensbeheer af te wikkelen. Daarbij blijven de afspraken uit dit Reglement geldig.

7.4 Als de Bewaarinstelling stopt, zoekt Vive Invest een vervanger. De Bewaarinstelling mag haar rechtsverhouding met u over laten nemen door een nieuwe vennootschap (contractsovername).

U stemt met deze vervanging en/of contractsovername, nu al in.

8. Veranderingen in en aanvullingen op het Reglement

8.1 De Bewaarinstelling mag dit Reglement op ieder moment helemaal of voor een deel veranderen of aanvullen. Een aanpassing gaat pas in als u daarover een e-mail hebt gekregen.

8.2 Is een verandering of aanvulling nadelig voor u? Dan gaat deze aanpassing pas in 1 maand nadat Vive Invest (namens de Bewaarinstelling) deze aanpassing bekend heeft gemaakt. Binnen deze maand kunt u de Klantovereenkomst met Vive Invest beëindigen. Hoe u dit doet, staat in de algemene voorwaarden.

Definities

In dit reglement maken wij gebruik van begrippen. Deze begrippen staan uitgedrukt met een hoofdletter.

• Beleggingen: Vorderingen van de Klant op de Bewaarinstelling, luidende in Effecten.
• Bewaarinstelling: De Bewaarinstelling Vive Custody B.V., statutair gevestigd te Amsterdam.
• Beleggingsrekening: Een Beleggingsrekening op naam van de Klant bij Vive Invest waarop beleggingen worden geadministreerd.
• Effecten: Financiële instrumenten die de Bewaarinstelling op eigen naam maar voor rekening van de Klant aanhoudt.
• Fondsen: Beleggingsinstellingen of andere instellingen waarin Vive Invest voor u belegt.
• Klant: Een klant die een Beleggingsrekening bij Vive Invest heeft geopend en een Klantovereenkomst met Vive Invest heeft gesloten.
• Vive Invest: Vive Invest is gevestigd te Amsterdam.
• Reglement: Het onderhavige Reglement Bewaarinstelling Vive Custody B.V.
• Klantovereenkomst: De overeenkomst op basis waarvan Vive Invest uw Effecten beheert (vermogensbeheer).

Introduction to SFDR Documentation

Vive classifies itself as light green according to the Sustainable Finance Disclosure Regulation (SFDR). This is also known as an SFDR Article 8 classification. Light green investment firms are required to make the information below available. Since Vive does not provide model portfolios but must provide information about specific portfolios, the information is given for three 'example' portfolios. It is important to mention that this is an example based on estimates and that the degree of realization of the promoted sustainable characteristics depends on the specific parameters of a Vive investment portfolio.

Hieronder volgt per "voorbeeldportefeuille" de desbetreffende documentatie.
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De Vive rendementsportefeuille

The Vive return portfolio is a model portfolio for the Vive annuity investment account when a pension investor's retirement is more than 10 years in the future.

Article 10 (SFDR) Information Disclosure - The Vive return portfolio (link to pdf download)

Article 8 (SFDR) pre-contractual information - The Vive return portfolio (link to PDF download)

​The Vive phased-out pension portfolio

The Vive de-risked pension portfolio is a model portfolio for the Vive annuity investment account when a pension investor's retirement is less than 1 year in the future.

Article 10 (SFDR) Information Disclosure - The Vive phased-out pension portfolio (link to pdf download)

Article 8 (SFDR) pre-contractual information - The Vive phased-out pension portfolio (link to pdf download)

The Vive balanced risk portfolio

The Vive balanced risk portfolio is a model portfolio for the Vive asset management account when an investor indicates a balanced risk preference for a specific plan. It concerns, to be precise, a risk preference of 10% VaR. This is a common asset management portfolio.

Article 10 (SFDR) Information Disclosure - The Vive balanced risk portfolio (link to pdf download)

Article 8 (SFDR) pre-contractual information - The Vive balanced risk portfolio (link to PDF download)

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Vision

At Vive, investing goes beyond just financial aspects. Vive includes sustainability criteria in its selection policy. In doing so, Vive strives to select investment funds and managers that excel in the field of sustainability within their category. Sustainability is approached from two sides.

1. Sustainability risks (Outside-in): Vive analyzes the sustainability risks that can affect the performance of investments, such as environmental problems, social risks and poor corporate governance. These are briefly referred to as ESG factors: Environment, Social and Governance. We integrate these risks into our investment process to make informed selection decisions that increase the robustness of our portfolios.
2. Sustainability impact (Inside-out): Vive does not have a sustainable investment objective but promotes social characteristics through its selection policy. Vive does this on the basis of the frameworks from the Sustainable Finance Disclosure Regulation (SFDR), the European legislation that promotes transparency around sustainability.

By managing sustainability risks with ESG integration, we strengthen our risk-return ratio and support our long-term goals.

Application of sustainable investing

Vive heeft geen specifieke duurzaamheidsdoelstellingen geformuleerd maar promoot sociale kenmerken. Vive selecteert beleggingsfondsen op basis van een selectiebeleid, waar rekening wordt gehouden met duurzame karakteristieken, met als doel een gebalanceerde risico-rendementsverhouding. De selectiecriteria op basis van duurzaamheid zijn gebaseerd op de volgende principes:

1. Exclusion policy: Vive only invests in funds that actively exclude investments based on a structured exclusion policy, if this is possible within the investment category.
2. Best-in-Class Selection: Vive only invests in funds that excel in sustainability within their investment category and mandate based on ESG performance and that promote ESG goals or make a positive impact in line with the SFDR criteria. To guarantee this, Vive only selects funds with:
   • Minimum MSCI ESG rating BBB
   • Minimum SFDR article 8 classification, with a preference for article 9 funds
3. Voting Rights and Engagement: Vive only invests in funds that actively exercise their voting rights and have a clear engagement strategy to encourage improvements in sustainability aspects. This is only relevant for equity funds.‍
4. Social characteristics: Vive promotes social characteristics by only investing in investment funds of which:
   • less than 0.5% of the portfolio is invested in companies with direct or indirect involvement with controversial weapons.
   • less than 0.5% of the portfolio is invested in companies that derive at least 5% of their revenue from tobacco production or at least 15% from the combined revenue of tobacco distribution, supply or retail.
   • less than 0.5% of the portfolio is invested in companies that are directly involved in highly persistent controversies. These controversies may relate to the environment, customers, human rights, labor rights or governance and are determined using the 'MSCI ESG Controversies' methodology.
   • less than 0.5% of the portfolio is invested in companies that violate the UN Global Compact (UNGC) principles.

The minimum SFDR classification is not applied to government bonds by default, as these are generally less measurable than other investment categories.

With this policy, we ensure that our investments not only meet financial requirements but also contribute to sustainable and social value, in line with the continuous development of sustainability standards and regulations.

Overzicht per criterium

1. Sustainability risks & ESG Ratings

Sustainability risks

A sustainability risk is an event or circumstance in the field of Environment, Social or Governance that may have a negative impact on the value of an investment. Examples of such risks are:

Environmental risks: Climate change can reduce the value of investments in CO₂-intensive sectors, as the business model of these companies may not be sustainable in the long term.

Social risks: Poor working conditions or human rights violations can damage a company's reputation, with negative consequences for its financial results.

Governance risks: Lack of proper governance, such as corruption or insufficient risk management, can lead to operational and financial problems.

ESG Ratings

ESG ratings measure how well a company manages financially relevant sustainability risks and opportunities. These ratings are used to identify leaders and laggards within sectors based on:

1. Their exposure to ESG risks.
2. Their ability to effectively manage these risks compared to competitors.

Vive uses MSCI ESG Ratings from MSCI to assess funds in terms of sustainability risks. MSCI ESG Ratings are designed to quantitatively measure sustainability risks in order to assess the extent to which a company is resistant to sector-specific sustainability risks. The MSCI ESG Ratings are categorized as:

1. ‍Leaders: AAA, AA‍
2. Average: A, BBB, BB‍
3. Laggards: B, CCC

These ratings apply to various investment categories, such as stocks, corporate loans and government bonds. Funds also receive a rating, based on the rating of the underlying companies in which investments are made.

What does Vive do in the area of sustainability risks and ESG ratings?

At Vive, we actively integrate the MSCI ESG Ratings into our investment policy to limit sustainability risks. Our Best-in-Class approach focuses on selecting funds that perform better than their comparable competitors within their sector on sustainability risk criteria. We use ESG ratings as an important measure within our selection process. These ratings help us to identify funds that fit within the standards of our policy regarding sustainability risks. Vive only selects funds with a minimum ESG rating of BBB, whereby we strive for the highest scores within each segment. The funds in which Vive invests score as follows based on MSCI ESG ratings.

2. Restriction of negative impact (PAI)

Principal Adverse Impact (PAI) criteria

One way to invest sustainably is to exclude investments with a negative impact on people and the environment. The Principle Adverse Impact (PAI) indicators have been drawn up to map the negative consequences of investments. This set of 64 measurable indicators evaluates the possible negative effects of an investment.

For investment products that indicate that they take into account the adverse effects of investment decisions on sustainability factors, it is mandatory to report on at least 18 of these 64 PAI indicators. Of these 18, 14 are core indicators that must be measured for all relevant investment products; in addition, 4 additional indicators may be included at your choice. The 14 mandatory indicators are:

• Greenhouse gas emissions
• Carbon footprint
• Greenhouse gas intensity of companies in which investments are made
• Exposure to companies active in the fossil fuel sector
• Consumption and generation of non-renewable energy.
• Intensity of energy consumption by sector with major climate impacts
• Negative consequences for biodiversity-sensitive areas
• Emissions in water
• Hazardous and radioactive waste ratio
• Violations of the UNGC and OECD guidelines
• Lack of procedures and compliance mechanisms for monitoring compliance with the UNGC and OECD guidelines
• Unadjusted gender pay gap
• Gender diversity of the board of directors
• Controversial weapons

What does Vive do in the field of negative impact and PAI?

Vive does not take into account any adverse effects of its investment decisions on sustainability factors.

This is because Vive currently only invests in unlisted investment funds. In Vive's current position, it is not yet readily possible to directly intervene or take targeted measures at the level of the underlying investments in these funds. For this reason, we cannot effectively limit specific negative effects in the area of sustainability.

What Vive does do is exclusively select funds with a structured exclusion policy. Vive has not drawn up any specific exclusions that the underlying funds must apply.

What do the underlying funds do in the field of negative impact and PAI?

The underlying funds in which Vive invests report on the specific negative effects (PAI indicators) that they limit through their own exclusion policies. Below is an overview of the negative effects that the funds in each Vive investment category limit.

3. Positive social and environmental contribution (SFDR)

Sustainable Finance Disclosure Regulation (SFDR) classifications

The SFDR provides a European framework for classifying investments based on their sustainability performance. Only investments that meet the SFDR requirements for 'sustainable investments' may be labeled as such. This regulation requires financial institutions to report transparently on how sustainability is integrated into their investment choices and enables investors to be better informed about the sustainability of investment products. SFDR divides products into three categories, based on the extent to which sustainability plays a role:

• Article 6: Investment products that do not actively integrate sustainability and generally do not provide specific information about the approach to sustainability risks within the investment strategy. These products are often referred to as “grey investments.”
• Article 8: Investment products that take into account the impact of investments on ESG criteria, without sustainability having to be the primary focus. These funds can pursue sustainable investment goals, but this is not mandatory. Article 8 funds are known as “light green investments.”
• Article 9: Investment products with an explicit focus on sustainable objectives, with the aim of measurable positive impact on the environment, climate or social area. Article 9 funds are focused on in-depth sustainability and are referred to as “dark green investments.”

This classification system helps investors distinguish the sustainability performance of investment products and provides a standardized basis for responsible investment choices.

What does Vive do in the field of positive social and ecological contribution & SFDR

Where possible, Vive only selects funds that at least meet SFDR Article 8 criteria, with a strong preference for Article 9 funds. However, these classifications do not apply to investments in government bonds. Vive's selection criteria do not set a minimum percentage for sustainable investments in accordance with SFDR, but only apply to the SFDR classification of the fund. Vive itself also falls under SFDR regulations as an investment product and is classified as an SFDR Article 8 product. Below is an overview of Vive's funds and the SFDR classifications.

What do the underlying funds do in the field of positive social and ecological contribution & SFDR

Funds with an SFDR Article 8 classification are not required to have a minimum target for sustainable investments in accordance with SFDR. Vive also does not set a minimum requirement for this. However, some of the funds in which Vive invests do have a minimum target for these sustainable investments.

Below is an overview of the objectives of the funds in which Vive invests, as well as the reported achieved percentages of sustainable investments in accordance with SFDR.

What is a sustainable investment according to SFDR?

Fund managers have internal policies and methodologies to measure whether an investment is sustainable in accordance with SFDR. There is no uniform set of instruments to classify an investment as sustainable in accordance with SFDR. SFDR legislation stipulates that an investment may be called sustainable under three conditions:

1. The investment must make a positive contribution to an ecological or social objective.
2. The investment must comply with the “Do No Significant Harm” principle, which means that the investment does not contribute to activities that can cause major damage, such as controversial weapons.
3. The company being invested in must meet standards for good governance practices with clear rules to prevent social problems.

If a fund manager determines that an investment meets all 3 of these conditions, then it is a sustainable investment in accordance with SFDR.

4. Environmentally sustainable investments (EU Taxonomy)

EU Taxonomy

And an investment is only classified as ecologically sustainable by the EU Taxonomy if the underlying activity makes a significant and measurable contribution to at least one of the six defined environmental objectives. In addition, it must also be demonstrated with data that the company does not significantly harm other environmental objectives (the "Do No Significant Harm" principle). The company must also meet social standards, such as the protection of labor rights and respect for human rights.

The six environmental objectives of the EU Taxonomy are:

1. Mitigating climate change: Reducing the company's impact on global warming by, for example, reducing greenhouse gas emissions.
2. Adaptation to climate change: Measures to manage the impact of climate change on the organization, for example by building dikes to protect against flooding.
3. Sustainable use and protection of water and marine resources: Promoting efficient water use and the protection of water quality.
4. Transition to a circular economy: Promoting recycling, reuse and reduction of waste production.
5. Prevention and control of pollution: Preventing and reducing air, water and soil pollution.
6. Protection and restoration of biodiversity and ecosystems: The conservation and restoration of natural habitats and the prevention of biodiversity loss

What does Vive do in the field of ecologically sustainable investments & the EU Taxonomy?

None of Vive's sustainable selection criteria relate to sustainable investments under the EU Taxonomy.

What do the underlying funds do in the field of ecologically sustainable investments & the EU Taxonomy?

None of the underlying funds in which Vive invests has an objective for environmentally sustainable investments in accordance with the EU Taxonomy.

Only the Corporate Loans Euro fund reports ex-post ecologically sustainable investments of 1.06% (31/12/2023) in accordance with the EU Taxonomy.

Continuous improvement and adaptation

Sustainability is a topic in continuous development. At Vive, we recognize that the standards, legislation and insights surrounding sustainable investing continue to evolve. We therefore continue to refine our sustainability policy and adapt it to the latest developments. This enables us to continuously align our strategy with the best practices within the sector.

‍Version management

Terms and Conditions

Vive Invest B.V.

1. Who are you making agreements with?

1.1 You make agreements with VIVE Invest B.V. (Vive).

1.2 Vive has a license from the AFM and is registered in the AFM register. The AFM and DNB supervise all financial institutions, including Vive. Information about our registration in the AFM register can be found on the website www.afm.nl.

1.3 Our address is Keizersgracht 268 (1016 EV) in Amsterdam. Our website is www.viveapp.com. We can be reached by e-mail and via the chat on our website or in our app.

2. What do we do for you?

2.1 You have asset management with us. This means that we invest for you. So you do not decide on your Investments yourself. We do that for you. We do our best to invest for you as well as possible. But it remains your money. Do your Investments increase in value? Then that profit is for you. Do your Investments decrease in value? Then the investment losses are also for you. We are not responsible (liable) for this.

2.2 How do we decide what to invest in? We do this based on the agreements you have made with us. You agree with us on the main rules for investing. For example, how much risk you want to take. These agreements are set out in the Investment Plan. We then decide what to invest in for you.

2.3 We will always send you information about your Investments and the asset management. It is important that you read this information. This way you know exactly what we are doing for you.

2.4 If we think the Investment Plan needs to change? Or do you think so? Then we will make new agreements.

2.5 To invest for you, you give us permission to open and use your Investment Account. This is an (administrative) account that you receive from the Custodian Institution, you can read about this in article 7. We will only use your money and Investments to meet our obligations arising from the Investment Plan agreed with you. We will make an overview of the money and these Investments. That overview can be found in your personal environment in our app.

2.6 You are obliged to install, activate and use the Vive app during the term of the agreement. Without the Vive app, we cannot communicate with you and you will not have access to information that is important to you.

2.7 We do not provide credit. This means that we will not purchase Investments for you if you do not have the money for it.

2.8 We agree that you will not use the Investment Account yourself. So you cannot give us investment orders.

3. Your personal circumstances are important

3.1 You have provided us with information about your personal circumstances. Your personal circumstances indicate whether you can bear the risk of losses, and whether you are willing to bear it. We take this information into account when investing. For example, you have given us information about the following:

a) What your financial position is, what your income and your assets are.

b) How much you know about investing and how much experience you have with it.

c) Your objective. By this we mean what you exactly want to achieve with the asset management.

d) What risks you are willing to take with investing and what risks you are not willing to take.

e) Other information about yourself, such as your age, education and work.

f) Your sustainability preferences (whether and how you want to invest sustainably).

Some individuals are not always allowed to invest by law or by the company they work for. Does this apply to you? Then you can let us know. We can help you with this. But you are responsible for not violating the law or these rules.

3.2 We assume that the information you have given us about your personal circumstances is correct. We may also assume that you have given us the information we have asked for, and that you yourself provide the information that you know is important to us. For example, if you know that you will soon have to sell your home and may therefore be left with a debt, or if you are getting married or divorced.

3.3 Has anything changed in your personal circumstances? Or do you expect something to change?

And is the information about your personal circumstances that we received from you no longer correct as a result? Then you must let us know as soon as possible. You can implement changes via your personal environment in our app. Then we will assess whether we need to change the Investment Plan. If you do not do this or do it too late, we are not responsible for the consequences.

Suppose you are getting divorced. This may mean that the Investment Plan needs to change. If you do not inform us that you are getting divorced, the Investments we make may no longer suit your new personal circumstances and you may no longer be able to bear an investment loss, for example.

3.4 We treat you as a retail investor. We will therefore not treat you as a professional investor, even if you ask us to do so. We do this to protect you. Professional investors include banks or (other) asset managers.

3.5 If your personal circumstances change and you are considered a US person, you are required to report this to us. In that case, we are forced to terminate our services to you.

You can find more information about whether you are a US person on the website www.irs.gov.

In the event that one or more of the following situations apply to you, you must inform us immediately:

(i) you have a U.S. passport;

(ii) you were born in the United States;

(iii) you live in the United States; and,

(iv) you have a U.S. residential or mailing address.

4. How do we execute investment orders?

4.1 We have rules about how we execute investment orders (order execution policy). You can find the order execution policy on our website.

4.2 Our goal is to achieve the best possible result for you. We will send you these rules with the agreement and they can be found in your personal environment in our app.

5. You take risk when you invest

5.1 Investments involve risks. An investment can decrease in value.

An investment may also be worth nothing at all. There are different types of investments in which we can invest. The most important information about this can also be found on your personal environment in our app and on our website www.viveapp.com.

Would you like more information? Please let us know. Then you will receive that information from us.

5.2 Do you no longer understand your Investments? Or do you no longer understand the risks of your Investments? Then you must let us know immediately. We are happy to explain.

5.3 You declare the following to us:

a) You have received enough information from us about the risks associated with each investment. You have read this information. You have also understood this.

b) You understand that your Investments can increase or decrease in value. You are never sure how much your Investments will be worth. If you have made a profit on your Investments in the past, this does not mean that this will also happen in the future.

So you can also suffer a loss. You also understand that investments that have a chance to become extra valuable can also decrease extra much in value. You not only understand this, but you also accept it.

c) You understand that you run an extra risk if you borrow money and invest it. Or if you have borrowed money and your Investments are security for repaying the loan. Your Investments may become worth less. Or worth no money at all. Then you still have to repay the loan. Or provide other security if your Investments are no longer sufficient security for repaying the loan. We advise against investing with borrowed money.

d) You do not invest with money that you need for other purposes.

6. Your fee for our management

6.1 You pay fees for the asset management. These costs are collected from the Investment Account.

6.2 These costs are listed in our cost overview, which can be found on our website.

1) A fixed fee (management fee) per year. You pay this fee in the first week of each month. We then collect the fee for the new month preceding it, so you pay in arrears. The management fee covers our operational costs, the custody costs for Vive Custody B.V., and the costs of supervision by the AFM and DNB. These are costs for the supervision they exercise over us. And part of the fixed fee is for ourselves.

2) Fund costs that may vary per portfolio.

3) One-off costs for occasional events, such as a transfer of value in the case of an annuity product.

6.3 The fixed fee depends on the money and value of your Investments in your Investment Account.

6.4 Vive has the right to change its rates. In the event of an increase, you have the right to terminate the agreement within thirty days of the announcement of this change.

You will still owe the fee for the month in which you cancel.

6.5 You give us permission to automatically debit all costs you owe us from your Investment Account.

6.6 If the contract ends, we will calculate the management fee pro rata up to and including the last day of the month in which the agreement ends.

7. Vive Custody B.V. safeguards your Investments

7.1 We use a custodian called Vive Custody B.V. (hereinafter: "Custodian"). The Custodian is a separate company. The Custodian safeguards and administers your Investments.

7.2 The Custodian ensures that Vive complies with the rules of asset segregation: in the event that Vive goes bankrupt, your Investments will not fall into Vive's estate.

7.3 You enter into a separate agreement with the Custodian (and Vive). We call this agreement the Vive Custody B.V. Custody Regulations (hereinafter: "Regulations"). These Regulations govern the relationship between you, the Custodian and Vive. You can always find these regulations in your personal environment in our app and on our website.

8. You are allowed to vote

8.1 Some Investments include the right to attend a meeting. Or to vote.

The Custodian is the legal owner of the Investments and, in that capacity, has a voting right.

8.2 The Custodian will not exercise its voting rights in meetings for investors. As a Client, you can request the Custodian in writing to grant a proxy to allow you to vote on your investments yourself. To make use of this proxy, please contact Vive via support@viveapp.com.

9. How can you send us a message?

9.1 Would you like to send us a message? Then you can do that in two ways:

1) We can be reached via the chat on our website or in the app.

2) You send an email to support@viveapp.com.

9.2 If you send us a message in a different way? For example, by fax? Or by post? And this causes misunderstandings, for example? Or delays? Then that is your risk. You cannot give us investment orders.

10. You consent to the processing of personal data

10.1 You agree that we include your (personal) data in our customer registration.

This personal data includes, among other things, your name, address and place of residence details, and the other data provided with or as a result of this agreement.

10.2 Vive will treat this data confidentially and will not make it available to third parties, except in the following cases:

1) it is necessary to carry out transactions related to this agreement;

2) To comply with legal obligations.

10.3 The General Data Protection Regulation (GDPR) applies to the processing of personal data.

11. You consent to electronic information

11.1 You will receive information from us about the asset management. You give us permission to send this information to you electronically, for example by e-mail, or to your personal environment in our app.

11.2 We expect you to regularly monitor your personal environment in our app so that you do not miss any important information.

11.3 Information that is not intended for you personally can be found on our website www.viveapp.com.

So we don't have to send you that information separately. Although we are allowed to.

12. We have rules about conflicts of interest

12.1 We have rules on how we prevent conflicts of interest with our Clients or between our Clients. Or a conflict of interest with ourselves, for example with companies that belong to us.

12.2 Is there a conflict of interest after all? Then we also have rules on how we deal with this conflict of interest. You can find all these rules on our website www.viveapp.com. Would you like more information? Please let us know and we will provide you with more information.

13. You are responsible

13.1 The risks of asset management are entirely for you. If your Investments have become worth less and you sell your Investments, you will receive less money. We are not responsible (liable) for this. You can read when we are responsible in article 16.

13.2 You are also responsible for immediately notifying us of changes in your personal circumstances (see article 3 of these general terms and conditions).

14. We provide you with information

14.1 We provide you with information about the asset management and the development of your Investments.

14.2 We make the following information available in your personal environment in our app:

a) Information about every investment order we have executed. This could be a purchase of an investment or a sale of an investment. If we have executed multiple investment orders, we will send that information all at once. We will do this no later than 1 day after the investment order has been executed.

b) Information about the asset management we do for you. For example, about the value of your Investments at that time and which Investments you have exactly. We will send you this information every 3 months. We also send you information about the costs.

c) Information about how your Investments meet your preferences and objectives and thus are still suitable for you. We provide this information annually.

(d) Information about a loss of 10% of the total value of your portfolio as determined at the beginning of each reporting period or a multiple thereof. We will send this information no later than the end of the day on which this loss occurred. You agree that we will therefore not report to you a 10% decline in the value of each investment but only in the event that the total value of your portfolio declines by 10% (or more).

All this information is given to you in your personal environment in our app.

15. Always check our information

15.1 Have you received any information? For example, confirmations or statements? And is this information incorrect? Or do you disagree with an investment order we have carried out? For example, because you believe that it is not covered by the Investment Plan? Then you must let us know immediately. Do you not let us know within 5 days? Then we may assume that the information and related investment instructions we gave you were good.

15.2 If you do not notify us within 30 days after we have made the quarterly report available to you that you do not agree with it, we will assume that you are in agreement with the management conducted by us during that period.

15.3 Are you expecting a notice from us or should you know that you should get a notice from us? But you do not receive that message? Then you must let us know as soon as possible.

16. When are we responsible (liable) and when are we not?

16.1 Do you have a claim? Is that damage caused by our management? And are we seriously at fault for this or is it due to intent on our part? Only then are we responsible for it and must pay for that damage.

16.2 We are therefore not responsible for other damages. For example, if you have damage in the following situations:

1) If your claim results in other damages.

2) If you do not meet the goals you have for wealth management.

3) If we had to take measures that follow from the law or from the regulator, or due to special circumstances.

Force majeure

17.1 We are not responsible for damages if we cannot do what we should or have invested due to force majeure. What is force majeure? That is, for example, failure of systems, power failure, fire, or other circumstances beyond our control.

18. We may change our arrangements with you

18.1 We may always change our arrangements with you. For example, the rules we have made about how we execute investment orders to get the best possible result for you (order execution policy).

We will let you know via personal area in our app. Or we will send you a letter or email. The change will take effect immediately. Or on a date we have chosen. That date is never in the past.

We will not change your Investment Plan without consulting you.

18.2 Is a change detrimental to you? Then the change will only take effect 30 days after we have announced the change. Do you disagree with these changes? Then you can stop the contract. How you stop the contract is in Article 19 of these conditions. Do we not hear from you? Then you agree to those changes.

18.3 If a law imposes new requirements on our agreement that require the agreement with us to change, the change will take effect immediately. We do not need permission to do so.

19. When does your contract with us end?

19.1 Our contract does not have an end date.

19.2 You can stop the contract. We can also stop the contract. You can do so any day. However, you and also we must give one month's notice. This is always done by the end of a subsequent month. As long as there are funds or Investments in your Investment Account, we will calculate the fixed charges we receive from you on the last day of the month.

19.3 In some situations, we may choose to terminate the contract immediately or temporarily. No notice is then required. These are the following situations:

(a) If you apply for a moratorium (suspension of payments);

(b) If your bankruptcy is filed;

(c) If you are a business and it is dissolved;

(d) If the debt restructuring scheme applies to you;

(e) You die and we receive a certificate of inheritance or executorship and with it a request to stop managing;

f) If a receiver or trustee decides about your money and Investments;

g) If continuation of our relationship is no longer allowed by law, court or seriously damages our reputation;

h) If you refuse to cooperate to enable Vive to comply with regulations; to combat money laundering and other financial crime;

(i) If you are a US person; or

j) If you move to a country on the European Union sanctions list.

Have we temporarily stopped our work for you? Then if we can, we will consult with you, the trustee or administrator about whether the contract should stop.

19.4 Does the contract end? Then we stop investing for you. Did we already carry out an investment order? But has that investment order not yet been completed? Then that investment order will still be completed.

If the contract ends, we will liquidate your portfolio within two weeks and deposit the released money into the contra account known to us. If you still need to pay a fee to us, we will first offset it against the funds in your Investment Account. You may decide how we sell your Investments after the contract. You must let us know in good time. It must be easy to carry out and be completed within two weeks. Do you say nothing? Then we will decide as we see fit. This can mean that we sell all our investments on one day.

If your contra account is incorrect or no longer in your name and we still cannot reach you after 6 months to return your money, you authorize Vive to donate your money to charity.

Extradition

20.1 You cannot request delivery of Securities held by the Depository.

21. If we go bankrupt

21.1 We are covered by the investor compensation scheme. The bank we work with is also covered by the investor compensation scheme.

21.2 Your Investments are segregated from Vive through the Custodian. If we go bankrupt, your Investments and funds are outside the bankruptcy of Vive. Your Investments and funds are held by the Custodian. You will retain your claim against the Custodian in the event of Vive's bankruptcy.

Death 22.

22.1 If you, as a natural person, are the sole account holder or the sole director of the legal entity and you die, then (to the extent that no succession has yet been provided for) the scope of the asset management will be limited for one year after death to legal acts that - in our judgment - cannot be postponed without disadvantage.

This includes, for example, giving orders to the custodian bank to execute orders that seek to sell and close positions.

22.2 One year after death, the management mandate will automatically cease. We will sell or, if applicable, close your positions within a reasonable period of time prior to that time and deposit the proceeds in the contra account linked to the deposit.

23. Do you have a complaint?

23.1 Do you have a complaint or comment? If so, please let us know. How to do so is in your personal environment in the app and on our website www.viveapp.com.

23.2 Have you received a response to your complaint from us? And do you disagree with it? Then you can submit your complaint within three months to the Financial Services Complaints Institute (KiFiD), PO Box 93257, 2509 AG The Hague. You can also submit the complaint via www.kifid.nl.

You can find more information about the KiFiD on our website.

You can also go to court with your complaint.

Dutch language 24.

24.1 The contract containing these terms and conditions and all other information from us regarding asset management are in Dutch.

24.2 Have we received information about Investments that is in English? Then you will also receive that information in English. Do you not understand that information? Then let us know. Then we will explain it to you.

25. Dutch law shall apply

25.1 The contract and these terms and conditions shall be governed by Dutch law.

25.2 The District Court in Amsterdam shall have jurisdiction to resolve any disputes between us by judgment.

Protocol Streamlining Capital Transfers (PSK)

If you have built up tax-efficient pension capital with another provider and you wish to transfer this capital to Vive (or vice versa) without immediate income tax, the Protocol Stroomlijning Kapitaaloverdrachten (PSK) offers a solution. This document explains how to arrange such transfers. This also applies to the transfer of pension capital from Vive to another provider.

Vive Pension Plan

Vive's pension plan includes:

• A personal annuity account.
• A diversified investment portfolio.
  
• An investment strategy.
  ‍

The annuity account is blocked to prevent unintended withdrawals, which can lead to tax consequences, such as the direct deduction of income tax and possible revision interest. Contributions to this account may be tax deductible. Transfers to or from another provider, without direct income tax, are possible under certain conditions.

PSK

Vive is affiliated with the PSK to ensure the transfer of accrued capital runs smoothly and without direct tax consequences. This protocol, supported by the Dutch Association of Insurers and the Dutch Banking Association, ensures a 'tax-neutral' transfer of value, where there is no need to immediately settle with the Tax Authorities.

Avoiding income tax

A transfer of value must be done carefully, because otherwise the Tax Authorities can levy tax on the accrued capital. The Dutch Association of Insurers and the Dutch Association of Banks have therefore made mutual agreements to ensure that a transfer of value runs smoothly. This is called "tax neutral". This means that the transfer takes place in such a way that there is no need to settle with the Tax Authorities in the interim. These agreements are laid down in the PSK. The parties affiliated to the PSK (such as banks, insurers and investment institutions and companies) have agreed procedures with regard to the transfer of value of fiscally facilitated products to another provider. Vive is affiliated with the PSK and works according to this protocol.

Read more about the PSK on the website of the Dutch Banking Association (NVB) or on the website of the Verbond van Verzekeraars.

Advice on value transfer

You are responsible for choosing to transfer value to or from Vive. If necessary, seek advice from a financial advisor to determine if doing so is a wise choice. Value transfers can have long-term tax consequences.

How does it work?

a. Transfer of value to Vive

Download the form at the bottom of this text. Sign it and send it to your current provider. Once the current provider has received the form and all required documents, they will initiate the transfer.

After this, the transfer will be carried out within fourteen calendar days. If the fourteenth day falls on a weekend or a public holiday, the first following working day will be considered the fourteenth day. Vive will send you a message as soon as the money has been transferred to Vive by the transferring PSK participant. The provider carrying out the transfer may charge fees.

Link to the form

b. Value transfer from Vive to another provider

If you decide to continue the value of your pension investment account (in the interim) with another PPI provider, please report this in the chat function of the Vive app or by e-mailing support@viveapp.com. Vive will then send an e-mail with the transfer form and an explanation of the form. The form must be fully completed, signed and returned. After receipt, Vive will complete the transfer within fourteen days. The administrative costs charged by Vive for transferring your value to another provider are: (to be determined).

Additional required documents

In some situations, additional documents are required, for example, in the event of a divorce or death. Without these documents, Vive is not allowed to transfer your money to another provider.

• Divorce: Divorce agreement.
• Death: Death certificate and certificate of inheritance.
• Power of attorney: Proof of power of attorney.
  ‍

In the event that the financial institution to which you wish to transfer the value does not participate in the PSK, the acquiring financial institution of Vive requires a disclaimer. Vive will coordinate this disclaimer with the acquiring financial institution.

Interest

If the fourteen-day period for transfer of value is exceeded, the transferring party is obliged to pay statutory interest.

Fully customized

Everything we do is based on your situation, wishes and goals.

Your ideal portfolio

We put together the ideal investment portfolio for you that exactly matches your situation, wishes and goals.

Always adaptable

You can always and everywhere change or cancel your plan, wherever and whenever you want.

A plan that fits perfectly.

We will create an investment portfolio for you that perfectly matches you and your goals. To get a good idea of who you are, we will ask you a number of questions in advance. We also map out your financial situation. We give this a score and call this your financial profile. Based on this, we estimate what risks you can take and which style of investing suits you best.

Next, you indicate what you want to invest for. For example, for your house, camper van or pension. You can also let your money work without a specific goal.

Then we execute this plan for you by implementing your investment strategy. You can always choose to adjust your plan. We immediately process your new wishes into your strategy. Do you want to take less risk? Then we will ensure that we purchase safer investments for you. Do you want to deposit less per month, but still get the same return? Then we will invest more boldly for you.

You can always see exactly which investments your portfolio consists of. You can find this in the app under plans > your plan > portfolio.

Good to know: every goal is different and requires a different plan. That's why we create a unique strategy with a suitable investment portfolio for each goal.

Introduction to risk policy

The risk policy forms the core of Vive's investment approach. Vive bases its strategies on risk budgets, with which investments are optimally aligned with the objectives and risk preferences of its customers. This enables Vive to make the investment process not only scientifically sound and efficient, but also personal and flexible.

Vive believes that a good risk policy is more than just risk management at the portfolio level. It is a dynamic process in which personal control is central. The best form of risk management is yourself. That is why Vive's risk policy is not only designed to optimize risks and returns, but also to continuously give you as an investor insight and a perspective for action.

By establishing a dynamic risk budget for each client's financial plan that can change over time, Vive ensures that investors are exposed to investment risks very accurately and efficiently. This means that you do not take unnecessary risks, but you also do not miss out on potential returns. Vive ensures that you, as an investor, always have insight and a perspective for action to maintain control over your investment risks.

What is the risk policy?

Vive's risk policy is fully aligned with the individual wishes and financial situation of the investor. Vive sees risk not as a limitation, but as a means to achieve your financial goals. The risk policy ensures that you not only have a well-diversified and efficient investment portfolio, but also the insights and tools to manage it.

While traditional institutions often work with fixed risk profiles such as defensive, neutral, or offensive, Vive opts for a customized approach. Vive recognizes that every investor is unique and that risk preferences can even differ per financial goal.

Vive, therefore, uses Value at Risk (VaR) as a core metric for risk management. This means that the maximum percentage loss over a one-year period is calculated and aligned with what you consider acceptable. Based on this metric, Vive optimizes investment strategies so that your investments remain in line with your personal risk budget and objectives.

Vive uses an internally developed Economic Scenario Generator (ESG). Through this technology, Vive can scientifically calculate the downside risks and expected returns of various investment categories, such as equities, bonds and money market instruments.

Vive offers continuous monitoring of your portfolio and closely monitors developments in relation to your personal goals. This means that you not only gain insight into the performance of your investments, but also receive concrete signals when action is desired.

Using advanced technology and scenario analyses, in which hundreds of thousands of market scenarios are calculated, Vive ensures that:‍

Risks are identified early on – You will receive timely warnings if market developments or portfolio performance deviate from the expected course.

Dynamic adjustments are possible – Your risk budget can be adjusted if necessary, so that it continues to match your personal situation and goals.

Transparency and control are central – You always have insight into how your portfolio is developing and remain in control of your financial future.

In addition to personal control, Vive also applies advanced risk management at the portfolio level. This is how risks are actively managed and adjusted where necessary. Vive uses:

Dynamic risk management – The risk budget is continuously evaluated and can be adjusted based on changing market conditions or personal goals.

Rebalancing – The portfolio is automatically adjusted as soon as it falls outside the strategic bandwidth, so that the intended risk-return ratio is maintained.

Broad diversification – Investments are spread across multiple asset classes, regions and sectors to minimize concentration risks and limit the impact of market volatility.

Scenario analyses and stress tests – The portfolio is constantly subjected to hundreds of thousands of simulated market scenarios. This allows Vive to estimate how your investments perform under different circumstances and take proactive action if necessary.

With this approach, Vive offers a carefully managed and flexible investment process, in which you, as an investor, remain in control and can make conscious choices. Together, we ensure an optimal balance between risk and return, tailored to what is truly important to you.

How is risk limited and which risk metrics are used?

Vive applies a coherent and carefully structured risk management to ensure that risks remain within acceptable limits. This is done through a combination of broad diversification, strict selection criteria, active monitoring and risk metrics that align with the client's personal goals. The following measures are applied to limit risks:

Broadly diversified portfolios
By investing globally in different regions, sectors and asset classes (such as equities and bonds), the portfolio becomes less sensitive to specific market or sector shocks. This broad diversification helps to limit overall risk and prevents excessive dependence on individual markets or companies.‍

Strict selection of investment funds
Vive invests exclusively in UCITS funds with daily tradability, sufficient diversification and transparent costs. Multiple risk-reducing criteria are used in the selection of funds, such as:

— Currency risk – Unnecessary currency risk is avoided where possible.

— Interest rate risk – The duration of bonds is carefully matched to the customer's risk preferences.

— ESG criteria – Funds are assessed on sustainability risks to minimize long-term risks and encourage responsible investment.

‍Lifecycle approach and rebalancing

— For plans with a fixed end date, the risk level can be gradually reduced as the end date approaches, reducing the chance of large losses at a critical moment.

— Rebalancing takes place when the portfolio deviates too much from the agreed risk limits (VaR) and the desired level of final goal certainty. This ensures that the portfolio remains optimally aligned with the investment strategy and objectives.

No complex or non-transparent products
Vive avoids investments in complex or opaque products, such as hedge funds and funds with complicated derivative structures. This prevents unpredictable risks, hidden costs and illiquidity, allowing investors to always maintain a clear insight into their portfolio.

Which risk measures are used?

To accurately assess risks in both the short and long term, Vive uses various risk measures that may differ per plan:

Value at Risk (VaR): The maximum accepted (negative) return within one year – given a confidence level of 95% – in a worst-case scenario. Example: A VaR of 15% means that in a bad scenario, the portfolio can fall by a maximum of 15% within one year, with a 5% chance of a greater loss.

Impairment to Mission (ITM): The maximum permitted deviation from the plan's end goal with a 95% confidence level. Example: an ITM of 30% means that in a worst-case scenario, the portfolio may deviate by a maximum of 30% from the end goal, with a 5% chance of a greater deviation. This measure is applied to plans with a specific end goal.

These metrics form the basis for the structure and risk management of each portfolio and each have their own function in determining the dynamic risk budget:

— VaR focuses on short-term risks (maximum loss within one year).

— ITM focuses on the long-term goal (maximum deviation from the final value).

In addition to client-focused risk metrics, Vive also performs internal analyses to ensure the stability and efficiency of the portfolio:

Volatility (standard deviation): This measures the volatility of the portfolio to gain insight into the degree of price fluctuations.

Tracking Error: This measures the extent to which passive investment funds deviate from their underlying index.

Through this combination of risk measures and management tools, Vive can make a thorough and objective assessment of the risk level and ensure that the portfolio optimally matches the client's investment goals and risk preferences.

How is the portfolio monitored for risk?

Vive only works with strategic asset allocation. The portfolios are automatically checked daily to ensure that they are still in line with the strategic asset allocation. For example, if shares rise or fall too sharply in relation to bonds, automatic rebalancing will follow, so that the portfolio fits back into the desired risk profile. The underlying strategic asset allocation is periodically recalculated and changed if necessary.

1. Quarterly update: Every quarter, all scenarios are recalculated based on current market conditions.
2. Annual update: The risk premiums of each investment category are evaluated annually and it is assessed whether the assumptions made earlier are still up to date.

Vive continuously recalculates your investment plan based on the most recent developments. If it turns out that the expected final goal deviates from the original forecast, the investment plan is not automatically adjusted. Instead, you will receive an 'on-track/off-track' notification. This gives you control and, if desired, you can make changes to:

— The portfolio's risk level

— The monthly deposit

— The target amount

— The plan's end date

This data-driven, systematic monitoring ensures that Vive's risk policy remains in line with your personal objectives and risk preferences at all times.

To provide complete control and insight, investors in the Vive app can always view the current structure of both the portfolio and the plan under "Strategic portfolio". If desired, adjustments can be made directly here.

With this approach, the portfolio not only remains optimally aligned with your financial goals, but you, as an investor, also maintain maximum control and transparency over your risk level and the value development of your investments.

Countless economic scenarios mapped out

So that we know exactly how our funds move through market changes.

Thousands of investment strategies calculated

Based on countless economic scenarios.

Broad portfolios with different risk levels

Our model invests in a mix of equity, bond, and money market funds.

Now available for you.

Vive has built a financial model that creates thousands of investment strategies based on numerous economic scenarios. This model puts together a mix of funds that perfectly match your goals, wishes and situation. If your plan changes, our model immediately calculates a new strategy that fits your new settings.

A strong investment portfolio consists of a broad portfolio with different types of investments. This way, the risk is spread as much as possible. Our investments are divided over different Asset Classes (investment categories). These are again spread over different geographical regions and sectors. Your money is invested by our financial model in a mix of equity, bond and money market funds. All carefully selected on cost profile, performance, risk and sustainability.

The estimates of this model are also updated every quarter to incorporate the latest market developments.

ESG MSCI

Our funds are measured for sustainability based on the MSCI ESG criteria.

People, planet and society

Our funds take people, the environment and society into account as much as possible.

Investing for the future

Our funds are chosen with a good expected return for the medium and long term.

Investing is more than putting your money to work.

The way your money works for you has an impact on the world. That is why our funds take into account the ESG criteria of MSCI. These are standards that measure the effect on people, the environment and society.

It is also important to know that sustainable investing does not have to come at the expense of performance. In fact, more sustainable funds are increasingly outperforming funds that are not. This is because recent laws and regulations have increasingly rewarded sustainability in recent years. Take companies with low CO2 emissions, for example. They are less at risk of negative consequences from new laws and regulations than companies with high emissions. This may ensure that they have broader social support in the future, and therefore become more valuable.

We are constantly looking for the balance between sustainability, costs and the highest possible return. That is why we pay a lot of attention to our fund selection.

Are you dissatisfied with Vive's services? Then we advise you to contact customer service by emailing: support@viveapp.com, or send a chat message in the app (account/ support/ chat with us). The customer service staff will gladly work with you towards a suitable solution.

If you cannot resolve the issue with customer service and your complaint remains unresolved, make it clear that you are not satisfied with the solution offered. The customer service representative will initiate the complaints procedure for you, so that your complaint can be formally processed. 

Complaints procedure

1. We have received your complaint.
This can be done via the communication channels that Vive uses. It is unavoidable that messages are sometimes lost due to technical malfunctions, for example, or otherwise. Therefore, if you do not receive a response from us after 10 working days, please always verify with us whether we have received the message.

For the sake of completeness, it is noted that this complaints procedure does not prevent you from pursuing normal legal proceedings in the Netherlands.

We would also like to note that you should file a complaint with us as soon as possible to prevent the complaint from no longer being processed due to the expired deadline. The right to file a complaint generally expires at least five years after you become aware of the subject of the complaint.

In addition to this complaints procedure, we have taken a special procedure and measures to prevent and manage conflicts of interest. These also apply to complaints. You can receive a copy of this if desired. ‍

2. The complaint is registered upon receipt.
In any case, your complaint will be registered within five working days in the manner prescribed by the regulators and included in our complaints register. The Compliance Officer monitors this and will also request additional information where necessary in order to fully understand the complaint and record it. In this and throughout the handling of the complaint, the applicable privacy regulations will be respected at all times.

The Compliance Officer supervises the business operations and therefore also the entire complaints handling process.

It is possible that you will hold us liable for the damage you have suffered in your complaint. In that case, we must also report your complaint to our professional liability insurer. They will then take over the handling of the complaint from us. We will always inform you of this.

If the complaint relates to the actions of one of the directors, the opinion of the director whose actions are being complained about will in any case be requested, as well as that of at least one of the other directors.

All complaints are registered using the complaint form. A complaint is any expression of dissatisfaction addressed to Vive by a person (both a natural person and a legal entity) relating to an investment service provided by Vive, via a channel through which Vive communicates with customers.

​3. We strive to respond to your complaint within 10 working days.
Preferably, we will handle your complaint immediately by resolving it. If this is not yet possible, you will in any case receive an acknowledgment of receipt of your complaint within this period, stating the period within which you can expect a response and what steps we will take to handle your complaint.

The assessment of the complaint will only be sent to you after approval by the Compliance Officer. If necessary, the Compliance Officer will also inform the relevant Custodian Bank, where your investments are held, about the complaint. In addition, Vive provides the AFM with timely information about complaints and complaint handling.

4. You will at all times be given the opportunity to respond to the assessment of the complaint sent to you.
If there is reason to do so, we will send you a second assessment of the complaint, taking into account your objections to the first assessment of the complaint. In the second assessment, a director who was not involved in the assessment of the first complaint will be involved where possible. In addition, the steps as under 1 to 5 will apply again.

5. If, after handling the complaint, you are still unable to agree with the first and/or any second or further assessments, you can contact KiFiD.
Below you will find the contact details of KiFiD. For the latest information, you can check www.kifid.nl.

Kifid
Postal address KiFiD: Postbus 93257, 2509 AG The Hague
Visiting address KiFiD: Kantoren Stichthage, Koningin Julianaplein 10, 2595 AA The Hague
Telephone number: +31(0)70 333 8 999
E-mail: consumenten@kifid.nlWebsite: https://www.kifid.nl

Under the laws and regulations, financial companies are required to have procedures and measures in place to prevent and manage conflicts of interest. Below you can read how Vive has incorporated the policy on conflicts of interest into its operations and the measures Vive has taken to protect the client's interest. At all times, the applicable laws and regulations take precedence and also serve as a guideline in the event of conflicts of interest.

Principles of the policy‍

Vive has established the policy in accordance with its license as an investment firm. The policy applies to all companies affiliated with Vive Group.

The policy

Vive recognizes that, as with any other investment firm, there may be potential conflicts of interest. Vive's policy is aimed at protecting the client's interest, so that a client cannot suffer material damage from this. Vive has laid down in this policy which circumstances can lead to a conflict and which measures have been taken to control and/or prevent these conflicts.

Possible conflicts of interest

Conflicts of interest can arise in the following (non-exhaustive) situations:

• Having an interest in the result of a service or transaction performed for the client that differs from the client's interest in this result;
• A conflict of interest between clients.
• Having a financial or other incentive to give priority to the interest of one client or group of clients over the interest of other clients;
• The provision of services by affiliated companies; The structure and (financing of) business operations

Because Vive's services are highly automated, the chance that Vive, or an employee of Vive, has an inappropriate influence on the way asset management is carried out for the benefit of a single client, or a group of clients, is considered extremely small. Where clients may have a conflict of interest among themselves, or otherwise have different interests, this is reported to the Compliance Officer.

Although the chance of this conflict of interest is considered small, given the service and the far-reaching degree of automation, the Compliance Officer will appoint persons to represent the interests of these clients with potentially conflicting interests.

In the event of conflicting interests, the Compliance Officer, together with the board member who is not responsible for commercial matters, will make a weighing of interests.

‍
With regard to services provided by affiliated parties, the decision-making process is structured in such a way that, in the event of a conflicting interest, the interest of the affiliated party is subordinate to the interest of (the clients of) Vive.

To ensure this, the Compliance Officer, together with Vive's management, will decide that the person in whom the affiliated party is or may be represented, will not participate in the decision-making process.

‍
Vive has established various measures, procedures and policies to identify, prevent and manage conflicts of interest. Below is a non-limitative list of a number of measures that Vive has taken to safeguard the material interests of the client.

Internal supervision

Vive has a member of the board of directors who is ultimately responsible for compliance matters. In addition, the Compliance Officer supervises compliance with the conflicts of interest policy. Agreements with affiliated parties will be assessed by the management in conjunction with the Compliance Officer on the “at arms length” principle, whereby the final decision-making authority lies with the member of the board of directors who is not involved with the affiliated party. Periodically, at least annually, the effectiveness of the policy regarding the prevention of conflicts of interest is evaluated and updated if necessary. In the event that a conflict of interest occurs that is not provided for in the policy, the Compliance Officer will immediately adjust the policy accordingly.

Remuneration policy

A specific remuneration policy has been established ensuring that the service model and the method of charging fees to clients are not based on services that are not in the client's best interest. Employees who can influence investment decisions do not receive variable remuneration. Therefore, the integration of sustainability risks into the remuneration policy is not applicable.

Private investment transaction

The personnel policy states that if an employee wishes to make a private investment transaction, this must be reported to the Compliance Officer in advance.

Gifts

In addition to the private investment transactions policy, the gifts policy and secondary employment activities policy are included in the personnel policy to manage conflicts of interest.

Commission

Vive does not receive any provisions, commissions or monetary or non-monetary benefits that are paid or provided by a third party.

Market abuse

To prevent Vive employees from using (price) sensitive information for their own gain, Vive has drawn up a regulation on private investment transactions. The regulation must ensure that (the appearance of) insider trading and mixing of business and private interests is prevented.

‍Segregation of duties

To ensure that individuals cannot misuse the system, segregation of duties is guaranteed. There is a separation between functions in which investment services are performed and functions in which the operational processes are handled for the benefit of the activities.

Communication

Any (potential) conflict of interest within Vive is reported to the Compliance Officer, who will inform the Management Board. Compliance, in consultation with the Management Board, will investigate the reports. Each report is assessed against the conflicts of interest policy. A written record is made of each relevant report, in which Vive indicates how the conflict of interest was handled.

Given the specific nature of conflicts of interest, Vive will assess each notification on an individual basis. If the organizational and administrative arrangements put in place by the investment firm to prevent or manage a specific conflict of interest are not sufficient, this will be disclosed to the clients involved in this case.

Version management

The Act on the segregation of assets and investor compensation. Companies that provide investment services must, by law, keep their own assets separate from the invested assets of clients.

If things go wrong, their clients' investments are safely in a separate fund. Vive complies with the rules of asset segregation.

The Dutch Authority for the Financial Markets (AFM) monitors whether Vive complies with the rules applicable to asset segregation. These rules ensure that if Vive goes bankrupt, our clients' investments are separated from Vive's assets. As a result, clients' investments are not included in the bankruptcy estate.

In the unlikely event of fraud and/or mismanagement at Vive and Vive cannot guarantee the rules of asset segregation, there is an investor compensation scheme for aggrieved investors.

The investor compensation scheme offers protection up to a maximum of EUR 20,000 per person and per company.

If you and your partner have a joint investment account, you are guaranteed to receive a maximum of EUR 40,000 back together.

‍More information about the investor compensation scheme can be found on the website of De Nederlansche Bank.

General

VIVE Invest B.V. (Chamber of Commerce 62098896), hereinafter referred to as Vive Invest, hereby grants you access to www.viveapp.com and all of our VIVE Invest B.V. websites where it publishes texts, images and other materials which have been supplied by Vive Invest and others.

Vive Invest retains the right to alter the contents of the Website and mobile application or remove material without having to notify you at any point in time about such changes. The information and materials on the Website and mobile application are provided “as is” and cannot be considered an offer of services or a contract proposal. Contracts and services are only established by the acceptance of duly indicated quotations or offers by Vive Invest.

‍
Liability

Although great care has been taken with the content of this Website and our mobile application, Vive Invest shall never be liable for losses or other damages that may result from inaccuracy or incompleteness of information on this Website and/or its mobile application. The materials on the Website and our mobile application are offered without any warranties, expressed or implied, and without any claims as to their accuracy. These materials can be subject to change at any given time without prior notification from Vive Invest. Especially all sums, prices and fees on the Website and mobile application are provided with reservation of type-, conversion-, and programming errors.

For the consequences of such errors no liability is acknowledged or accepted by Vive Invest. No agreement or contract with Vive Invest is established based on such errors. Studying the contents of this Website and/or our mobile application, signing up for newsletters or to send information requests can not cause any kind of relationship between Vive Invest and the receiver of the information.

This website may contain links to other websites. Vive Invest has no control over the content of those other sites and is not responsible for the content of those websites or other links to other websites. Transmission of web forms or other communications to Vive Invest without encryption or other secure means of communication and shall always be for the risk of the sender.

‍
Intellectual Property Rights

This website contains information, data, software, photos, graphics and other materials protected by copyright, trademark or other proprietary rights. The content on this Website and our mobile application may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or exploited in any manner without the express prior written consent of Vive Invest. All intellectual property rights with regards to these materials offered and available on the Website and our mobile application are the property of Vive Invest and its licensors. All intellectual property rights relating to this Website, including software, text, photographs, images and / or sounds are owned by us and / or the person from whom we have obtained a license.

At Vive Invest, we care about the protection of your data and privacy and how it applies to you, as a user of our website(s). In this Privacy Policy ('Policy'), you can find information about how, whether, and why we collect and use your personal information on our Vive Invest website www.viveapp.com and on our mobile application Vive App. This Policy applies to any personal information that is gathered when you use our services, visit our Website, or otherwise interact with us. We have divided this Policy into different sections. The processing of your personal data complies with the General Data Protection Regulation (GDPR), the Dutch GDPR Execution Act and the Dutch Telecommunications Act.

About us

The data controller for the processing of your personal data is VIVE Invest B.V., registered at the Dutch Chamber of Commerce with registration number 62098896. Our address is Keizersgracht 268, 1016 EV Amsterdam, the Netherlands.

If you have any questions about the processing of personal data resulting after reading our Privacy Statement, you can contact us at privacy@viveapp.com.

Types of personal data we collect

To assess and open Vive Website and Mobile Application accounts, we can collect and use the following personal data:

• First and last name
  
• Date, country and place of birth
  
• Nationality
  
• Gender
  
• Residential address
  
• Telephone number
  
• Email address
  
• Social security numbers and/or other tax identification numbers
  
• Counter IBAN
  
• Device data (such as type of device, operating system, IP-addresses and advertising IDs)
  
• Location data via GPS
  
• Uploaded images/content
  
• Device data of added devices and API-keys
  
• Financial and banking data, product subscriptions and transaction history
  
• Cookies and usage date on how you use our products and services
  
• Correspondence with Vive Invest and support data (telephone, chat conversations and email)
  
• Additional information related to opening an account and creating your personalized investment
  
• Plans such as your knowledge and experience of financial markets, your financial situation, investment situation and preferences and your risk preferences
  
• Marketing data (statistics related to our marketing campaigns and data to measure this)
  

Information about our communication

• When you send us an email, or chat with us online or via social media, we save your correspondence with us if you are already a customer or in the process of becoming one or contacting us to find more about our products and/or services.
  
• Information we collect when you use our Website and/or our mobile application.
  
• When you visit our Website and mobile application or use our services, we may register your IP address, browser type, operating system, referring website, web-browsing behaviour.
  
• We may receive an automatic notification when you open (or open a link from) newsletters from us.
  

Information in relation to social media

Depending on your social network settings, we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may gather publicly available information you give us access to from your social network profile, including your contact details, interests, and social network.

For more information on the personal data that we receive from your social network provider, and how to change your privacy settings, please refer to the website and the privacy policy given by your social network provider.

Information you choose to share with us

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

Purposes of processing your data

Vive Invest processes your personal data in accordance with the laws and regulations based on several legal grounds. Vive Invest processes personal data to provide our services. For example, personal data is processed to:

• Comply with legal obligations
  
• To preserve our agreement and to provide our services securely, we process your personal data. For example, we need your contact information to keep you informed about relevant developments, and we store correspondence data to improve our customer services
  
• To make your user experience easier and more effective, we may assess how you use our services and combine this data with information collected via your personal account, registration details, cookies, and similar technologies. This combination enables us to, for example, optimize our search algorithms and offer a better customer experience
  
• To create better and personalized investment strategies
  
• To process personal information for (direct) marketing purposes. This means we may use your personal information to send you newsletters, emails, promotions, or other marketing communications. We use the results of our analysis to tailor our marketing communications to your specific interests and preferences. For example, if our analysis shows that you may be interested in certain services, we may customize our newsletters and Website with content that is relevant to you. We may use different channels for our marketing communications, such as emails, social media, and your personal online account during different time frames and in a recurrent manner.
  
• To initiate and evaluate business relationships. Your personal data will be processed for entering into agreements and the performance thereof to the point of commercial services and the managing of the business relations which emerge from them, including the performance of activities aimed at the expansion of our client database.

Vive Invest is allowed to process personal data for this purpose because you gave consent or because Vive Invest has a legitimate interest. The consent can be withdrawn at any moment, and you can object at any moment to the processing of your personal data for direct marketing purposes. The withdrawal of consent or exercise of your right to object does not affect the lawfulness of the processing prior to the moment of withdrawal or exercise of the right to object.

You may object or revoke your consent for receiving marketing communications at any time, by following the instructions in the relevant marketing communication or by sending an email to privacy@viveapp.com

Legitimate and legal interests

In many cases, we are legally required to store certain data about you, for example to verify your identity, for research and to create personalized investment plans.

We can also process certain data when we have a legitimate interest to do so. For example, to prevent and combat misuse, to research and analyze the use of our products and services for marketing purposes, for information and system security or to share certain data with governmental institutions.

Disclosing or sharing data with third parties

General

We reserve the right to release personal information without your consent or without consulting you, when we deem it necessary to comply with our legal obligations, to enforce our terms and conditions, to protect the security of our Website and application, or to prevent fraud.

To be able to provide our services, we share certain personal data with third parties. We keep the sharing to a minimum and ensure these third parties will handle your personal data with the same care as we do. This means, among other things, we sign Data Processing Agreements. The third parties or categories of third parties with whom we share data are: Auth0, Onfido Limited, Online Payment Platform, Pipedrive, and Twilio.

Governmental institutions

To comply with laws and regulations, we can share data with the concerned institutions. For example, the Tax Authorities can request financial data, and we can share data with the Dutch Central Bank for participating in the Deposit Guarantee Scheme. In addition to this, Vive Invest may have a statutory or legal obligation to share personal data with investigating authorities to prevent and combat misuse, fraud, and crimes.

Security and retention

Vive Invest takes the safeguarding of your information very seriously. Vive Invest will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use. These measures include but are not limited to: facilities protected by appropriate security measures, encryption of devices, version tracking and access to our databases is limited to key personnel and IP addresses and use of it is logged. Personal identifiable information and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password.

How long we keep your personal data

We will hold all the data for so long as we have an obligation to the Customer to provide the Services, and thereafter until such time as we delete the Customer's account in accordance with our Customer Terms and Conditions.

Your personal information will be deleted on one of the following occurrences: - deletion of your personal information by you (or by another person engaged by the Customer); or - receipt of a written request by you (or another person engaged by the Customer) to us

For a large amount of data, we are legally obliged to retain this for a minimum of 5 to 7 years after ending the customer relationship. After this period, we don't store your personal data longer than legally allowed and no longer than necessary for the purposes the data was collected for.

We are able to store personal data for longer periods with a valid legal ground, or when the data is sufficiently (for example) pseudonymised or anonymised.

Your Rights

You can request access to or a copy of your personal data collected by us. You may also request the rectification and removal of personal data or the restriction of the processing of your personal data, if there is a reason for doing so. You also have the right to data portability. You also have the right to object to a processing on grounds relating to your particular situation or against the processing of your personal data for direct marketing purposes. More information on your rights is available at: https://autoriteitpersoonsgegevens.nl.

To exercise your right(s), please send us an email at privacy@viveapp.com or mail us: VIVE Invest B.V., Keizersgracht 203, 1016 DS Amsterdam, The Netherlands.

Revoking & limiting consent

When you have provided us with permission to process personal data, or when we process your personal data based on legitimate interests, you are able to revoke this permission in an easy manner or ask us to limit the use of your data. Revoking your permissions does not mean that stored data is deleted.

Direct marketing & usage data

If you do not want your data to be used for direct marketing activities and analysis of the usage of our products and services, you can let us know via the VIVE app anytime. Next to this, our communication via email contains the possibility to unsubscribe from these messages.

GPS and image and content access

While using the VIVE app, you can provide permission to process location data. If you no longer want us to use location data, you can revoke these permissions easily. This permission is also offering the possibility to protect your account, sending, for example, notifications when there is a login from an unknown location. You'll find these settings in the VIVE app. You can revoke provided permissions at any given moment.

Images and content that you use to personalise your VIVE account can be easily changed in the VIVE app.

Cookies

For more information on how to delete cookies, please see our Cookie Statement.

Modifications to this Policy

This Policy is effective as of 23 of October 2018. We reserve the right to alter or otherwise make changes to this Policy. Notices may be by email to the last email address you provided us, by posting notice of such change on our Site or the Optimizely Service, or by other communication channels. You consent to receiving notices in these ways. We reserve the right to determine the form and means of providing notifications to you, consistent with applicable law. Changes take effect as soon as the Policy is posted.

Questions or complaints

If you have any question or complaints about the processing, please send an email to us at privacy@viveapp.com . If you feel that your rights have been violated, you may also make a complaint with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl). For more information on the protection of personal data, please consult the website of the Autoriteit Persoonsgegevens.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@viveapp.com

Vive's investment beliefs

Vive wants you to achieve your goals through your investments. The investments and investment portfolios serve to realize your financial goals. Vive's asset management for private clients ensures the desired investments with an efficient balance between return and risk, at low costs, in a transparent manner and taking into account widely accepted ESG criteria (i.e. in the areas of living environment, social relations and good corporate governance).

Sustainability policy

At Vive, investing goes beyond just financial aspects. Vive includes sustainability criteria in its selection policy. In doing so, Vive strives to select investment funds and managers that excel in the field of sustainability within their category. Sustainability is approached from two sides.

Sustainability risks (outside-in): Vive analyzes sustainability risks related to the environment, society and governance (ESG) that can influence investments. We include these in our investment process to make better choices and strengthen our portfolios.

Sustainability impact (inside-out): Vive does not have a sustainable investment objective but promotes social characteristics through its selection policy. Vive does this on the basis of the frameworks from the Sustainable Finance Disclosure Regulation (SFDR), the European legislation that promotes transparency around sustainability.

Vive selects investment funds based on a selection policy that takes sustainable characteristics into account, with the aim of achieving a balanced risk-return ratio. The selection criteria based on sustainability are based on the following principles:

1. Exclusion policy

Vive only invests in funds that exclude investments based on a structured policy, where possible within the investment category.

2. Best-in-Class Selection

We only select funds that excel in sustainability:

• At least an MSCI ESG rating of BBB, to limit sustainability risks.
• At least an SFDR Article 8 classification (preference for Article 9).
  This requirement is not automatically applied to government bonds.

3. Voting Rights and Engagement

For equity funds, we only invest in funds that actively use their voting rights and encourage companies to adopt more sustainable behavior.

4. Social Characteristics

Vive promotes social values such as:

• No investments in controversial weapons.
• Restriction of investments in the tobacco industry.
• Respect for human rights, labor rights and the fight against corruption according to the UN Global Compact.

With this policy, we ensure that our investments are not only financially strong but also contribute to social and sustainable goals, in line with changing laws and regulations. See the Vive Sustainability Policy and the SFDR documents for more information.

Keeping risk diversification high and costs low is important

Vive believes that investing is best done through broadly diversified portfolios. Vive strives to diversify as much as possible across investment categories, and within them across geographic regions and sectors. Avoidable risk that is not rewarded with a positive expected risk premium (excess return above the risk-free rate) should in principle be avoided.

Vive does not believe that market timing and tactical asset allocation add value to the customer after deduction of costs. Vive does not believe that trying to beat the market structurally adds value for the customer after deduction of costs. With active management, it is very difficult to do better than the market average. Therefore, the policy is to select funds on the basis of 'passive where possible'. Vive believes that active management makes sense for less efficient or inefficient markets if it leads to better risk management. Vive's focus within portfolio management is on compiling portfolios per risk level as well as possible based on realistic and plausible (long-term) economic scenarios. The investment horizon of customers ranges from short to long term. With the help of outsourcing to external asset managers, i.e. the suppliers of non-listed investment funds in which Vive invests for its customers, Vive can focus on the added value for you as a customer. Vive can select the investment funds itself. Vive only invests via non-listed UCITS in the selected investment categories.

Focus on risk management

Risk management is crucial for sustainable asset management. This means that risk is frequently measured and the portfolio is adjusted if necessary. Vive operates on the principle that the value of the downside risk of the optimal portfolios is updated every quarter and that the composition of the optimal portfolios can be adjusted in conjunction with this in order to achieve the best ratio between expected return and downside risk. To ensure that clients' investment plans remain close to the intended risk profile, Vive monitors your investment portfolios daily and applies rebalancing of the portfolios if they deviate too much from that risk profile. The actual composition is then brought in line with the strategic portfolio belonging to the investment plan at the time of rebalancing.

In which investment categories is the money invested?

The investment categories that qualify for the optimal portfolio must have a positive expected risk premium that is scientifically substantiated.

Vive can fill the portfolios with the following investment categories based on the investment beliefs:

• Money market investments in euros;
• Government bonds in euros or hedged to the euro;
• Investment Grade corporate bonds in euros or hedged to the euro;
• Equities worldwide, in mature markets and emerging markets;
• High Yield corporate loans, i.e. corporate loans with a lower credit quality than Investment Grade class.

Vive determines a representative index series for each category, which is used to determine the statistical characteristics in the Economic Scenario Generator model of Vive Technology. These characteristics determine the degree of risk diversification across categories.

How does Vive select the funds for each asset class?

Vive offers asset management through investments in unlisted investment funds ('funds'). Vive does not invest in its own funds but uses third-party funds; this prevents undesirable conflicts of interest.

Vive selects third-party funds based on the following criteria:

Liquid: The portfolio is set up with non-listed open-end investment funds that are tradable daily.

High degree of risk diversification: There is a broad diversification within the fund: there are sufficient names in each investment fund and care is taken to ensure that no individual investment has too large an allocation within the fund, both in terms of weighting in euros and in terms of risk weighting. This is tested by applying a 5% worst case scenario to the two largest positions in the portfolio and checking whether it exceeds the Value at Risk of the relevant investment category. If exceeded, the fund does not meet the risk diversification criterion and is not eligible for selection.

Low costs: The Ongoing Charges Factor (OCF) must be low. This is tested by comparing the OCF of a fund to be selected with the median OCF of comparable funds. The amount of any entry or exit fee must be in line with the market.

Sustainability criteria: Vive only invests in funds that meet our sustainability criteria (see above for more information).

Appropriate mandate of the instrument: The fund's benchmark is reasonably consistent with the representative index series on which the statistical characteristics are based; the tracking error between the two indices is expected to be no more than 1%. This concerns two index series. The index series on which the statistical characteristics are based refers to the index series used to determine the parameters in the Economic Scenario Generator model. The other index series, from the benchmark, concerns the fund's benchmark. The investment universe and risk limitations contribute to sufficient risk diversification. In the case of an index tracker, the replication method ensures a good connection to the benchmark (for example, full replication). The fund's management style is passive and responsible where possible.

Good quality asset manager: The asset manager has a proven track record (i.e. has demonstrated that the asset management in the relevant asset class is carried out reliably), has its own risk management in order and has a stable organization. Vive specifically sets an AFM registration of the fund manager and the fund as a criterion. In addition, the fund must have a reliable custodian.

Suitable and permitted for retail investors within the European Union: The fund has UCITS status and the Key Investor Information Document (KIID) is available for the fund in English and in the language of the country where Vive offers the app. This means that the KIID is available in Dutch for the funds used for customers in the Netherlands.

Funds with securities lending and unnecessary use of derivatives should be avoided: Vive has a strong preference for funds without securities lending and without the use of derivatives (such as total return swaps). Vive considers adding counterparty risk by lending securities undesirable, as this is not a transparent source of risk for the customer. The use of derivatives in a fund entails additional risks that cannot be clearly understood by non-professional investors. If a fund without securities lending or derivative use is not available for a specific investment category, but the improvement in the risk-return ratio for Vive's clients is significant, Vive may still consider adding this fund. In that case, it will be specifically recorded and communicated to clients in what way the Vive principle for securities lending and derivatives is deviated from, and why Vive considers it in the interest of clients that the fund in question can be part of client portfolios. Excluded are funds that use so-called exotics (custom derivatives).

How are investment plans created?

Vive helps clients set investment goals based on preferences that clients specify and within the client's risk tolerance profile based on the risk acceptance indicated by the client. An optimal investment strategy is then derived for each target plan via a software-based procedure. This strategy is a so-called lifecycle strategy: the 'investment risk decreases as the end date approaches'.

Vive determines an optimal investment portfolio within the client's risk profile. Vive ensures portfolio optimization and rebalancing after adjusting the risk-return characteristics of the underlying investment categories. The optimal portfolios and forecasts for the median scenario and the worst-case scenario are based on an economic scenario set that is generated quarterly by the Economic Scenario Generator model.

The investment plans are implemented by investing, for each investment plan, in an optimal portfolio belonging to the risk level that the client has accepted when drawing up the plan (or the last revision of the plan). Vive uses the same consistent portfolio optimization to fill in the investment mix in the different types of investment plans.

The portfolio optimization with the eligible investment categories is done by selecting the portfolio with the highest expected return (median scenario) at each desired Value-at-Risk (VaR) level, based on a realistic 1-year scenario. Vive uses a robust optimization technique to minimize the impact of extreme deviations. The VaR level is determined as the 5% percentile of the probability distribution of portfolio returns.

Part of Vive's services is rebalancing the portfolios in the investment plans created by the customer. Differences between the actual portfolio and the strategic portfolio for the customer's investment plan can arise ​​due to price developments and changes in the strategic portfolio. The aim of rebalancing is to align the actual portfolio with the strategic portfolio that belongs to the specific investment plan at that time.