GENERAL TERMS AND CONDITIONS
Date: 12.03.2025
1. Preamble
These are the General Terms and Conditions (“GTC”) of AFRANGA EOOD, UIC
206337510, having its seat and registered address at: city of Sofia, Mladost 4, 79B
Alexander Malinov boulevard, fl. 5, represented by Svetlin Sabev, Managing Director,
hereinafter referred to as “Afranga”, which lay down the rights, obligations, and
procedures governing the use of Afranga’s crowdfunding platform. The GTC set out the
terms under which project owners, investors, and Afranga interact within the
crowdfunding platform.
Afranga is a licensed crowdfunding service provider under Regulation (EU) 2020/1503 of
the European Parliament and of the Council of 7 October 2020 on European
crowdfunding service providers for business, amending Regulation (EU) 2017/1129 and
Directive (EU) 2019/1937 (the “Regulation”), registered with the Financial Supervision
Commission in Bulgaria according to Decision № 863-ДУКФ as of 12.09.2023, and
operating a crowdfunding platform that facilitates granting of loans available on Afranga’s
website www.afranga.com, referred to as the “Platform”.
The Platform consists of software with specific functionalities, database management
software, database, texts and images. The specific functionalities of the software provide
the ability to perform the functions necessary for carrying out crowdfunding activities
Afranga, without taking on own risk, facilitates the matching of the interests of prospective
lenders (investors) with businesses (project owners) that seek funding.
2. Definitions
All specific terms used in these GTC not explicitly defined bellow shall be
interpreted in accordance with the definitions of the Regulation.
2.1. Participants in the crowdfunding process
2.1.1. “Investor”
- means any natural or legal person who, through Afranga’s
crowdfunding platform, provides loans for the purposes of crowdfunding.
Afranga defines investors as “sophisticated” and “non-sophisticated”.
Afranga will offer its services to both “sophisticated” and “non- sophisticated” Investors.
Afranga treats all Investors as “non-sophisticated” for the purposes of the Regulation,
unless, after checking the criteria in accordance with Annex II to the Regulation and after
explicit notification, the Investor is qualified as “sophisticated”.
The Investors may be one of the following:
Va) Natural persons who are legally competent, of legal age and are either citizens or have
a permanent residence permit from a Member State of the European Union or of the
European Economic Area, or Switzerland.
b) Legal persons established in a Member State of the European Union or of the
European Economic Area, or Switzerland.
2.1.2. “Project Owner”
Platform.
– means any legal entity which seeks funding through the
2.1.3. Lemonway is the licensed payment service provider, which carries out the transfer
of funds between the other participants in the crowdfunding process.
Lemonway is a French simplified joint-stock company (société par actions simplifiée),
named LEMONWAY, registered with the Paris trade and companies register under
number 500 486 915. Lemonway provides Payment Services within the meaning of article
L. 314-1 of the French Monetary and Financial Code as a payment institution within the
meaning of article L. 522-1 of the French Monetary and Financial Code.
It is licensed by the French Prudential Supervisory and Resolution Authority (ACPR) on
24 December 2012 with Interbank Code CIB 16568. This information may be verified at
any time on the website https://www.regafi.fr or in the European Banking Authority (EBA)
register.
2.2. Other terms
2.2.1. “Data Protection Legislation” means any applicable laws, regulations, and
guidelines related to the processing, storage, and transfer of personal data, including but
not limited to the General Data Protection Regulation (EU) 2016/679 (GDPR), the
Bulgarian Act for Protection of Personal Data and any national implementing legislation
thereto, as well as any statements, resolutions, rulings, guidelines, etc. of the Bulgarian
Commission for Protection of Personal Data.
2.2.2. “Intellectual Property” means all patents, utility models, know how, trademarks,
business and trade names, domain names, logos, copyrights and related rights, database
rights, trade secrets and other confidential information, any other similar intellectual or
commercial rights (in each case whether or not registered or capable of registration),
together with all applications for registration of any of the foregoing and the rights to apply
for, as well as any licenses to use any of the foregoing and rights or protections
howsoever described of the same or similar effect or nature in any part of the world.
2.2.3. “Investment” means giving a loan to the Project Owner under the terms of a:
2.2.4. “Loan” means an amount of money provided by Investors to the Project Owner
through the Platform, subject to repayment under the agreed terms specified in the Loan
Agreement.
2.2.5. “Loan Agreement” means a legally binding agreement between the Project Owner
and an Investor that sets out the terms and conditions under which the Investor provides
a Loan to the Project Owner, including repayment obligations, interest rates, and any
applicable fees.
2.2.6. “Personal Data” means any information relating to an identified or identifiable
natural person, as defined under the Data Protection Legislation.
2.2.7. “Project” means the particular crowdfunding endeavour presented by the Project
Owner to potential Investors on the Platform, aimed at attracting financing which to be
used by the Project Owner for a particular purpose as defined in the particular Project
description included in the Key Investment Information Sheet (“KIIS”).
2.2.8. “Tax” means (whether disputed or not) any state, local, or foreign income tax, gross
receipts tax, payroll tax, employment tax, excise tax, severance tax, stamp duty,
occupation tax, environmental tax, franchise tax, social security tax, withholding tax,
customs duties, or any similar governmental charge imposed by any Governmental Entity
in the Republic of Bulgaria or any other jurisdiction, including any penalties, interest, or
additional charges associated therewith.
2.2.9. “User” means a a person who has registered on the Platform, the registration has
been approved and a User Profile has been created. Users can be potential and current
Investors and Project Owners.
2.2.10. “User Profile” means a feature on the Platform, allowing the Investors and Project
Owners to register as a user for the purposes of participating in the crowdfunding process
in accordance with their designated role within that process.
2.2.11. “Visitors” means natural or legal persons who have accessed the website
www.afranga.com without registering a User Profile.
3. Subject of these GTC
3.1. These GTC govern the relationship between the Investors and Afranga and their
rights and obligations.
3.2. These GTC also contain a statement of certain obligations that the Project Owners
may have towards the Investors and Afranga. The relationship between the Project
Owners and Afranga and their rights and obligations are comprehensively regulated in a
separate agreement.
3.3. The relationship between the Project Owners and the Investors and their rights and
obligations after making an Investment are regulated by the specific loan agreement
pursuant to which the Investment is made.
3.4. The provisions of each separate agreement concluded between Project Owners and
Investors, as well as between them both and Afranga shall prevail over the provisions of
these GTC. For all matters not being subject of these agreements, as well as in case of
discrepancy or uncertainties in their interpretation and implementation, the GTC, as well
as the applicable law of the Republic of Bulgaria shall apply.
3.5. These GTC are deemed accepted by the Users upon successful completion of their
registration and are binding for them as of that moment onward.
4. Access to the platform
4.1. The Platform is publicly available to any person who has the necessary hardware
and Internet access and visits the Internet address www.afranga.com.
4.2. Afranga does not allow restriction of access to the Platform or the use of the offered
services for collective financing, including based on criteria such as race, gender, social
status or other discriminatory criteria.
4.3. Visitors have the right to familiarize themselves with the freely published information
on the Platform, including: the published financing proposals and general information
about the functionalities of the Platform, including these GTC. Visitors do not have the
opportunity to use the functionalities of the Platform.
4.4. The User Profile provides the opportunity for Users to use the functionalities of the
Platform. The User Profile consists of separate pages on the Platform, accessible only to
the User Profile’ owner, by entering identification data (such as name and password).
4.5. To create a User Profile, the visitor must complete the registration process by
providing the required personal information, agreeing to these GTC, and successfully
verifying their identity independently or through a third party external provider (such as
Veriff: https://www.veriff.com/). Afranga reserves the right to request additional
information or documents to confirm the User’s identity and ensure compliance with legal
and regulatory requirements.
4.6. Users are responsible for maintaining the confidentiality of their login credentials and
must not share them with third parties. Afranga is not liable for unauthorized access
resulting from the User’s failure to safeguard their credentials.
4.7. Afranga reserves the right to suspend or terminate a User Profile in case of suspected
fraudulent activity, violation of these GTC, or non-compliance with applicable laws.
4.8. Any activity performed through a User Profile is deemed to have been carried out by
the respective User. By clicking a checkbox, button, or engaging in any similar action on
the Platform to indicate agreement or consent, the User provides an electronic signature
as defined under Regulation (EU) No 910/2014. According to Article 13.4 of the Bulgarian
Electronic Documents and Electronic Certification Services Act the parties to these GTC
give their consent and agree that such electronic signature shall have the same legal
effect as a handwritten signature. Via such electronic signature the Users enter into Loan
Agreements, accept the present GTC, etc.
4.9. With the creation of User Profile, the User is deemed to have authorized Afranga to
act on their behalf in dealings with the participants in the crowdfunding process and any
other third parties, to the extent necessary to protect the User’s rights and legitimate
interests (including, but not limited to authorization for court procedures and handling of
disputes, negotiations, conclusion of settlements and court settlements under pending
Loans, enforcement proceedings, etc. against other Users of the Platform). This does not
create obligation of Afranga to exercise its powers and Afranga retains the right to refrain
from taking any action.
5. Entry knowledge test and simulation of the ability to bear loss
5.1. In order to provide adequate protection to Investors, Afranga categorizes each
Investor as:
a) Non-sophisticated Investor; or
b) Sophisticated Investor.
Categorization is done during the process for creation of a User Profile (“Registration”).
5.2. As part of the Registration, Investors must complete a dedicated request form which
is available during the Registration for establishing their categorization. During the
Registration the Investor will be asked to pass a knowledge test and do a simulation
before Afranga provides the respective services under these GTC. If the input of the
Investor meets the criteria for categorization as a Sophisticated Investor, the Investor
may be asked to provide additional evidence that he/she meets the criteria for a
Sophisticated Investor as set out in these GTC.
5.3. If Afranga is unable to carry out the categorization due to reasons beyond its control,
each Investor shall be classified as non-sophisticated.
5.4. Investors may request to change their categorization through their User Profile.
Knowledge test
5.5. The purpose of the test is to assess whether and which proposed crowdfunding
services are suitable for the Investor, whether the Investor has the necessary experience
and knowledge to understand the risks associated with the types of investments offered
on the Platform and in general.
5.6. In order to carry out the assessment, Afranga may request specific information about
the Investor’s understanding of the risks associated with lending through the Platform,
and their professional experience of investing through crowdfunding, including but not
limited to:
a) types of investment services and financial investments with which the Investor is
familiar with; the nature, volume and frequency of past transactions in transferable
securities, eligible instruments for crowdfunding purposes or loans, including in early or
expansion stage businesses, and the period during which they have occurred; the level
of education and occupation or relevant prior occupation, including any professional
experience or skills acquired in connection with crowdfunding investments;
b) investment objectives and, where appropriate in relation to the type of collective
financing service offered, requests information on the expected holding period of the
investments, their risk profile and preferences regarding the sustainability of the
investments.
Simulation
5.7. For the purpose of making the assessment under clauses 5.1. to 5.6. above, Afranga
requires the Investors to make a simulation of their loss bearing capacity. The simulation
may be carried through an online tool provided by the Platform. The tool calculates the
loss-absorbing capacity of the Investors based on their input.
5.8. The simulation shall test the ability of the Investors to incur a loss, calculated as 10%
of their net worth. For this purpose, Afranga has the right to request and collect the
following information concerning each Investor:
a) total income and whether the income is permanent or temporary;
b) assets, including financial investments and any cash deposits, excluding personal and
investment real estate and pension funds;
c) financial expenses, including regular, current or future expenses.
5.9. Any Investor categorized as non-sophisticated shall:
a) pass a knowledge test every two years after the entry knowledge test; and
b) complete a simulation every year after the initial simulation.
5.10. Afranga does not bear responsibility of the result of the knowledge test and the
simulation in case the Investor has submitted false or incomplete information. The online
tool is provided only for informational purposes and its results/outcome have to be
confirmed by the Investor.
6. Categorization of the investors
6.1. Any Investor who does not meet the criteria for a Sophisticated Investor set out in
paragraph 6.4 below will be categorized as non-sophisticated.
6.2. Non-sophisticated Investors can benefit from a higher level of protection in respect
of their investment opportunities through the Platform and will be advised more frequently
of the risks that may arise in investing in the Projects.
6.3. Certain services may not be suitable for Investors categorized as non-sophisticated
and therefore the provision of these services may be refused by Afranga.
6.4. Afranga will classify as sophisticated, even without obtaining their consent to do so,
an Investor who has the experience, knowledge and expertise to make their own
investment decisions and properly evaluate the risks while participating in the
crowdfunding process and meets the following requirements:
6.4.1. For legal entities, at least one of the following criteria:
a) registered capital of at least EUR 100 000;
b) a net turnover of at least EUR 2 000 000;
c) a balance sheet total of at least EUR 1 000 000.
6.4.2. For natural persons, at least two of the following criteria:
a) a personal gross income of at least EUR 60 000 per financial year or a portfolio of
financial instruments which includes, by definition, cash deposits and financial assets in
excess of EUR 100 000;
b) the Investor works or has worked for at least one year in a professional position in the
financial sector that requires knowledge of the transactions or services envisaged, or has
held a managerial position for at least 12 months in a legal entity referred to in point 6.4.1
above;
c) during the previous four quarters, the Investor has executed an average of 10
transactions of significant size per quarter in the capital markets.
6.5. Investors categorized as sophisticated are required to:
a) promptly provide Afranga with information about changes that may affect such
Investors’ compliance with the requirements set forth for their status as a Sophisticated
Investor pursuant to clause 6.4.;
b) at the request of Afranga, provide documents that prove the accuracy of the information
provided.
6.6. Afranga shall also designate as a Sophisticated Investor any person who is a
professional client as defined in Section I, points 1, 2, 3 or 4 of Annex II to Directive
2014/65/EU.
6.7. Afranga is entitled to assume that an Investor categorized as sophisticated is able to
independently obtain the information necessary to make investment decisions in the
Projects.
Recategorization
6.8. An Investor categorized as non-sophisticated may request to be recategorized as
sophisticated by submitting the request to Afranga through the Platform or by email.
6.9. In order to be categorized as sophisticated, the Investor must meet the criteria in
clause 6.4. Afranga has the right to reject the request without providing reasons for the
rejection.
6.10. The categorization as Sophisticated Investor granted by Afranga shall be valid for
two (2) years. An Investor who wishes to retain their sophisticated categorization after the
expiration of the two (2)-year validity period must submit a new request to be categorized
as a Sophisticated Investor. If the Investor fails to submit a new request for categorization
after the expiry of the two (2) year validity period, the latter shall be recategorized as a
Non-sophisticated Investor.
6.11. In the event that Afranga receives reliable information from which it can be
concluded that the Investor no longer qualifies as a Sophisticated Investor, Afranga shall
have the right to revoke its decision regarding the Investor’s categorization and re-
categorize the Investor as non-sophisticated.
6.12. In any case, an Investor categorized as sophisticated may request to change its
categorization and be recategorized as non-sophisticated by submitting the request to
Afranga through the Platform or by email.
6.13. Any recategorization shall be made after a completion of knowledge test and
simulation.
Investment restrictions
6.14. Afranga warrants that each time a Non-sophisticated Investor accepts an individual
offer, thereby investing an amount in excess of the higher of EUR 1,000 or 5% of such
Investor’s net worth calculated in accordance with the simulation (provided that the Non-
sophisticated Investor has provided such data), the Non-sophisticated Investor:
a) will receive a risk warning informing them that investing in the Project involves a risk of
losing the entire amount invested;
b) will be asked to acknowledge receipt of the risk warning and to give express consent
to the investment;
c) he will be asked to demonstrate that he understands the investment and its risks. The
knowledge test and/or simulation may be used as evidence that the Investor understands
the investment and its risks.
7. Investing mechanism
Prior to listing a Project on the Platform Afranga has the right to conduct a due diligence
of the Project Owner about its good standing, ownership, financial and legal status,
licensing, ongoing litigation procedures, regulatory compliance, and any other relevant
factors that may affect its eligibility.
Afranga has also the right to conduct an assessment of the proposed Project in order to
evaluate its compliance with the applicable laws, Platform requirements, and investor
protection standards. For each Project, submitted for listing on the Platform, the Project
Owner shall prepare and submit a KIIS in accordance with Article 23 of the Regulation,
which contains clear, fair, and non-misleading information.
Primary market
7.1. Investors are entitled to:
- create their own User Profile through which they can use the functionalities of the
Platform;
- request the opening of an investment account in their name, deposit and withdraw funds
to the account, make transfers to the Project Owners on the investments made, receive
funds accumulated as a result of the investments made and monitor the movement and
balance of their investment account;
- access the Projects offered through the Platform, information documents and other
marketing communications;
- submit orders and conclude transactions (Loans) when the orders are executable;
- obtain information on the reflection period during which they can withdraw their
investment, the moment from which it starts, as well as submit orders to withdraw their
commitment for conclusion of a Loan Agreement (this functionality is only available for
Non-sophisticated Investors);
- receive confirmation of their transactions, as well as electronic copies of Loan
Agreements and any other documentation concluded in electronic form;
- access information about their investment portfolio (open positions, active orders, with
all their details) and historical information about their investments;
Date: 12.03.2025
- receive and submit notices, communications and documents from/to Afranga;
- receive and file notices, communications and documents from/to the Project Owners in
whose Projects they have invested;
- carry out a simulation of their loss-absorbing capabilities (online tool);
- sign Loan Agreements and any other relevant documentation in electronic form as per
art. 4.8. above.
7.2. Project Owners are entitled to:
- create User Profile reflecting their role in the crowdfunding process;
- request the opening of a Project Owner account in their name, deposit and withdraw
funds to the account, make transfers to the Investors on the investments made, receive
funds accumulated as a result of the fundraising conducted and monitor the movement
and balance of their account;
- obtain a complete statistical report on their active and closed Projects, including financial
parameters, Investors who have invested in their Projects, credit data, etc;
- receive confirmation of their transactions, as well as electronic copies of Loan
Agreements and any other documentation concluded in electronic form;
- receive and submit notices, communications and documents from/to Afranga;
- receive and submit notices, communications and documents from/to Investors who have
invested in their Projects;
- sign Loan Agreements and any other relevant documentation in electronic form as per
art. 4.8. above.
Project selection. Execution of an order
7.3. Through the Platform, the Investor has the opportunity to make an investment in the
listed Projects. After selecting a Project or offering in which they wish to invest, the
Investors can submit an order for the conclusion of a Loan Agreement through the
available functionalities of the Platform.
7.4. The Platform’s software executes orders in the order they are received. When
executing an order, the software automatically, without any discretion, processes the
order subscribed in terms of sender of the order, the amount of the investment, the place
and time of submission of the order, etc. The software’s algorithm does not allow for
changes to the operating model, nor external interference or influence in the execution of
specific orders, such as “manual” adjustments by employees. The software algorithm
does not allow unauthorised changes to orders once executed or to the order in which
they are received.
7.5. The Platform offers two ways to invest:
a) Manually
The Investor enters the amount they wish to invest in a particular Project. By clicking on
a specially marked button, the Investor consents to enter into a Loan Agreement under
the terms of the KIIS to that Project.
b) Filtering and using the “Auto Invest” function
Afranga may introduce in the future a functionality on the Platform where the Investor can
filter Projects according to criteria set forth by them in the Platform. Different criteria
combinations may be proposed by Afranga in this regard or the Investor may choose
manually what criteria to apply. The Investors can enter the amount they wish to invest in
more than one Project at the same time. The amount indicated by the Investor is allocated
under different Projects according to criteria predefined by the Investor until it is
exhausted. By clicking on a specially marked button, the Investors give their explicit
consent for the conclusion of Loan Agreements in all the Projects they have filtered.
Fundraising
7.6. In the KIIS of each Project the Project Owner indicates the amount of funds to be
borrowed under a Project proposal and the deadline for borrowing funds.
7.7. Once the maximum parameters of the proposal have been reached, such as: the
maximum amount of funds to be lent and the expiry date of the proposal, the Project will
cease to be active.
7.8. In the KIIS of each Project the Project Owner shall indicate the consequences if the
minimum amount of funds to be borrowed is not reached within the time limit for
borrowing.
7.9. Non-sophisticated Investors are granted a pre-agreement reflection period in
accordance with Article 22 of the Regulation.
Agreement conclusion
7.10. The Loan Agreement between the Investor and the Project Owner is deemed to be
concluded after the automatic processing of the Investor’s order to make the investment.
The Project Owner explicitly agrees that by submitting a Project on the Platform all Loan
Agreements concluded at the initiative of Investors are binding for the Project Owner
which has signed them as per art. 4.8. above (without any need for further confirmation).
7.11. The reflection period under clause 7.9, during which Non-sophisticated Investors
may withdraw their investment order, starts from the moment the investment order is
made and expires in 4 (four) calendar days. During reflection period the funds designated
by an Investor to be granted under a Loan Agreement shall be deducted in the User
Profile and cannot be invested in any other Project. If a right of withdrawal is exercised,
the funds will be returned to the User Profile.
7.12. If a withdrawal is made during the reflection period, the Non-sophisticated Investor
is not required to point out a reason and shall not suffer any penalty.
7.13. The withdrawal procedure is similar to that of placing an order, whereby the
Investors have the option to withdraw the order by clicking on a specially marked button
via their investment account on the Platform.
Completion of the fundraising. Notifying the Project Owner of Investor interest in a
Project
7.14. Once the maximum parameters of the crowdfunding Project campaign have been
reached, or the campaign has expired (except in the case of a Project being withdrawn),
the fundraising process ends.
7.15. Afranga notifies the Project Owner of the outcome of the fundraising phase, which
contains details of the amount of funds raised, the number of Investors who have
expressed an interest, the size of each individual investment and other details of the
fundraising process.
Payment services. Making payments on Projects
7.16. All payments on the Platform are carried out through Lemonway (or another
designated licensed payment service provider). Afranga does not take or hold any funds
on behalf of or for the account of the Project Owner and/or the Investors.
7.17. By using the services of Lemonway (or another designated licensed payment
service provider) the Users on the Platform may be obliged to engage directly with such
third-party service providers (accept separately their respective Terms and Conditions,
etc.).
7.18. The investment accounts opened in the name of the Investors may only be used to
make payments related to specific Projects offered on the Platform, namely:
- for investing funds under Projects selected by the Investor;
- to receive payments on the Loans granted, as well as contractual interest, penalties and
other payments to the Investors.
8. Warnings
8.1. The Investor accepts and agrees that investing in Projects entails risks, including the
risk of partial or complete loss of the invested funds, and that his/her investment is not
covered by guarantee schemes, including the deposit guarantee scheme or the investor
compensation scheme operating in the Republic of Bulgaria.
8.2. The Investor acknowledges and agrees to the following:
a) The Investment may not generate any returns;
b) The Investment is not a savings product, and Afranga advises Investors to limit their
investment in crowdfunding projects to no more than 10% of their net worth;
c) The Investor may not be able to sell the investment instruments at his/her discretion,
and even if a sale is possible, there may be losses;
d) The Projects have not been reviewed or approved by the Financial Supervisory
Authority, the European Securities and Markets Authority (“ESMA”) or any other
regulatory body in the EU.
8.3. The Investor acknowledges and agrees that Afranga will not be held responsible for
any loss or lost profits arising from the preceding points, for which liability lies with the
Investor, the Project Owner, or third parties.
8.4. The Investor acknowledges and agrees that Afranga does not provide investment
advice or recommendations. While Afranga may publish and review all relevant
documents, information, and marketing materials related to each Project, this should not
be construed as advice, endorsement, or a recommendation regarding the investment’s
reliability, quality, or suitability. The Investor is solely responsible for conducting their own
research, assessing the risks, and making an informed decision regarding whether to
invest. Any decision to invest will be based entirely on the Investor’s independent
judgment, without reliance on any information provided by Afranga.
9. Complaints
9.1. Any User who is dissatisfied with the services provided by Afranga may file a
complaint. The complaint procedures do not apply to complaints made by persons or
organisations who are not Users of Afranga.
9.2. Afranga will consider written complaints filled in and submitted in Bulgarian or
English:
a) Online through the Platform or via e-mail to: [email protected].
b) On paper by a letter sent to Afranga’s address – Sofia 1715, Mladost 4 District, 91
Aleksandar Malinov Blvd., fl. 6
Complaints may be submitted also via the specifically designated standard complaint
form.
9.3. Afranga will consider a complaint inadmissible if it is made orally, if it relates to an
activity or service that Afranga does not perform or if the complaint does not meet the
criteria for submission of complaints.
9.4. The complaint must include the User’s personal data, information about the
representative (if applicable), a full description of the problem and all related documents
(KIIS, Project, Loan Agreement, etc.). In case of incomplete or inaccurate contact details,
Afranga is not responsible for its inability to contact the User.
9.5. Upon receipt of an admissible complaint, Afranga makes due effort to resolve it
promptly and fairly. Afranga assesses whether the request in the complaint is clear and
complete and reviews all attached documents. If necessary, Afranga may request
additional evidence and/or information.
9.6. Afranga will consider and make a decision on each admissible complaint within 20
(twenty) working days as of the date of its receipt. In case the complaint is inadmissible,
the decision shall be made within 20 (twenty) working days as of the date of elimination
of the reasons for inadmissibility.
9.7. In exceptional cases where Afranga is not able to make a decision within the specified
period, Afranga sends a special notification to the User, explaining the reasons for the
delay and indicating a new deadline for resolving the complaint.
9.8. All results are provided to the User in writing.
9.9. If the User is not satisfied with the decision, they have the right to:
a) file a complaint with the Financial Supervision Commission (FSC), with website:
www.fsc.bg, address: Bulgaria, 1000 Sofia, 16 Budapeshta Str., email: delovod-
b) file a civil claim, by referring the matter for resolution to the court of the Republic of
Bulgaria in accordance with the current laws and regulations of the Republic of Bulgaria,
to the extent permitted by law, except where applicable law requires a specific dispute to
be resolved exclusively by the courts of another jurisdiction.
9.10. The full procedure for filing a complaint is available on the Platform.
10. Data protection
10.1. Afranga takes due care to protect the Personal Data of its Users, in strict compliance
with the provisions of the Data Protection Legislation, as well as the Privacy Policy
approved by Afranga on 01.03.2025, which can be accessed on the following website:
https://afranga.com/privacy-policy.
10.2. In compliance with the applicable legislation and the clauses of these GTC, Afranga
may use the Personal Data of the Users solely and exclusively for the purposes of fulfilling
its contractual obligations, including with a view to providing technical assistance when
using the Platform by the User.
10.3. Afranga has the right to use the Personal Data provided by the User for the purposes
of direct marketing (i.e. offering goods and/or services, as well as for sending other
advertising and commercial communications) only with explicit consent to this effect.
10.4. Each User of the Platform has the right to exercise their rights arising from the Data
Protection Legislation in accordance with the procedure provided for in the Afranga
available here
Privacy Policy [ ].
10.5. Each User may stop sending materials related to direct marketing to him/her by
sending a letter in free text to the email address: [email protected], or to the
correspondence addresses specified in the Afranga Privacy Policy [ available here
].
10.6. The Platform may also collect data from “cookies”. For more information about what
cookies are, what they are used for and what types of data Afranga may collect about its
Users through them, you can read Afranga’s Cookie Policy [ available here
].
.Dispute resolution
11.1. All disputes between Afranga and the Investors shall be resolved in a spirit of
understanding and good will. In the event that no agreement is reached, all unresolved
disputes arising from or relating to the contract between the parties, including disputes
arising from or relating to its interpretation, invalidity, performance or termination, as well
as disputes to fill gaps in the contract or adapt it to newly arising circumstances, shall be
resolved in court by the competent Bulgarian court.
11.2. For all issues not regulated in these GTC, the laws of Bulgaria and the acts of the
European Union with direct effect shall apply, including the Regulation, and the acts
implementing them.
12. Fees and outsourcing of activities
12.1. When investing on Afranga, Investors may be subject to additional fees for the
services provided by Afranga. A full list with all applicable fees in accordance with the
Afranga Tariff is available here. The fees, which are due by the Project Owners are
regulated by a separate agreement between the respective Project Owner and Afranga.
12.2. Afranga is not obliged to report and/or deduct any Tax. Each User is obliged to
report and deduct Tax, which may be due as a result of Investments made and any
interaction with the Platform. Depending on various tax related legal circumstances, the
Project Owners may be obliged to withhold Tax in their country of registration in full
amount.
12.2. The User agrees that additional fees or charges may be payable to third parties
(such as banks and other payment institutions) in connection with the realization of the
Investment and the repayment of the Loan, which will not be related to or arise directly
from the relationship between the User and Afranga.
12.3. Afranga may outsource the following operational activities:
- Accounting activities;
- Technical support of hardware;
- Payment services;
- Identification of Users.
Afranga may also outsource the implementation of other operational activities, subject to
the outsourcing procedures specified in this document.
13. ADDITIONAL PROVISIONS
13.1. These GTC may be amended and supplemented unilaterally by Afranga, in which
case the Users will be notified of the change no later than 7 (seven) days before the entry
into force of the updated GTC on the email addresses indicated by the Users in their User
Profile.
13.2. The invalidity of any part of these GTC does not affect the validity of its other
provisions.
These General Terms and Conditions are effective as of 12.03.2025.
The Platform may contain links to websites that are owned or operated by third parties
and not by Afranga. These links are provided only for the convenience of the Users.
Afranga has no control over and is not responsible for the content, privacy policies or
security of such sites.
Company details:
Afranga EOOD
Address: Bulgaria, 1715 Sofia, 79B Aleksandar Malinov Blvd., 5th Floor
Email: [email protected]
Financial Supervision Commission details:
Address: Bulgaria, 1000 Sofia, 16 Budapeshta Str.
Tel: 02 / 940 49 99
Fax: 02 / 940 46 06
Information centre: 0800 40 444
E-mail: [email protected]
Website: www.fsc.bg
Personal Data Protection Commission details:
Address: Bulgaria, 1592 Sofia, 2 Prof. Tsvetan Lazarov Str.
Tel: 02/915 35 19
Fax: 02/ 915 35 25
E-mail: [email protected]
Website: www.cpdp.bg