Terms and conditions

Version 3.0, in force from 16 September 2026.

Consumer pre-contractual information (Articles L. 111-1 and L. 221-5 of the French Consumer Code).

These terms and conditions (the "Terms") govern the wealth management advice, financial investment advice, insurance brokerage and banking intermediation services offered by ASTERALE, a SASU (simplified single-shareholder company) with share capital of €1,000, registered with the Créteil Trade and Companies Register under no. 921 855 508, whose registered office is at 4 allée Django Reinhardt, 94110 Arcueil, France, represented by Mr Sébastien Bailly ("ASTERALE" or "the Firm").

Article 1. Purpose

The Terms define the conditions under which ASTERALE offers its clients (the "Client") advisory and intermediation services in wealth, tax, financial, property, succession and protection matters.

The services offered include in particular:

• wealth review and personalised study;
• financial investment advice (CIF) within the meaning of Article L. 541-1 of the French Monetary and Financial Code;
• insurance brokerage (IAS) within the meaning of Article L. 511-1 of the French Insurance Code;
• banking and payment services intermediation (IOBSP) within the meaning of Article L. 519-1 of the French Monetary and Financial Code;
• transactions in real property and businesses (carte T), under the Hoguet Act;
• advice on tax matters and wealth transfer;
• selection of investment solutions on an open-architecture basis and assistance with subscription.

Article 2. Regulatory status and authorisations

ASTERALE carries on its activities in compliance with the applicable regulations, under the following statuses:

• financial investment adviser (CIF), registered with ORIAS under no. 23 007 423 (www.orias.fr), member of ANACOFI-CIF, 92 rue d'Amsterdam, 75009 Paris, a professional association approved by the Autorité des marchés financiers;
• insurance broker (COA), insurance intermediary's agent (MIA) and agent of a banking and payment services intermediary (MIOBSP), registered with ORIAS under the same no. 23 007 423;
• holder of the professional licence « Transactions sur immeubles et fonds de commerce » (carte T) no. CPI 8501 2023 000 000 004, issued by the Paris Chamber of Commerce and Industry, with no client funds held;
• a business subject to the supervision of the Autorité de contrôle prudentiel et de résolution (ACPR), 4 place de Budapest, CS 92459, 75436 Paris Cedex 09;
• professional indemnity insurance policy no. 7400023129, taken out with Zurich Insurance plc, 112 avenue de Wagram, 75017 Paris.

ASTERALE never holds its clients' funds and has no financial guarantee. It does not manage portfolios on behalf of third parties and carries out no crowdfunding activity.

Article 3. Acceptance of the Terms

Any service undertaken by ASTERALE implies the Client's full acceptance of the Terms. The applicable Terms are those in force on the date the engagement letter is signed or, failing that, on the date of the first paid service.

ASTERALE may amend the Terms at any time. Amendments are binding on the Client from the date they are communicated. Engagement letters in progress remain governed by the Terms in force on the date they were signed.

Article 4. Engagement letter

Before any paid service, ASTERALE gives the Client an engagement letter setting out:

• the identity and contact details of the Firm and the Client;
• the purpose and scope of the engagement;
• the work to be carried out and any limitations;
• the Firm's remuneration (fees, commissions, charges);
• the duration of the engagement;
• the termination conditions;
• information on any conflicts of interest and how they are managed;
• the complaint and mediation procedures.

The engagement letter must be signed by both parties to engage ASTERALE's liability.

Article 5. First meeting

The first meeting, which lasts about one hour, is not invoiced and does not commit the Client. Its purpose is to gather preliminary information on the Client's wealth, professional and family situation, to identify needs and to present ASTERALE's scope and terms of work. Where appropriate, the Client is referred to a colleague or a more suitable specialist.

This first meeting constitutes neither personalised wealth advice nor an investment recommendation within the regulatory meaning. No document constituting advice is provided at this stage.

Article 6. Fees and remuneration

6.1 Advisory fees

Wealth advisory fees are freely set case by case, according to the complexity of the file, the estimated time, the skills involved and the scope of the engagement. They are stated in the engagement letter and expressly accepted by the Client before work begins.

As an indication, wealth advisory fees range from €3,000 to €50,000 excluding VAT depending on the scope and complexity of the engagement, from a complete wealth review to overall advice with annual follow-up and coordination of advisers. Extended advisory engagements (sale of a business, international structuring, property acquisition) are quoted separately.

Fees are payable as agreed: single fixed fee, instalments or time spent.

6.2 Commissions

As an insurance and banking intermediary, ASTERALE may receive commissions (rétrocessions) from the insurance companies, asset management companies, banks or developers whose solutions are subscribed by the Client.

The nature of the advice under MiFID II is set out in the legal notice.

The nature and amount of the commissions are disclosed in the client information document, in the engagement letter and before any subscription. They entail no additional cost for the Client.

6.3 Ancillary costs

Travel costs outside the Paris region (Île-de-France), costs of coordination with third-party advisers (lawyers, notaries, accountants) and any subscription or file costs of the products selected are separate from advisory fees. They are stated in advance in the engagement letter or invoiced against supporting documents.

6.4 Payment

Fees are payable by bank transfer (bank details given in the engagement letter), cheque or direct debit, as agreed. In the event of non-payment when due, late-payment interest at the statutory interest rate applies automatically from the due date. For a professional Client, the fixed indemnity of €40 for recovery costs provided for in Article D. 441-5 of the French Commercial Code is added.

Article 7. ASTERALE's obligations

ASTERALE undertakes to:

• act with competence, diligence and loyalty, in the Client's best interests;
• analyse the Client's situation and objectives in detail before any recommendation;
• provide clear, accurate and non-misleading information on the products and strategies recommended, including their risks, costs, taxation and key features;
• observe professional secrecy;
• detect, prevent and manage any conflicts of interest, in accordance with the Firm's conflicts-of-interest policy;
• keep its professional skills up to date through continuing training in accordance with regulation.

ASTERALE's commitments are obligations of means (obligations de moyens). ASTERALE gives no undertaking as to results: investment performance and changes in taxation cannot be guaranteed.

Article 8. Client's obligations

The Client undertakes to:

• provide ASTERALE with all accurate, complete and up-to-date information needed for the proper performance of the engagement (wealth, tax, family and professional situation, objectives, constraints);
• report without delay any significant change likely to affect current recommendations;
• keep all documents provided by ASTERALE (reports, recommendations, contracts);
• pay fees when due;
• comply with anti-money laundering regulations and provide the supporting documents requested (know-your-customer information, identity document, proof of address, origin of funds).

Any inaccurate, incomplete or late information may affect the quality of the advice and releases ASTERALE from liability to the corresponding extent.

Article 9. Conflicts of interest

In accordance with Articles 325-28 et seq. of the AMF General Regulation, ASTERALE has established a conflicts-of-interest policy, available on request. Its main measures are:

• prior disclosure to the Client of remuneration received from third parties;
• systematic assessment of the suitability of the products proposed for the Client's needs, which takes precedence over the Firm's commercial interests;
• refusal to provide the service where a conflict cannot be resolved.

Article 10. Anti-money laundering and counter-terrorist financing (AML/CFT)

Under Articles L. 561-1 et seq. of the French Monetary and Financial Code, ASTERALE must apply due diligence measures to its clients, including:

• identification and verification of the identity of the Client and, where applicable, of the beneficial owner;
• knowledge of the nature and purpose of the business relationship;
• ongoing vigilance throughout the relationship;
• reporting of suspicions to TRACFIN where necessary, in accordance with the law.

The Client authorises ASTERALE to carry out these checks and agrees to provide the supporting documents requested.

Article 11. Duration and termination

The duration of the engagement is stated in the engagement letter. Unless otherwise agreed, the engagement is concluded for a fixed term corresponding to the service described or, for follow-up engagements, for one year renewable by tacit agreement.

Either party may terminate the engagement at any time:

• automatically and without notice, in the event of a serious breach by the other party (non-payment, false statement, breach of professional ethics);
• with reasonable notice, generally 30 days, where termination is for no particular reason.

Termination does not affect fees due for services already performed, which remain payable to the Firm.

Article 12. Right of withdrawal

Where the Terms are concluded at a distance (electronic signature, exchange of emails) or off-premises, a consumer Client, within the meaning of the preliminary article of the French Consumer Code, has a right of withdrawal of 14 calendar days from acceptance of the engagement letter, under Article L. 221-18 of the French Consumer Code.

To exercise this right, the Client notifies ASTERALE of the decision by email to sebastien.bailly@asterale.fr or by registered letter. A model withdrawal form is available on request.

If the Client expressly requests performance of the service during the withdrawal period, the Client agrees to pay an amount proportionate to the services provided up to the date of withdrawal.

The right of withdrawal does not apply to contracts for financial services whose price depends on market fluctuations (Article L. 221-28 of the French Consumer Code).

Article 13. Liability and limitations

ASTERALE's liability is engaged within the limits of the obligations of means defined in Article 7 and in accordance with ordinary law.

ASTERALE cannot be held liable for:

• changes in tax, social or regulatory legislation after its recommendations;
• the performance of financial markets and the valuation of assets;
• decisions taken by the Client contrary to the recommendations given;
• inaccuracies arising from information provided by the Client;
• the failure of the institutions or counterparties with which the Client has subscribed products.

ASTERALE's financial liability is capped, for each claim, at the amount of its professional indemnity cover in force.

Article 14. Personal data

ASTERALE processes personal data in compliance with Regulation (EU) 2016/679 (GDPR) and French Act no. 78-17 of 6 January 1978 as amended.

• Controller: ASTERALE, Mr Sébastien Bailly, sebastien.bailly@asterale.fr.
• Main purposes: performance of contractual services, compliance with legal and regulatory obligations (AML/CFT, tax, archiving), client relationship management, marketing with consent.
• Legal bases: performance of a contract (Article 6.1.b GDPR), legal obligation (Article 6.1.c), the controller's legitimate interest (Article 6.1.f), consent for marketing (Article 6.1.a).
• Retention period: duration of the contractual relationship, extended by the statutory limitation periods (generally 5 to 10 years for accounting and AML/CFT obligations).
• Recipients: authorised persons at ASTERALE, IT providers under contract, competent authorities (ACPR, AMF, TRACFIN, tax administration). The data of appointments booked through the Calendly calendar are subject to a safeguarded transfer to the United States, described in the privacy policy.
• Client's rights: access, rectification, erasure, restriction, objection, portability, withdrawal of consent and instructions on the fate of the data after death, to be exercised by email to sebastien.bailly@asterale.fr. A complaint may be lodged with the CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 (www.cnil.fr).

Article 15. Intellectual property

All documents, studies, reports, simulations, reviews and recommendations provided to the Client remain ASTERALE's exclusive intellectual property. The Client obtains a strictly personal right of use and may not reproduce, distribute or use them for other purposes without prior written consent.

The elements of the www.asterale.fr website (texts, graphic identity, logo, editorial content) are protected by copyright and trade mark law.

Article 16. Complaints and mediation

Any complaint may be sent:

• by email: sebastien.bailly@asterale.fr;
• by post: ASTERALE, for the attention of Mr Sébastien Bailly, 4 allée Django Reinhardt, 94110 Arcueil, France.

ASTERALE undertakes to acknowledge receipt within 10 working days and to give a reasoned reply within 2 months at most.

Failing an amicable solution, a consumer Client may refer the matter free of charge to the competent mediator:

• for disputes relating to financial investment advice: the AMF Ombudsman, Autorité des marchés financiers, 17 place de la Bourse, 75082 Paris Cedex 02 (www.amf-france.org/fr/le-mediateur);
• for disputes relating to insurance broking and intermediation, banking and payment services intermediation and property transactions: ANM Conso (Médiation de la consommation), 2 rue de Colmar, 94300 Vincennes, France, telephone +33 1 58 64 00 05, contact@anmconso.com (www.anm-conso.com).

Article 17. Force majeure

Neither party shall be liable for non-performance or delay in performance of its obligations in the event of force majeure within the meaning of Article 1218 of the French Civil Code. Financial or organisational difficulties do not in themselves constitute force majeure.

Article 18. Evidence

The parties expressly agree that communications, signatures and documents exchanged electronically (email, electronic signature compliant with the eIDAS Regulation, exchange of scanned documents) have the same evidential value as a paper document and a handwritten signature.

Article 19. Governing law and jurisdiction

The Terms are governed by French law.

In the event of a dispute, and after the mediation procedure has failed, the French courts have exclusive jurisdiction. For a professional Client, exclusive jurisdiction is conferred on the Créteil Commercial Court. For a consumer Client, the statutory rules of territorial jurisdiction apply.

Article 20. Severability and entire agreement

If any provision of the Terms is held invalid or unenforceable, the other provisions remain in full force.

The Terms, supplemented by the engagement letter, the client information document (document d'entrée en relation, DER) and, where applicable, the specific conditions of each product, constitute the entire agreement between the Client and ASTERALE regarding the services concerned.

Document updated on 16 September 2026. For any question about these Terms: +33 6 28 54 13 74 or sebastien.bailly@asterale.fr.

The French version prevails.