Terms of Service

Last updated October 18, 2026

These Terms of Service (the "Terms") are a legally binding agreement between Individual Entrepreneur Steffan Kharmaaiarvi, doing business as Borderfolio ("Borderfolio", "we", "us", "our"), registered in Georgia at 29 Tornike Eristavi Street, Building 5, Entrance 1, Floor 1, Apartment 3, Tbilisi, Tbilisi 0192, Georgia, and the advisory firm or sole practitioner that opens an organisation in Borderfolio for Advisors (the "Firm", "you"). They govern the adviser workspace at b2b.borderfolio.app and its application programming interface (together the "Service"). By creating an organisation, accepting an invitation to one, or using the Service, you agree to these Terms on behalf of the Firm and confirm that you are authorised to do so.

The Service is a business-to-business product. The Borderfolio Terms of Use for the investor product do not apply to it, except where these Terms say so.

1. Definitions

• Organisation: the Firm's workspace in the Service, with its members, clients, settings and reports.
• Member or Adviser: a natural person the Firm has added to its Organisation, as an owner or an adviser. Owners manage settings, branding, members and permanent deletions.
• Client: a person for whom the Firm acts and whose investment information the Firm enters into the Service. Clients are not users of the Service and have no account in it.
• Client Data: brokerage statements, extracted positions and transactions, cross-border profile details, notes and any other information about a Client that the Firm or its Members put into the Service, and the analytics and reports derived from it.
• Pilot: the Founding Adviser programme under which the Service is currently offered.

2. The Service

The Service lets Members add Clients, create investment accounts for them, import brokerage statements, review and confirm the extracted positions and transactions, view consolidated holdings, allocation, income, fees and performance figures, read cross-border findings, and generate portfolio-review reports in PDF. Figures are produced by Borderfolio's portfolio engines from the data the Firm supplies and from third-party market, exchange-rate and fund data. The Service does not hold assets, execute transactions, connect to custodians on the Firm's behalf except where the Firm itself provides read-only broker credentials, or give advice.

Features, limits and the list of recognised broker formats are described in the Service and may change. We will not remove a capability on which generated reports depend without keeping those reports downloadable.

3. Accounts, members and security

Each Member signs in with an individual e-mail address and password, and may enrol a second factor (time-based one-time codes with recovery codes). An owner may require a second factor for every Member; a Member who has not enrolled then cannot use the Organisation until they do. Members are responsible for keeping their credentials and recovery codes confidential. The Firm is responsible for the acts and omissions of its Members, for removing Members who leave the Firm, and for ensuring that invitations are only accepted by the people they were meant for.

4. Authority over Client Data and acceptable use

The Firm represents that, for every Client it adds, it is authorised by the Client or otherwise lawfully entitled to obtain, hold and process the Client's investment information for the purpose of advising that Client, and to upload it to a software service acting on the Firm's instructions. The Firm will not add people it is not authorised to act for, will not upload documents it does not have the right to process, and will remove a Client's data when its authority ends or the Client asks.

You will not: use the Service to provide a service to the public under your own brand as a hosted platform; attempt to access another Organisation's data; probe, scan or circumvent security or rate limits; upload malicious files; reverse-engineer the Service; resell access; or use the Service for any unlawful purpose. Sections 7 (Prohibited activities) and 11 (Services management) of the Borderfolio Terms of Use apply to the Service by reference.

5. Pilot, plans and fees

The Service is offered under the Founding Adviser Pilot. Plan configurations (seat, active-client and monthly import limits; branded reports) exist in the Service and are enforced server-side, but no public price list is published and no fee is charged unless agreed in writing with the Firm. Pilot pricing is agreed on request and, once agreed, is held for the first six months after the Service becomes generally available. If and when fees apply, invoicing, renewal, cancellation and refunds will follow the Billing & Refund Policy; payments are processed by Freemius as merchant of record.

A new Organisation starts on a trial. We may convert a trial to a paid or free arrangement, extend it, or end it with notice; reports already generated remain downloadable for at least 30 days after access ends.

6. Client Data, privacy and data processing

As between the parties, the Firm owns Client Data and grants Borderfolio a licence to host, process, analyse, store and display it solely to provide the Service to the Firm, to maintain security and to comply with law. Borderfolio processes Client personal data as the Firm's processor under the Data Processing Addendum, and Members' own account data as controller under the Privacy Policy. Original statement files are retained for seven days after import and then purged; extracted data, confirmed records and report snapshots persist until deleted by the Firm or on termination.

We use aggregated, de-identified usage information to operate and improve the Service. We do not use Client Data to train machine-learning models and do not sell it.

7. Generated reports and adviser commentary

Reports are rendered from a snapshot stored at generation time and are labelled with their sources, assumptions and limitations. Commentary a Member writes is stored in the snapshot and printed in a section labelled as adviser-authored. The Firm is solely responsible for its commentary, for reviewing every figure before giving a report to a Client, and for compliance with the professional, regulatory and disclosure obligations that apply to it. Borderfolio is not a party to the Firm's relationship with its Clients.

8. No financial, investment or tax advice

The Service provides decision-support software for professional advisers. Borderfolio is not a broker, dealer, custodian, investment adviser, financial planner, tax adviser or regulated financial institution in any jurisdiction, and nothing the Service produces is a personal recommendation or advice to the Firm or to any Client. Tax and withholding figures are estimates: only US-source dividend withholding is modelled, Clients are treated as non-resident aliens for US purposes unless the Firm's screen says otherwise, estate-tax treaties are not applied, and US-person taxation is not modelled. Market data may be inaccurate or delayed. The Investment & Tax Disclaimer forms part of these Terms.

9. Intellectual property

The Service, its software, design, engines, reference tables and documentation are owned by Borderfolio and its licensors. Subject to these Terms, we grant the Firm a non-exclusive, non-transferable right to use the Service for its internal business during the term. The Firm may distribute reports it generates to the Clients they concern. Feedback you give us may be used without obligation.

10. Term, suspension and termination

These Terms apply from the moment the Organisation is created until it is deleted. Either party may terminate for convenience with 30 days' notice; we may suspend or terminate immediately for breach of section 4, non-payment of agreed fees, a security risk, or where required by law. On termination the Firm may export its reports and extracted data for 30 days by asking us at [email protected]; afterwards we delete the Organisation's data from active systems and purge it from backups in the ordinary cycle, except what we must keep by law. Sections 6 to 13 survive termination.

11. Modifications and interruptions

We may change, suspend or discontinue parts of the Service, and we may experience downtime for maintenance or causes beyond our control. We will give reasonable notice of material changes to these Terms by e-mail to owners or in the Service; continued use after the effective date is acceptance.

12. Disclaimer of warranties

THE SERVICE IS PROVIDED ON AN AS-IS AND AS-AVAILABLE BASIS. TO THE FULLEST EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT, AND MAKE NO WARRANTY ABOUT THE ACCURACY OR COMPLETENESS OF ANY DATA, CALCULATION, FINDING OR REPORT.

13. Limitation of liability

IN NO EVENT WILL WE OR OUR DIRECTORS, EMPLOYEES OR AGENTS BE LIABLE TO THE FIRM, ITS MEMBERS, ITS CLIENTS OR ANY THIRD PARTY FOR ANY INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, SPECIAL OR PUNITIVE DAMAGES, INCLUDING LOST PROFIT, LOST REVENUE OR LOSS OF DATA, ARISING FROM THE USE OF THE SERVICE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. NOTWITHSTANDING ANYTHING TO THE CONTRARY, OUR AGGREGATE LIABILITY FOR ANY CAUSE WHATSOEVER AND REGARDLESS OF THE FORM OF THE ACTION WILL AT ALL TIMES BE LIMITED TO THE AMOUNT PAID, IF ANY, BY THE FIRM TO US DURING THE SIX (6) MONTH PERIOD PRIOR TO THE CAUSE OF ACTION ARISING. WHERE APPLICABLE LAW DOES NOT ALLOW A LIMITATION, IT APPLIES TO THE EXTENT PERMITTED.

14. Indemnification

The Firm will defend and indemnify Borderfolio against claims, losses and expenses (including reasonable legal fees) arising from Client Data the Firm supplied, from the Firm's or its Members' breach of these Terms or of section 4 in particular, from advice or reports the Firm gives its Clients, or from the Firm's violation of law or of a third party's rights.

15. Governing law and disputes

These Terms are governed by the laws of Georgia. Individual Entrepreneur Steffan Kharmaaiarvi and the Firm irrevocably consent that the courts of Georgia have exclusive jurisdiction over any dispute arising in connection with these Terms. Individual Entrepreneur Steffan Kharmaaiarvi also retains the right to bring proceedings in the courts of the state of the Firm's principal place of business.

16. Miscellaneous

These Terms, the Privacy Policy with its Data Processing Addendum, the Cookie Notice, the Investment & Tax Disclaimer and the Billing & Refund Policy are the entire agreement. If a provision is unenforceable it is severed and the rest stands. Our failure to enforce a right is not a waiver. You may not assign these Terms without our consent; we may assign them in a business transfer. Notices to us go to [email protected]; notices to the Firm go to its owners' registered e-mail addresses.

17. Contact

Individual Entrepreneur Steffan Kharmaaiarvi, doing business as Borderfolio
29 Tornike Eristavi Street, Building 5, Entrance 1, Floor 1, Apartment 3, Tbilisi, Tbilisi 0192, Georgia
Phone +995591003454 · [email protected]