Terms and Conditions

§ 1 Scope, Definitions

(1) These Terms and Conditions (the "Terms") apply to all contracts between Sabia GmbH ("Sabia", "we") and users (the "User", "you") regarding the software and digital services offered under sabia.de and associated subdomains (the "Platform").

(2) Any deviating terms of the User apply only if Sabia has expressly consented to them in text form.

(3) Consumer means a natural person entering into the contract predominantly for private purposes (§ 13 BGB); Business means a natural or legal person or partnership acting in the exercise of a trade, business or profession (§ 14 BGB). Clauses that apply only to one group are marked accordingly.

§ 2 Provider

The contracting party and provider within the meaning of § 5 DDG is:

Managing Directors: Patrick Alex, Lukas Wagner
Commercial Register: Local Court of Berlin-Charlottenburg, HRB 286212 B
VAT identification number (§ 27a UStG): to be added shortly

Email: founders@sabia.de

§ 3 Description of Services

(1) Sabia provides web-based software that enables Users to consolidate and visualize personal financial data in one place (the "Service").

(2) The Service includes in particular:

• the aggregation and display of account, securities and transaction data which the User causes to be retrieved via the third-party provider WealthAPI (see § 11) after granting the necessary PSD2 consents;
• the visualization of such data in dashboards and overviews;
• the provision of general, non-individualized content on financial topics (e.g. interactive stories, lifestyle-based scenarios).

(3) Beta status. The Service is in a beta phase. Sabia may at any time expand, restrict, modify or discontinue functions. No specific availability or scope of functions is guaranteed during the beta phase; this is indicated within the Service.

(4) Any calculations, model calculations and scenarios shown in the Service constitute non-binding general information based on data the User has entered or released and on general assumptions. They do not constitute a recommendation to buy or sell any specific financial instrument.

§ 4 No Financial Service

(1) Sabia is not a financial investment broker (§ 34f GewO), not an independent fee-based financial investment advisor (§ 34h GewO), and provides no financial services within the meaning of § 1 (1a) KWG — in particular no investment advice, investment brokerage, contract brokerage, proprietary trading or financial portfolio management.

(2) Sabia is not an account information service provider (§ 1 (34) ZAG). The retrieval of account and transaction data is performed exclusively by the licensed third-party provider WealthAPI; Sabia merely provides the interface for visualization.

(3) The content shown in the Service does not constitute investment, tax or legal advice and does not replace individual advice from qualified advisors. Sabia recommends consulting a suitably qualified advisor before making investment decisions, entering into contracts or making tax-relevant arrangements.

§ 5 Contract Formation, Registration, Waitlist

(1) The presentation of the Service is not a binding offer but an invitation to the User to submit an offer.

(2) A contract for the use of the Service is concluded when the User creates a user account, confirms the applicability of these Terms and acknowledgement of the Privacy Policy, and Sabia accepts the registration by activating the account or sending a corresponding confirmation message.

(3) Waitlist. Prior to activation, access may be controlled via a waitlist. By entering the waitlist, Sabia processes the email address provided to send you the platform invitation and — to the extent you have separately consented — product updates, status information and other marketing communications about Sabia. Consent to marketing communications is voluntary and not a condition of entering the waitlist; it may be withdrawn at any time with effect for the future, e.g. via the unsubscribe link in any email or by message to founders@sabia.de. Details are set out in the Privacy Policy. There is no entitlement to an invitation or to a particular order. Entering the waitlist does not itself constitute a user contract under paragraph (2).

(4) Use of the Service requires the User to be at least 18 years old and to have unlimited legal capacity.

§ 6 User Obligations, Suspension

(1) The User shall provide truthful and complete information when registering and using the Service and keep it up to date. Credentials must be kept confidential and protected from third-party access; suspected misuse or compromise must be reported to Sabia without undue delay and the password changed.

(2) The User shall use the Service only in accordance with these Terms, applicable law and the rights of third parties. The following are prohibited in particular:

• uploading unlawful, offensive, discriminatory or otherwise immoral content;
• automated access (scraping, crawling, bots) without express permission;
• circumventing security or access restrictions;
• reverse engineering, decompiling or disassembling the software, except as mandatorily permitted by law (§ 69e UrhG);
• using the Service for the User's own paid advisory, brokerage or asset management activities towards third parties.

(3) The User is responsible for the accuracy of data entered and data integrated via third-party services (in particular WealthAPI).

(4) Suspension. Sabia may temporarily suspend the user account or restrict individual functions if there are concrete indications of a breach of paragraphs (1)–(3), of applicable law or third-party rights, or where necessary to avert specific security risks. Sabia will inform the User in text form of the suspension and its reasons without undue delay, unless this must be omitted on security grounds or to protect the legitimate interests of third parties, and will lift the suspension as soon as the reason for it has ceased to exist. Before terminating under § 7 (4), Sabia will give priority to suspension as the milder measure.

§ 7 Compensation, Term, Termination

(1) Compensation. Use of the Service is currently free of charge unless expressly indicated otherwise within the Service. To the extent the User's provision of data qualifies as consideration within the meaning of § 327 (3) BGB, the relevant statutory provisions apply.

(2) The introduction of paid functions for existing accounts requires the User's express consent (button solution under § 312j (3) BGB). The deemed-consent mechanism under § 14 (3) is excluded in this respect.

(3) Term. The contract is concluded for an indefinite period.

(4) Termination. Either party may terminate the contract at any time without notice in text form (email is sufficient) or via the account-deletion function provided within the Service. The right to extraordinary termination for good cause remains unaffected.

(5) Upon termination taking effect, the user account is deactivated and the associated data is deleted or anonymized in accordance with the Privacy Policy. Statutory retention obligations remain unaffected.

§ 8 Right of Withdrawal for Consumers

This clause applies only to Consumers.

(1) Consumers have a statutory right of withdrawal upon entering into a contract for the use of the Service in accordance with the Withdrawal Instructions (Annex A).

(2) If the Consumer expressly requests that Sabia commence the provision of digital content or services before the end of the withdrawal period, the right of withdrawal expires under § 356 (5) BGB on the conditions stated therein. This request is obtained separately during registration.

§ 9 Availability, Maintenance

(1) Sabia endeavors to maintain the highest possible availability but does not guarantee — particularly during the beta phase — any specific availability or response time. No SLA is agreed.

(2) Sabia may temporarily restrict or interrupt the Service for maintenance and will announce planned maintenance in advance where possible.

(3) Impairments caused by disruptions at integrated third-party providers (in particular WealthAPI, banks, hosting and AI providers) lie outside Sabia's sphere of responsibility and do not constitute a defect of the Service.

§ 10 Liability

(1) Sabia is liable without limitation for intent and gross negligence, for injury to life, body or health, within the scope of any expressly assumed guarantee, and under the Product Liability Act.

(2) For slight negligence — outside the cases under paragraph (1) — Sabia is liable only for breach of a material contractual obligation (cardinal obligation) the fulfilment of which is essential to the proper performance of the contract and on whose observance the User may regularly rely. Liability is then limited to the typical, foreseeable damage.

(3) Any further liability for slight negligence — in particular for indirect damages, consequential damages, lost profits or financial losses — is excluded.

(4) Sabia is in particular not liable for:

• investment decisions taken by the User on the basis of content shown in the Service, and any market losses resulting therefrom;
• the accuracy, completeness or timeliness of data retrieved via WealthAPI or other third-party services;
• damages caused by failure, malfunction or faulty data delivery of third-party providers;
• damages caused or contributed to by the User through a culpable breach of cooperation duties (§ 6).

(5) The limitations above apply equally in favor of Sabia's legal representatives, employees and vicarious agents.

(6) For paid use, statutory warranty for defects applies in addition (§§ 327 et seq. BGB for Consumers, §§ 535 et seq. BGB by analogy for Businesses); for free use, this § 10 applies accordingly and any further warranty for defects is excluded.

§ 11 Integrated Third-Party Providers

(1) To provide the Service, Sabia uses selected third-party providers. A current overview is set out in Annex B and in the Privacy Policy.

(2) The User in particular consents to the integration of the following key services:

• WealthAPI — retrieval of account, securities and transaction data based on PSD2 consent. WealthAPI is licensed as an account information service provider and acts as the User's contracting party (account information service contract);
• Supabase — database, authentication, storage (EU hosting, eu-west region);
• Vercel — hosting and delivery of the web application;
• Generative AI providers (Google Gemini, OpenAI) — processing of text inputs and generation of general, non-individualized content;
• Langfuse — logging/observability of AI calls for quality assurance;
• PostHog — product analytics and usage statistics (pseudonymized).

(3) Some of these services transfer data to third countries (in particular the USA). The required safeguards (Standard Contractual Clauses, EU-US Data Privacy Framework adequacy decision) are described in the Privacy Policy.

(4) Sabia regularly reviews the service providers it uses and may replace or supplement individual service providers, provided the agreed scope of functions is not materially impaired.

§ 12 Intellectual Property, Rights of Use

(1) All rights to the Platform, the Service, its content, software, designs, databases, texts, graphics and trademarks vest exclusively in Sabia or its licensors.

(2) For the term of the contract, Sabia grants the User a non-exclusive, non-transferable, non-sublicensable right to use the Service for its intended purpose.

(3) The User retains all rights to content uploaded by the User or integrated via third-party services ("User Content") and grants Sabia a non-exclusive right, limited geographically and temporally to the purpose of the contract, to process, store and make such User Content accessible to the extent necessary for the provision of the Service (e.g. display in the dashboard, transmission to the data processors named in § 11).

§ 13 Data Protection

Sabia processes personal data in accordance with the GDPR and the German Federal Data Protection Act (BDSG). Details on purposes, legal bases, recipients, third-country transfers, retention periods and data subject rights are set out in the Privacy Policy at https://www.sabia.de/datenschutz.

§ 14 Amendments to These Terms

(1) Sabia may amend these Terms to the extent necessary to adapt them to changes in the law, supreme court case law, technical conditions or the scope of the Service, provided that the contractual balance is not materially shifted to the User's detriment.

(2) Sabia will notify the User in text form at least six weeks before the planned effective date of intended amendments, the effective date, the right to object and the legal consequences of failing to object.

(3) If the User does not object in text form within six weeks of receiving the notice, the amendments shall be deemed approved. If the User objects in due time, the contract continues on the previous terms; Sabia may in that case terminate the contract pursuant to § 7.

(4) Excluded from the deemed-consent mechanism under paragraph (3) are amendments affecting the balance of primary obligations, in particular the introduction of new paid primary services for existing accounts, a material reduction in the scope of functions, or a change in the main obligations of the parties. Such amendments require the express consent of the User.

§ 15 Consumer Arbitration

Pursuant to § 36 VSBG, Sabia is neither willing nor obliged to participate in dispute resolution proceedings before a consumer arbitration board.

§ 16 Final Provisions

(1) Governing law. German law applies, excluding the UN Convention on Contracts for the International Sale of Goods. Vis-à-vis Consumers this choice of law applies only insofar as the protection of mandatory provisions at the Consumer's habitual residence is not thereby withdrawn (Article 6 (2) Rome I Regulation).

(2) Place of jurisdiction. If the User is a merchant, a legal entity under public law or a special fund under public law, the exclusive place of jurisdiction is Berlin. Sabia may also bring proceedings at the User's general place of jurisdiction.

(3) Text form. Unless expressly stated otherwise, declarations within the scope of this contractual relationship require text form (§ 126b BGB).

(4) Severability. Should individual provisions be or become invalid, the validity of the remaining provisions shall not be affected; the invalid provision shall be replaced by the statutory regulation (§ 306 BGB).