1. Introduction

Welcome to Luminaris Securities & Capital Ltd (“Luminaris”, “we”, “our”, or “us”).
By accessing, browsing, or using any part of our website, platforms, trading interfaces, client portals, or educational communities, you acknowledge that you have read, understood, and agreed to be bound by this User Agreement (“Agreement”).

If you do not agree with any part of this Agreement, please discontinue the use of our services immediately.

2. Legal Entity & Regulatory Framework

Luminaris Securities & Capital Ltd is a United States–registered financial services company operating under U.S. corporate law, with strategic cooperation partners in South Africa to facilitate lawful access to investment products, ETF mechanisms, and market-maker stock services.

In South Africa, execution, settlement, custody, and regulated trading services are provided exclusively through authorised Financial Services Providers (“FSPs”) licensed by the Financial Sector Conduct Authority (FSCA).

Luminaris does not independently hold client funds, execute trades, or provide custodial services within South Africa.

3. Eligibility to Use Our ServicesYou may use our services only if:

• You are at least 18 years old.
• You have full legal capacity to enter into binding contracts.
• You comply with the laws of your jurisdiction.
• You successfully pass any required verification or KYC procedures by our authorised partners.
• We reserve the right to accept or reject client access at our sole discretion.

4. Nature of Services

Luminaris provides:

• Investment research commentary and market insights ETF off-market link information
• Market-maker stock educational materials
• General investment education
• Access pathways to regulated trading partners
• Portfolio strategy frameworks and analysis

We do not:

• Accept deposits
• Execute trades
• Provide personalised financial, legal, or tax advice
• Guarantee investment returns
• Offer any unauthorised investment products

All trading activities are executed solely by regulated partners licensed under FSCA or equivalent international authorities.

5. No Financial Advice Disclaimer

All content on the website, communication groups, newsletters, and research outputs is provided on an educational and informational basis only.

Nothing provided by Luminaris should be interpreted as:

• Personalised investment advice
• A recommendation to buy or sell any asse
• Financial planning adviceA promise of profit or guaranteed return

You are solely responsible for your investment decisions.

6. Risk Disclosure

Investment in financial markets involves significant risks, including but not limited to:

• Market volatility
• Liquidity fluctuation
• Currency risk (including USD/ZAR) Economic and geopolitical shifts Potential complete loss of capital

Past performance does not guarantee future results.

You acknowledge that you understand and accept these risks before using our services or trading through our partners.

7. User Responsibilities

You agree to:

• Ensure all information you provide is accurate and up-to-date
• Maintain the confidentiality of your login credentials
• Use the website and services lawfully and ethically
• Avoid engaging in fraud, abuse, or harmful behaviour
• Comply with all applicable regulations, including those governing cross-border investments

Any misuse or suspicious activity may result in account suspension or termination.

8. Intellectual Property

All content on this website—including text, images, reports, frameworks, logos, and proprietary systems—belongs to Luminaris Securities & Capital Ltd.

You may not reproduce, distribute, modify, or create derivative works without written permission.

9. Third-Party Partners & Platforms

Our services may include referrals or links to platforms, brokers, custodians, or educational partners.
We are not responsible for:

• Their actions or omissions
• Their service performance
• Their compliance obligations

Your engagement with third parties is governed exclusively by their own terms, policies, and regulatory requirements.

10. Data Privacy & Security

We collect and process limited personal information for service provision and compliance purposes.

We commit to:

• Implementing reasonable security measures Protecting user data
• Not selling customer information to third parties

Complying with South African POPIA and applicable international privacy laws Detailed practices can be found in our “Privacy Policy”.

11. Prohibited Activities

Users must not:

• Misuse or reverse engineer our systems
• Attempt unauthorized access
• Spread harmful content or malware
• Provide false identity or documents
• Engage in market manipulation, fraud, or regulatory violations

Breaches may lead to immediate termination and reporting to relevant authorities.

12. Limitation of Liability

To the fullest extent permitted by law, Luminaris shall not be liable for:

• Losses arising from market movements
• Trading losses with partner brokers
• Service interruptions
• Incorrect or outdated market information
• Indirect, incidental, or consequential damages

Your use of our information and services is at your own risk.

13. Amendments to the Agreement

We reserve the right to update, modify, or revise this Agreement at any time. Changes will be posted on our website, and continued use of our services constitutes acceptance of the updated version.

14. Governing Law

This Agreement is governed by:

United States corporate law (for Luminaris operations)
South African financial regulatory requirements (for partner-executed services)

Any disputes shall be resolved in the competent courts of these jurisdictions as applicable.