Terms of Service

PETRUSCHENKO CONSULTING Glärnischstrasse 3 8134 Adliswil UID: CHE-320.408.506 dimitri@petruschenko.consulting

1. Scope

These Terms of Service ("Terms") govern the use of the Wealth Manager Info website ("Website") and the paid subscription service Wealth Manager Monitor ("Newsletter Service"), operated by Petruschenko Consulting ("Provider").

By using the Website or subscribing to the Newsletter Service, you agree to these Terms.

2. Description of Services

2.1 Wealth Manager Info (publicly accessible)

The Website provides a publicly accessible directory of FINMA-licensed financial intermediaries in Switzerland. The data includes company names, registered offices, licence types, and supervisory organisations. Access is free of charge and does not require registration.

The Website is currently in a beta phase. Features, data scope, and presentation may change without prior notice. The beta designation does not limit the applicability of these Terms.

2.2 Wealth Manager Monitor (paid subscription)

The Newsletter Service delivers a curated market intelligence briefing by email every two weeks, covering:

• newly granted FINMA licences (portfolio managers, trustees, managers of collective assets)
• potential new market entrants identified through automated analysis of public registry data
• single family offices identified in the Swiss commercial register

The newsletter is delivered as an HTML email. Access to a web portal is not currently included in the service.

3. Data Sources and Data Quality

3.1 Sources

The information presented on the Website and in the Newsletter Service is derived from publicly accessible sources, in particular:

• FINMA (Swiss Financial Market Supervisory Authority) — list of licensed financial institutions
• Zefix / FCRO (Federal Commercial Registry Office) — commercial register data
• SOGC / SECO (Swiss Official Gazette of Commerce) — commercial register publications

Commercial register data is sourced from the Federal Commercial Registry Office (Zefix) under its open data licence. Source: Zefix, Federal Office of Justice.

3.2 Not an official publication

The information presented on the Website and in the Newsletter Service does not constitute an official publication. The authoritative sources are the official publications of FINMA, the SOGC data bearing the electronic signature or seal of SECO, and the cantonal commercial registry offices.

3.3 Automated analysis

Some of the information contained in the Newsletter Service — in particular the identification of potential market entrants and the assessment of likely licence categories — is produced using automated methods, including AI-assisted classification. These assessments are based on publicly accessible commercial register entries and do not guarantee the actual regulatory classification of any entity. The accuracy of the automated classification cannot be guaranteed.

3.4 No warranty

The Provider endeavours to ensure the accuracy, completeness, and timeliness of the data but assumes no liability for any errors, omissions, or delays. The data is provided on an "as is" basis. In particular, there may be delays relative to the official sources, and the automated analysis may produce inaccurate assessments.

4. Subscription, Pricing, and Cancellation

4.1 Formation of contract

The contract for the Newsletter Service is formed upon payment of the subscription fee via the payment link provided by the Provider. Payments are processed by the payment service provider Stripe.

The payment processing is subject to Stripe's terms of service (stripe.com/legal).

4.2 Price

The subscription is priced at CHF 29.00 per month, plus applicable VAT. VAT is charged in addition to the subscription price where required by law.

4.3 Term and renewal

The subscription renews automatically on a monthly basis. Billing occurs monthly in advance via Stripe.

4.4 Cancellation

The subscription may be cancelled at any time, effective at the end of the current billing period. Cancellation can be made through the Stripe customer portal or by email to the Provider. There is no minimum commitment period.

4.5 Price changes

The Provider reserves the right to change the subscription price. Price changes will be communicated to subscribers by email at least 30 days in advance. In the event of a price increase, subscribers have the right to cancel the subscription effective at the end of the current billing period.

4.6 Refunds

No refunds are provided for the current billing period after cancellation. The Newsletter Service remains active until the end of the paid period.

5. Obligations of Users

5.1 Lawful use

The Website and the Newsletter Service may only be used in accordance with these Terms and applicable law.

5.2 No systematic extraction

Automated, systematic extraction (scraping) of the Website or systematic redistribution of the Newsletter contents is prohibited without the prior written consent of the Provider.

5.3 Organisational use

A subscription is personal to the subscriber. Use of the Newsletter content for internal purposes within the subscriber's organisation is permitted. Resale or paid redistribution to third parties is not permitted. The Provider reserves the right to offer separate licence tiers for organisational use in the future.

6. No Financial Service

6.1 Information service only

The Website and the Newsletter Service are a pure information service. They do not constitute a financial service within the meaning of the Swiss Financial Services Act (FinSA/FIDLEG), investment advice, legal advice, or tax advice.

6.2 No recommendations

The listing of any company on the Website or in the Newsletter does not constitute a recommendation for or against entering into a business relationship with that company. The assessments contained in the Newsletter serve exclusively as general market information.

6.3 Own due diligence

Users are solely responsible for their own business decisions based on the information provided. The Provider recommends conducting independent verification and seeking professional advice before making business decisions.

7. Liability

7.1 Exclusion of liability

To the extent permitted by law, the Provider accepts no liability for damages arising from the use of, or the inability to use, the Website or the Newsletter Service. This applies in particular to:

• inaccuracies, omissions, or delays in the data presented
• misclassifications by the automated analysis
• decisions made on the basis of the information provided
• technical disruptions, outages, or interruptions of the Website or newsletter delivery

7.2 Limitation of liability

Where liability cannot be excluded, the Provider's liability is limited to the total subscription fees paid by the affected user in the twelve months preceding the event giving rise to the claim. No liability is accepted for the free use of the Website.

7.3 Force majeure

The Provider is not liable for service interruptions caused by force majeure, including outages of the data sources (FINMA, Zefix, SOGC), the payment service provider, or the technical infrastructure.

8. Intellectual Property

8.1 Public data

The official data used on the Website and in the Newsletter (FINMA lists, commercial register data, SOGC publications) is publicly accessible and is not subject to any copyright claim by the Provider.

8.2 Value-added content

The aggregation, analysis, design, and editorial curation of the content — including the automated classification methodology, the presentation, and the newsletter format — are the Provider's own work and are protected by copyright.

9. Data Protection

The processing of personal data is governed by the Provider's Privacy Policy, available on the Website. In the context of the subscription, only the personal data necessary for contract performance is collected (email address, payment information via Stripe).

10. Availability

The Provider endeavours to maintain high availability of the Website and the Newsletter Service but does not guarantee uninterrupted operation. Scheduled maintenance will be announced in advance where possible. There is no entitlement to availability at all times.

11. Amendments

The Provider reserves the right to amend these Terms at any time. Amendments will be communicated to subscribers by email and take effect 30 days after notification, unless the subscriber cancels within that period. For the free use of the Website, the Terms published on the Website at the time of use apply.

12. Governing Law and Jurisdiction

These Terms are governed exclusively by Swiss law. The exclusive place of jurisdiction is Zurich, unless mandatory statutory provisions require a different jurisdiction.

13. Severability

If any provision of these Terms is or becomes invalid or unenforceable, this shall not affect the validity of the remaining provisions. The invalid or unenforceable provision shall be replaced by a valid and enforceable provision that most closely reflects the economic purpose of the original provision.

14. Contact

For questions regarding these Terms or the services offered, please contact the Provider at the address stated above.