Comprehensive Legal Notice, Regulatory Framework & Terms of Service

Full version last updated on September 3, 2026. Legal reference document governing the Pioneer Invest platform operated by KŪB Nabob Fund under the jurisdiction of the Republic of Lithuania and the regulatory framework of the European Union.

Article 1. Identification of the Publisher and Corporate Information

The digital platform accessible at Pioneer Invest's official address, together with all of its subdomains, mobile applications and associated APIs, is published, managed and operated exclusively by the company KŪB Nabob Fund. KŪB Nabob Fund is a commercial entity incorporated under the laws in force in the Republic of Lithuania in the legal form of a Komanditinė ūkinė bendrija (a limited partnership under Lithuanian law).

The legal registration of the corporate entity has been formally validated with the Lithuanian Register of Legal Entities (Registrų centras) under the unique official registration number 306292614. The company is identified on international markets by the Legal Entity Identifier (LEI) code 984500A5BU6A1E5F1311, recorded with the Global Legal Entity Identifier Foundation (GLEIF).

The effective registered and administrative office of KŪB Nabob Fund is officially established at the following legal address: Naujojo Sodo g. 1A-101, LT-92118 Klaipėda, Lithuania. This location constitutes the company's legal domicile for any formal notice, judicial act, summons or official correspondence addressed to corporate management or the authorised legal representative.

The commercial operation of financial services, analysis tools and application modules is carried out under the registered trademark and trading name Pioneer Invest. All marketing operations, financial analysis publications and communications addressed to users are carried out in the name and on behalf of KŪB Nabob Fund in strict compliance with financial transparency standards.

For any general enquiries, technical support, administrative requests or legal notices, users and partner authorities may contact the company via the legal email address contact@pioneer-invest.com or the official assistance phone number +370 674 04125. The legal compliance department can be reached at the dedicated address compliance@pioneer-invest.com.

Article 2. Regulatory Status, Licences and Supervisory Authorities

KŪB Nabob Fund operates on international and European financial markets under the strict supervision of the competent regulatory authorities. The principal administrative authority responsible for supervising and overseeing the financial sector in the Republic of Lithuania is the Bank of Lithuania (Lietuvos bankas), located at Gedimino pr. 6, LT-01103 Vilnius, Lithuania.

The company carries out its activities in accordance with applicable national and EU legislative frameworks. Investment services, the reception and transmission of orders, market data aggregation and the provision of portfolio structures are provided in compliance with the European directive on markets in financial instruments (MiFID II Directive 2014/65/EU).

With regard to features related to crypto-assets, digital tokens and conversion services, KŪB Nabob Fund applies the provisions of the European regulation on markets in crypto-assets (MiCA Regulation (EU) 2023/1114). Activities requiring specific registration as a Crypto-Asset Service Provider (CASP) are operated directly or in partnership with entities holding a verifiable formal authorisation.

It is expressly stated that Pioneer Invest may collaborate with regulated third parties (credit institutions, electronic money institutions - EMIs, investment firms and authorised brokers) for the technical execution of banking flows, the custody of financial instruments and the processing of market transactions. The identifiers and licence numbers of partners are kept up to date in the platform's public register.

Each user is invited to regularly consult the official register of financial market participants maintained by the Bank of Lithuania in order to verify the exact scope of authorisations held by KŪB Nabob Fund and its partner entities. No marketing statement may substitute for the data recorded in the central bank's register.

Article 3. Hosting, Technology Infrastructure and ICT Security

The technical infrastructure of the Pioneer Invest platform is hosted within highly secure server environments provided by Google Cloud Platform (Google Ireland Limited), whose European headquarters are located at Gordon House, Barrow Street, Dublin 4, Ireland.

All data centres hosting the databases and application processing modules are physically located within the European Union, ensuring an optimal level of compliance with strict data sovereignty regulations and the General Data Protection Regulation (GDPR).

KŪB Nabob Fund implements a rigorous framework for managing information and communication technology (ICT) risk in accordance with the European Regulation on Digital Operational Resilience for the Financial Sector (DORA Regulation (EU) 2022/2554). This framework includes regular security audits, penetration testing and continuous vulnerability monitoring.

The protection of data exchanges relies on advanced end-to-end encryption protocols (TLS 1.3 for web traffic and AES-256 for the storage of sensitive data at rest). Users benefit from mandatory strong authentication mechanisms (MFA) for account access and the validation of critical operations.

Despite the implementation of redundancy and business continuity arrangements (DRP/BCP), KŪB Nabob Fund cannot guarantee absolute uninterrupted availability of the technology infrastructure, as maintenance operations, code improvements or third-party network outages may occasionally affect access to the interfaces.

Article 4. Scope of Services Offered and Functional Description

The Pioneer Invest platform provides its registered users with a broad range of digital tools geared towards wealth management, the visualisation of financial assets and access to global markets. The main features are summarised in this legal document.

The wealth tracking module enables the visual aggregation of different asset classes, notably including listed shares, exchange-traded funds (ETFs), cryptocurrencies, fiat cash, real estate assets and stock market indices. This tool provides overall performance indicators, transaction histories and asset allocation analyses.

The investment and order-placement module allows users to run simulations, record buy or sell positions, configure threshold-execution orders (target price) and track the evolution of P&L (profit and loss) in real time. Depending on the user account configuration and active authorisations, these orders are transmitted to real markets via the platform's brokerage partners.

The "Term Baskets" module offers predefined asset allocation structures based on risk-tiered allocation algorithms. These baskets combine several financial or virtual instruments over set time horizons (for example 30, 90 or 365 days), allowing exposure to targeted themes to be optimised.

The scheduled savings module (Dollar-Cost Averaging - DCA) allows users to configure automated recurring investments on a weekly, bi-weekly or monthly basis. The user defines the amount and underlying asset, and the system executes the periodic purchases within the limits of the funds available in the user's balance.

Article 5. Risk Warning and Absence of Personalised Financial Advice

LEGAL WARNING ON INVESTMENT RISKS: Investing in financial instruments, derivative products, asset baskets and cryptocurrencies carries a high risk of capital loss. The value of investments and the income derived from them may fluctuate significantly, both downward and upward. There is a genuine risk of total loss of the amounts committed. Under no circumstances should you invest money that you cannot afford to lose.

All content, analyses, charts, live prices, ETF comparison tools, simulations and information modules published on the Pioneer Invest platform are provided for informational and educational purposes only. They do not, under any circumstances, constitute investment advice, a personalised recommendation, financial advice, an inducement to buy or sell, or banking and financial solicitation within the meaning of European regulations.

No information provided by KŪB Nabob Fund takes into account the particular financial situation, investment objectives, level of experience or risk tolerance of any specific user. The user remains solely and entirely responsible for assessing the suitability and risks of each transaction carried out on or via the platform.

The use of mechanisms involving leverage (up to ×10 on certain position categories) very significantly multiplies the impact of market movements. While leverage can amplify potential gains, it symmetrically accelerates and amplifies losses, and may lead to the automatic and immediate liquidation of positions in the event of an adverse market movement.

Before making any investment decision, every user is strongly advised to conduct their own research (Do Your Own Research - DYOR) and to consult independent financial, legal and tax advisers duly authorised in their primary jurisdiction of residence.

Article 6. Legal Regime of the "Term Baskets" Product

The product marketed under the trade name "Term Baskets" is a structured asset allocation feature in which a user allocates a set amount to a group of underlying instruments for a fixed period determined in advance (notably 30, 90 or 365 calendar days).

It is formally stated and brought to the attention of users that the "Term Baskets" product does not, under any circumstances, constitute a bank deposit, a regulated savings account, or a financial instrument benefiting from a public deposit guarantee or a national investor protection scheme.

Marketing references to indicative returns, projected rates or performance targets describe only statistical projections based on algorithmic allocation models and historical market data. These indications in no way constitute a contractual promise or a return guaranteed by KŪB Nabob Fund.

Funds allocated to a term basket are invested in the underlying assets making up the basket. The final performance returned at maturity depends exclusively on the actual valuation of the underlying financial instruments on official markets on the maturity date of the term.

By subscribing to a term basket, the user accepts that the amounts committed will be locked for the entire duration of the selected term. Unless otherwise expressly agreed by KŪB Nabob Fund, no early withdrawal or premature liquidation may be requested before the contractual maturity date of the basket.

Article 7. Terms Applicable to the Scheduled Savings (DCA) Service

The scheduled savings service (Dollar-Cost Averaging) gives users the option to schedule automatic, recurring asset purchase orders. The user defines the execution frequency (weekly, bi-weekly or monthly), the amount in fiat currency, and the target asset or basket.

To allow scheduled orders to be executed, the user undertakes to maintain a sufficient available balance in their Pioneer Invest account before each scheduled due date. Execution of a DCA order is conditional on the actual presence of unencumbered funds at the exact moment the automatic processing is triggered.

In the event of an insufficient balance at the time of an execution attempt, the system will retry within 24 hours. If three (3) consecutive attempts fail due to a lack of funds, the relevant savings plan will automatically be suspended and placed in inactive status.

The user may, at any time, change the amount, frequency or target, or pause or permanently cancel an ongoing DCA plan, free of charge and without penalty, directly from their user management interface. Any change takes effect for future due dates provided it is recorded at least 24 hours before the scheduled execution date.

KŪB Nabob Fund applies the standard fee schedule to every transaction executed under the DCA module. The fees applied are clearly displayed in the savings plan's configuration summary.

Article 8. Deposit, Withdrawal and User Balance Management Terms

The balance shown in the Pioneer Invest user account represents the book value of the fiat funds and assets recorded in the user's name. This internal balance is used exclusively for management, purchase, sale and withdrawal operations on the platform.

The user balance does not constitute a payment account within the meaning of the European Payment Services Directive (PSD2), nor a standalone electronic money wallet. Fiat funds deposited by users are immediately ring-fenced and deposited in segregated accounts held with credit institutions or electronic money institutions authorised in the EU.

Deposits on the platform may be made by SEPA/SWIFT bank transfer, by bank card via our partner payment service providers (such as Stripe or PayPal), or by transfer of accepted crypto-assets. Each deposit is subject to automated or manual security and KYC/AML compliance checks before being definitively credited to the account.

Withdrawal requests are submitted by the user from their secure interface to a bank account (IBAN) or crypto wallet address opened in the exact name of the account holder of the Pioneer Invest account. No withdrawal to a third-party account is permitted by the platform.

KŪB Nabob Fund reserves the right to suspend, delay or refuse any deposit or withdrawal transaction presenting anomalies, suspicions of money laundering or fraud, or failing to comply with the security thresholds established by the compliance department.

Article 9. Anti-Money Laundering (AML) Prevention and KYC Procedures

As an entity operating in the financial sector in Lithuania, KŪB Nabob Fund is subject to the strict legal obligations arising from the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania, which transposes the EU AML directives (5th and 6th AML Directives).

Every user wishing to open and use an account on the Pioneer Invest platform must undergo the customer identification and verification procedure (Know Your Customer - KYC) before being able to carry out financial operations, deposits or market transactions.

The KYC procedure requires the submission of personal data and valid supporting documents, including in particular: a valid official identity document (passport, national identity card), recent proof of address (less than 3 months old), proof of the source of funds, and a financial and professional profiling questionnaire.

KŪB Nabob Fund applies continuous transaction monitoring tools and carries out automated checks against international sanctions lists (UN, EU, OFAC) and politically exposed persons (PEP) files. Any suspicious transaction will be the subject of a formal report to the Lithuanian Financial Crime Investigation Service (FCIS).

KŪB Nabob Fund reserves the right to request additional documents at any time, to temporarily freeze an account, or to terminate the business relationship without notice if a user refuses to comply with requests for proof of identity or source of funds.

Article 10. Protection of Personal Data (GDPR) and Confidentiality

KŪB Nabob Fund attaches paramount importance to protecting the privacy and personal data of its users. Data processing carried out in connection with the operation of the Pioneer Invest platform strictly complies with the General Data Protection Regulation (Regulation (EU) 2016/679 - GDPR) and Lithuanian law on the legal protection of personal data.

The controller for personal data processing is the company KŪB Nabob Fund, located at Naujojo Sodo g. 1A-101, LT-92118 Klaipėda, Lithuania. The Data Protection Officer (DPO) can be contacted directly at the dedicated email address: dpo@pioneer-invest.com.

Personal data collected (identity, contact details, banking data, transaction history, connection logs, KYC documents) is processed for specific purposes: performance of the service contract, compliance with AML/KYC legal obligations, fraud prevention, improvement of application performance, and customer relationship management.

In accordance with the GDPR, every user has the right of access, rectification, erasure (right to be forgotten), restriction of processing, data portability and objection to processing. These rights may be exercised by sending a signed written request accompanied by proof of identity to the DPO's address.

If, after contacting us, a user considers that their rights have not been respected, they have the right to lodge a formal complaint with the competent supervisory authority in Lithuania: the State Data Protection Inspectorate (VDAI), L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania (website: vdai.lrv.lt).

Article 11. Cookie Management and Web Tracking Technologies

The Pioneer Invest platform uses cookies and similar tracking technologies to ensure the technical operation of its interfaces, optimise the user experience, carry out audience measurement, and offer tailored features.

Cookies strictly necessary for the technical operation of the site do not require the user's prior consent. They include secure authentication session cookies, load balancers and security identifiers essential for navigating the platform.

Statistical analysis, performance measurement and optimisation cookies (such as Google Analytics in its GDPR-compliant configuration with IP address anonymisation) are only placed on the user's device after obtaining their prior explicit consent via the cookie management banner.

The user retains the ability to change or withdraw their consent at any time by accessing the cookie settings panel, permanently accessible from the website's footer, or by configuring their internet browser directly.

Declining to accept certain functional or analytics cookies does not affect access to core investment services, but may restrict access to certain advanced interface personalisation features.

Article 12. Fee Structure, Pricing and Billing Terms

Access to Pioneer Invest's services and the execution of financial operations are subject to the fee schedule in effect on the day the operation is carried out. The user undertakes to review the Fees & Costs Policy before any transaction.

The fee structure applicable on the platform is broken down into several distinct categories: transaction execution fees (fixed commission or percentage of the order value), market spreads, currency conversion fees, overnight fees on leveraged positions, and any applicable administrative fees.

For subscriptions to "Premium" plans, prices are shown in Euros (€), all taxes included. The subscription is billed in advance according to the chosen frequency (monthly or annual) and renews automatically by tacit renewal unless cancelled by the user before the due date.

KŪB Nabob Fund reserves the right to change its fee schedule at any time. Any pricing change will be notified to users by email or via an announcement on the platform at least thirty (30) calendar days before its effective date.

In the event of disagreement with the newly notified pricing terms, the user has the right to close their account and withdraw their assets free of cancellation charges during the thirty-day notice period.

Article 13. Intellectual Property and Copyright Regime

All visual, software, architectural and editorial elements making up the Pioneer Invest platform, including without limitation text, graphic charters, logos, trademarks, icons, illustrations, photographs, algorithms, source code, databases and application structures, are the exclusive and full property of KŪB Nabob Fund or its licensors.

Access to the platform and the granting of a user account confer no intellectual property rights over Pioneer Invest's software or graphic elements. The user is granted a personal, non-exclusive, non-transferable and limited right to use the application interfaces strictly for the purpose of using the services for their own needs.

It is strictly prohibited for any user or third party to copy, reproduce, display, modify, adapt, translate, disassemble, decompile, reverse-engineer, extract or attempt to extract the source code or structured data of the platform without the prior written and formal consent of KŪB Nabob Fund.

Any automated data extraction (web scraping, data mining, unauthorised algorithmic queries via API) for commercial purposes or competing aggregation is formally prohibited and constitutes an infringement sanctioned by international intellectual property law.

The "Pioneer Invest" and "KŪB Nabob Fund" trademarks, together with their logo variations, are registered trademarks. Any unauthorised use of these distinctive signs exposes the infringer to civil and criminal proceedings before the competent courts.

Article 14. Order Execution Policy and Best Execution

When KŪB Nabob Fund or its authorised financial partners receive and transmit or execute orders on behalf of users in financial instruments, they take all sufficient steps to obtain the best possible result (Best Execution) in accordance with the requirements of the MiFID II Directive.

The execution policy takes into account a range of critical evaluation factors, including: the price of the instrument on reference markets, the total cost associated with execution, the speed of execution, the likelihood of execution and settlement, the size of the order, and its market impact.

Buy or sell orders submitted by users are routed to execution venues selected for their reliability and liquidity, including regulated markets (RMs), multilateral trading facilities (MTFs), or authorised market makers (Systematic Internalisers).

When a user gives a specific instruction regarding an order (for example, setting a strict limit price), KŪB Nabob Fund executes the order following that specific instruction, which may prevent the best execution from being obtained according to the usual general criteria.

In the event of a major market disruption, extreme volatility, or a technical incident affecting transmission networks, KŪB Nabob Fund reserves the right to temporarily suspend the acceptance of orders in order to protect users' interests against execution under abnormal price conditions.

Article 15. Conflicts of Interest Management Policy

In accordance with European regulatory standards imposed on financial market participants, KŪB Nabob Fund has developed, implemented and maintains an effective policy for managing and preventing conflicts of interest.

A conflict of interest means any situation in which the interests of KŪB Nabob Fund, its directors, employees, service providers or business partners come into direct or indirect competition with the interests of platform users.

The company has put in place strict information barriers (Chinese Walls), a functional separation of operational departments, and rigorous monitoring of personal transactions carried out by its staff to prevent any misuse of privileged information.

KŪB Nabob Fund refrains from receiving or paying remuneration, commissions or non-monetary benefits (inducements) likely to impair its duty to act honestly, fairly and professionally in the best interests of its clients.

If the organisational arrangements adopted prove insufficient to ensure, with reasonable certainty, that the risk of harm to a user's interests will be avoided, KŪB Nabob Fund will clearly inform the user before acting on their behalf.

Article 16. Complaints Handling Procedure and Financial Mediation

KŪB Nabob Fund provides its users with a transparent and free procedure designed to ensure the fast, effective and fair handling of any complaint made against the platform or its services.

Any complaint must first be addressed to the dedicated dispute-handling department by email at claims@pioneer-invest.com or by post to the registered office: KŪB Nabob Fund, Naujojo Sodo g. 1A-101, LT-92118 Klaipėda, Lithuania.

The compliance department acknowledges receipt of the complaint within a maximum of three (3) business days from receipt. In accordance with the guidelines issued by the Bank of Lithuania, a substantiated response will be provided to the user within a period not exceeding fifteen (15) business days.

If, due to exceptional circumstances beyond its control, a response cannot be provided within the 15-day period, KŪB Nabob Fund will send a holding response explaining the reasons for the delay and setting the final response date, which may not exceed thirty-five (35) business days.

In the event of persistent disagreement or the absence of a satisfactory response within the time limits set, a user who is a private individual has the right to refer the matter, free of charge, to the out-of-court consumer dispute resolution body at the Bank of Lithuania (Financial Market Participant Supervision), Totorių g. 4, LT-01121 Vilnius, Lithuania (website: www.lb.lt/en/disputes-between-consumers-and-financial-market-participants).

Article 17. Investor Compensation Scheme and Asset Protection

KŪB Nabob Fund applies strict procedures to ensure the segregation and absolute protection of assets and financial instruments belonging to its users, rigorously separating client accounts from the company's own accounts.

Fiat currency funds deposited by users are held in separate ring-fenced accounts opened with sound credit institutions or electronic money institutions established within the European Economic Area (EEA).

Depending on the exact regulatory classification of the services provided and the executing entities, eligible financial instruments held on behalf of clients may benefit from the investor compensation scheme implemented in accordance with the legislation of the Republic of Lithuania on the insurance of deposits and liabilities to investors (Directive 97/9/EC).

The investor compensation scheme covers situations of proven insolvency or irreversible failure of the investment firm to return funds or financial instruments held on behalf of its clients, up to a regulatory cap set by law (typically up to €20,000 per investor, subject to legal eligibility conditions).

It is reiterated that the investor compensation scheme does not, under any circumstances, cover financial losses resulting from a decline in the market value of assets, price fluctuations, the depreciation of crypto-assets, or a poor investment decision made by the user.

Article 18. Terms of Subscription to Premium Plans and Right of Withdrawal

The Pioneer Invest platform offers paid subscription plans ("Pioneer Premium") providing access to advanced features, enhanced technical analysis tools, reduced execution commissions, and priority support.

When initially subscribing to a paid plan, the user expressly accepts the immediate charge of the stated price. If the user qualifies as a consumer within the meaning of European law (a natural person acting for purposes outside their trade or business), they are in principle entitled to a statutory right of withdrawal of fourteen (14) calendar days.

However, by accepting immediate execution of the Premium digital services before the expiry of the 14-day withdrawal period, the consumer expressly acknowledges and accepts that they waive their right of withdrawal once the digital application service has been fully performed or begun with their agreement.

The Premium subscription may be cancelled at any time by the user directly from their account settings. Cancellation will take effect at the end of the current billing period (monthly or annual). No pro-rata refund is made for the remaining period until expiry.

KŪB Nabob Fund reserves the right to suspend access to Premium benefits in the event of a failed subscription payment, following a reminder notice that remains unanswered within forty-eight (48) hours.

Article 19. Geographic Restrictions, International Sanctions and Prohibited Countries

Access to Pioneer Invest's services is not intended to be provided to individuals or entities residing or established in jurisdictions where the distribution or use of such services would be contrary to local laws or regulations.

Due to international financial sanctions and terrorist financing prevention regulations, KŪB Nabob Fund does not accept any user from territories listed on the EU, FATF or OFAC blacklists (notably North Korea, Iran, Syria, Cuba, Russia and territories subject to specific sanctions).

The platform is not intended for persons classified as "US Persons" within the meaning of US tax regulations (Regulation S of the Securities Act of 1933 and the Foreign Account Tax Compliance Act - FATCA). Any US citizen or US tax resident is prohibited from opening an account on Pioneer Invest.

KŪB Nabob Fund uses IP geolocation technologies and automated identity checks to block access for users attempting to connect from territories subject to geographic restrictions or applicable sanctions regimes.

It is the responsibility of each user to personally ensure that opening an account and using Pioneer Invest's services are fully permitted under the laws of their country of tax residence and nationality.

Article 20. Changes to Legal Terms, Governing Law and Jurisdiction

KŪB Nabob Fund reserves the right to make changes, adjustments or updates to this entire legal document, the legal notice and the platform's general terms, in order to reflect legislative, regulatory, technical or commercial developments.

Any significant change will be the subject of prior notification sent to users by email or via a clearly visible warning banner at the next login to the platform, at least fifteen (15) calendar days before the effective date of the new provisions.

A user who continues to access the platform or use the services after the changes have taken effect is deemed to have accepted the new legal notice and revised terms without reservation. If the user refuses the new provisions, they must stop using the services and close their account.

This legal notice, its interpretation, its validity, and all contractual relationships arising from the use of the Pioneer Invest platform, are exclusively governed by and subject to the substantive law of the Republic of Lithuania.

Subject to the mandatory legal provisions applicable to consumers residing in other EU Member States (who retain the benefit of the mandatory protections granted by the laws of their country of residence), any dispute relating to the existence, validity, interpretation or performance of this contract shall be submitted to the exclusive jurisdiction of the competent courts of the city of Vilnius or Klaipėda (Lithuania).